Contrary to the favourable opinion of more than half a dozen FPMs contacted several years ago, the Operations Lead for the National FAASTeam, Kevin Clover, does not think that flight activities can be completed under WINGs with non-FAA instructors. The ground portion of the flight review can still be met through WINGs knowledge courses/seminars/webinars.
I have asked my local FAAST team manager for an answer. He did not know the answer and is running it up the flag pole. Asking the FAA General Counsel is the only way to get a definitive answer short of an NTSB court case.
NCYankee wrote:
One could send a request to the FAA General Counsel to get a definitive answer
Or one could read what @Qalupalik wrote and not poke the bear :) alas, from the post above, it looks like the damage has been done.
FAA AC 61-91J (WINGS—Pilot Proficiency Program), point 6(c)(1) states that:
Airmen must accomplish flying tasks with a qualified instructor and that instructor
must verify that the airman accomplished the selected tasks to the appropriate standards. Airmen
can accomplish documentation of these events online when the instructor, or other identified
representative, verifies the accomplished work. …
No interpretation is given to the term “qualified instructor” in the circular. The term used in Part 61 is “authorized instructor” which among other things means a “person authorized by the Administrator to provide ground training or flight training under part 61, 121, 135, or 142 of this chapter when conducting ground training or flight training in accordance with that authority.” 14 CFR 61.1(b). If the terms are synonymous then the WINGS flight activities could be accomplished with a non-FAA instructor outside the US pursuant to 14 CFR 61.41.
All but one of the nine FPMs I contacted some years ago agreed with this conclusion. However, a logbook endorsement such as model A.66 in FAA AC 61-65H could not be given by a non-FAA instructor. Instead this endorsement would be made by the FPM who awarded WINGS credit after determing that the non-FAA flight training covered the required WINGS flight activities.
At any given moment the FAA Safety Team has nearly a hundred program managers. Most of those I contacted some years ago have moved on or retired. On the recommendation of an FPM in the Southwest Region the question has been raised for review at the national level. This should ensure requests of this nature are handled consistently. It is also possible an unfavourable policy will emerge. Will report back when more is known.
alioth wrote:
I also think this means if you know an FAA CFI but can’t visit them (e.g. because of COVID), you can get the flight credit done with a foreign instructor so long as your FAA CFI is prepared to do what is necessary to validate it.
“Please find attached recent photo of me flying plane. Please print logbook entry on adhesive backed paper, my return address is as follows” 
The FAQ states:
“As an alternative, you can also request credit through your account using another CFI or authorized validator in our system. You will need to be able to provide them verification that you completed the activity.”
I think that’s what Qalupalik was getting at with the FAASteam managers, they could be a validator if you can’t find an FAA CFI to do it.
I also think this means if you know an FAA CFI but can’t visit them (e.g. because of COVID), you can get the flight credit done with a foreign instructor so long as your FAA CFI is prepared to do what is necessary to validate it.
In any case I will probably have to test that this is practical – at the current time, there seems to be no way I can see an FAA instructor before needing a BFR; our borders are currently sealed as tightly as a duck’s arse (due to COVID) and I don’t see this changing before March is out. However, I could use a local instructor for the flight parts, so long as I can find someone who is prepared to do what is needed to do the validation of this.
alioth wrote:
The contention in this thread though is the flight part of Wings can be done by any instructor, not just an FAA CFI.
The flight part needs to be validated by an FAA CFI. The WINGS program is documented in AC 61-91J, but the best answer I’ve found is in the FAQ here..
Of course, one can always fudge the system but at the end of the day an FAA CFI needs to validate the result either by direct entry in the FAA system or a log book entry.
….. comment overlap. @NCYankee has given the complete answer, so my short form is superfluous.
NCYankee wrote:
To get into the instructor portion of the Wings program, you have to be an FAA certified instructor.
But according to this:
…flight instruction by a non-FAA instructor is creditable towards the flying portion of Wings. The FAASTeam manager would have to do something on the Wings website to apply the credit.
chflyer wrote:
I do not believe that an FAA flight review can be completed without any actual flight (i.e. Wings ground study only). The Wings exercises can fulfill the ground/theory portion of the flight review.
I agree with your opinion. 61.56 Flight Review language for the Wings program states:
(e) A person who has, within the period specified in paragraph (c) of this section, satisfactorily accomplished one or more phases of an FAA-sponsored pilot proficiency award program need not accomplish the flight review required by this section.
61.195 Flight instructor limitations and qualifications.states in part:
a) A person who holds a flight instructor certificate is authorized within the limitations of that person’s flight instructor certificate and ratings to train and issue endorsements that are required for:
…
(7) A flight review, operating privilege, or recency of experience requirement of this part;
I interpret item (7) includes signing an endorsement for the flight training provided in the Wings program as specified in AC No: AC 61-91J which states:
h. Authorization for Completing WINGS Tasks. An authorized instructor can record
completed tasks of WINGS not recorded automatically at www.FAASafety.gov in a logbook or
other proficiency record with an endorsement similar to the following. This provides verification
for later recording at www.FAASafety.gov by an authorized individual:
“I certify that (pilot’s name), holder of pilot certificate No. XXXXX, has satisfactorily
demonstrated proficiency in the required tasks as outlined in the WINGS—Pilot Proficiency
Program, activity number XXX on (date).”
“Instructor Name, Certificate Number, Expiration Date, and Signature”
To get into the instructor portion of the Wings program, you have to be an FAA certified instructor.
The section authorizing training credit from flight instructors is limited to training for a pilot certificate or rating and does not include the certification endorsement privilege:
61.41 Flight training received from flight instructors not certificated by the FAA
(a) A person may credit flight training toward the requirements of a pilot certificate or rating issued under this part, if that person received the training from:
(1) A flight instructor of an Armed Force in a program for training military pilots of either—
(i) The United States; or
(ii) A foreign contracting State to the Convention on International Civil Aviation.
(2) A flight instructor who is authorized to give such training by the licensing authority of a foreign contracting State to the Convention on International Civil Aviation, and the flight training is given outside the United States.
(b) A flight instructor described in paragraph (a) of this section is only authorized to give endorsements to show training given.
One could send a request to the FAA General Counsel to get a definitive answer.
The contention in this thread though is the flight part of Wings can be done by any instructor, not just an FAA CFI.
