Sim, a FAA emitiu uma Carta de Interpretação do seu Conselho Chefe em maio de 2015, que abrange Verificações de proficiência da Seção 61.58 e aborda especificamente essa questão.
Ele diz que um piloto pode continuar atuando como PIC durante o mês de graça sob as Partes 91, 121 e 135. Ele diz (em parte e ênfase adicionada por mim):
Section 61.58(i) states that, if a pilot completes the proficiency check in the calendar month before or the calendar month after the month it is due, "the pilot is considered to have taken it in the month in which it was due for the purpose of computing when the next pilot-incommand proficiency check is due."
You have asked whether the language in paragraph (i) creates a "grace month" during which a pilot whose currency has lapsed under paragraph (a) may continue to act as pilot in command. The FAA has previously stated in a legal interpretation that § 61.58 includes a "grace month" for purposes of complying with the 12- and 24-month proficiency check requirements. We did not explicitly state, however, that a pilot may continue to act as PIC during this grace month. Legal Interpretation to Sean Conlin (Feb. 24, 2000). We have indicated, however, that similar provisions in parts 121 and 135 create a "grace month" during which a pilot may to continue to act as PIC during the month after the pilot's currency has lapsed? Legal Interpretation to Gregory S. Winton (2006), Legal Interpretation to J. Dennis Vanatta (June 25, 1996).
The FAA intended the grace month to limit disruptions in operations conducted under parts 121 and 135 by accommodating pilots who are unable to complete recurrent training requirements in the month they are due. At the same time, the FAA did not want operators to use the grace month as a means of regularly extending a 12-month proficiency check to a 13-month proficiency check. For that reason, a proficiency check under part 121 or part 135 that is completed in the grace month is considered to be completed in the month it is due. The FAA believes that the same approach is appropriate for§ 61.58 proficiency checks. As such, a pilot may continue to act as pilot in command during the month after a§ 61.58 proficiency check is due. However, when a pilot completes a §61.58 proficiency check during this grace month, it is considered to have been completed during the month it was due for the purpose of calculating the next proficiency check.