My son is working his way towards ATP quals while flight instructing and still lacks a ME class rating. The thinking is to get the ME, buy time to reach the 15 hours PIC requirements for MEI and build time to meet the 25 hours ME requirements regional require as mins for hiring. In discussing his (future) training, he asked/advised me that the time required under instruction toward the ME could not be logged as PIC due to the fact that it was a different airplane class. Intrigued (mainly because it's going to ultimately cost me more $$$$) I have been digging into the regs. First I verified that 15 hours PIC of ME is the minimum required for a MEI add-on to a CFIA. The next part is my question, seeking advice from those with a better understanding of the reg.

FAR 61.51 deals with logbooks and defines (among other things) the requirements for logging PIC. My drilling down gets me to 61.51 (e) (1) (iv) (B), which I'll share.

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation -........

My question is, What qualifies as an, "approved pilot in command training program that includes ground and flight training", as far as the FAA is concerned? . Must it be "approved" as in an FAR 141 school, or can a 61 program at an FBO be approved, as far as the letter of the law? Logging training as PIC from the start of ME training vs waiting to have the fresh ticket would mean several thousand of dollars not spent towards the 15 hour PIC requirement for the MEI. Looking at advertising online from several ME programs (that I assume are not 141) it isn't clear, they don't address the PIC issue when pricing a MEI add-on.