 According to AOPA's Jared Allen, a BasicMed pilot who wants to act as a safety pilot under FAR 91.109(c) without a medical certificate must meet all currency and qualification requirements to act as PIC, and to act as PIC during the portions of the flight in simulated instrument conditions.Even though the pilot under the hood cannot simultaneously act as PIC, the simulated instrument flight still satisfies that pilot’s recent flight experience requirements for a PIC under FAR 61.57, since that regulation does not require the pilot to be acting as PIC while he or she performed the required tasks during the simulated instrument flight.FAR Part 61.57 (c) Instrument experience.