In case Mr Skidmore hasn't read the submissions to and report of the Aviation Safety Regulatory Review, here are some quotes.
From pages 10-11 of the submission by that hot-bed of aviation fringe dwellers and risk-takers, the Australian and International Pilots’ Association (AIPA):
AIPA’s most frequent and often most frustrating interaction with CASA is through the Aviation Medicine Branch. The frustrations arise due to the inconsistent administration of medical clearances and certificates, the near impossibility of being able to talk to anyone about the administration processes and, most critically, what most members report as the CASA-unique approach of disregarding practicing medical specialists’ advice in favour of “riskbased” decisions made by non-practicing medical bureaucrats.
...
AIPA is most concerned about the immediate uncertainty caused to a member when the often expensive advice and tests are considered to be acceptable by DAMES and specialists but not by the Principal Medical Officer (PMO). Where else are they to turn? The problem is often exacerbated by the turnaround times, the best of which is 28 days, but as the applicant you will rarely be made aware that the clock has not started because some component of the required information is “missing”, at least until you can break through the communication firewall to ask as to what point your certificate has progressed in the administrative sequence.
Paragraph 13 of the submission by the aviation equivalent of base-jumpers, the Australian Federation of Air Pilots (AFAP):
13. The Aviation Medicine section of CASA in particular appears to act without due regard for the impact its decisions have on individual pilots and the industry. There is little or no communication about delays in the medical certificate renewal process or transparency about the reasons for delays occurring. Certificate holders are obliged to follow up with the section to find out why their certificates have not been renewed only to receive requests for additional medical reports and tests. The Federation has received numerous complaints from members as to the apparently arbitrary nature of decisions and the bureaucratic and incompetent processing of renewals. These delays threaten the livelihood of our members, and undermine the productivity of the businesses for whom they work. We have previously surveyed members and written to the former Minister on this issue1. An overhaul of the Aviation Medicine section of CASA should be a priority. This would include additional resources, clearer processes, specified service standards and improved training of staff.
From page 7 of the submission by a representative of notoriously inexperienced aviators, the Aerial Agricultural Association of Australia:
One area in particular that struggles with continuous improvement is CASA’s aviation medicine branch. Examples are plentiful of questionable rulings on pilot medicals that fly in the face of genuine expert opinion (for example in cardiology) and result in the trashing of careers for no safety purpose. The ability of the branch to hide behind the facade of medical qualifications is well known in industry and under current systems, is an almost unassailable position that has drifted far from actual safety issues, or the leading non-CASA advice on medical issues.
AOPA's submission, paragraph 9:
9. Medicals. This is probably the single biggest continuous issue that causes acrimony between GA pilots and CASA. Problems with Avmed include delays in dealing with medical assessments, rejection of DAMEs opinions, demands for ever more complex specialist reports that many would consider unnecessary, and which are then frequently ignored by Avmed itself. Avmed has unique medical opinions which sometimes do not agree with overseas experience, eg; FAA. Communication between CASA, AVMED and pilots has often been poor.
For what purpose? Most GA pilots intend to fly themselves and perhaps a few associates, mostly in VFR during daylight. Motor vehicle licencing is nothing like this, yet driving is only slightly less stressful.
CASA should rely on its own DAMEs for issue of class 2 medicals, and where specialist opinion is required, CASA should at least listen to specialist opinion.