License renewal · Implicit bias
Implicit Bias Training for License Renewal: Which States Require It and for Whom
A state-by-profession matrix of every implicit bias renewal rule we could verify for physicians, PAs, nurses and pharmacists, with the hours, cycles, 2026 changes and proof each board expects.
Reviewed October 2026 against 20 ILCS 2105 and IDFPR rules, Michigan LARA rules, the California Business and Professions Code and BRN regulations, Maryland, Massachusetts, Washington and New Jersey statutes and board notices, and the FSMB CME overview (August 2026)
Short answer: As of October 2026, seven states attach implicit bias training to health license renewal. Illinois (1 hour every renewal) and Michigan (1 hour per year of the cycle) apply it to nearly all licensed health professionals, including physicians, PAs, nurses and pharmacists. Maryland requires a one-time attestation for every health occupations board, Massachusetts requires 2 credits for physicians, and Washington requires health equity CE that must include implicit bias. California builds implicit bias content into CME and nursing CE courses rather than setting a separate hour, and New Jersey applies a 1-credit rule only to clinicians who provide perinatal care.
Key takeaways
- Illinois requires at least a one-hour implicit bias awareness course every renewal period for licensees under 24 health practice acts, and the hour counts toward existing CE.
- Michigan requires 1 hour of implicit bias training for each year of the license cycle at renewal and 2 hours within the 5 years before a first license; only veterinarians are excluded.
- From July 1, 2026, Illinois clinicians who report providing prenatal or postnatal care must take an hour that includes maternal health risk factors for racial and ethnic groups with higher maternal mortality.
- Maryland renewal applicants must attest to an approved implicit bias and structural racism training program at their first renewal after April 1, 2026; it is a one-time requirement.
- California physicians have no separate implicit bias hour: since January 1, 2022, CME courses with a patient care component from California providers must contain implicit bias curriculum.
- Who provides the course matters. Most of these states accept only board-approved, accredited or otherwise recognized providers, so check provider rules before you enroll.
The state-by-profession matrix
Implicit bias rules are written in three different ways, and that is why search results feel contradictory. Some states set a fixed number of hours each renewal. Some make it a one-time attestation. California instead regulates what goes inside CME and CE courses. The matrix below puts all seven states on one grid so you can find your own row and column quickly.
| State | Physicians (MD/DO) | PAs | Nurses | Pharmacists | How often |
|---|---|---|---|---|---|
| California | Yes Content inside every California-provider CME course with patient care; no separate hour | Yes Same content standard for PA CE | Yes Content in BRN-approved CE, plus 1 hour within the first two years of licensure | No No implicit bias rule; 1 hour of cultural competency instead | Built into each course; new-nurse hour once |
| Illinois | Yes 1 hour | Yes 1 hour | Yes 1 hour (LPN, RN, APRN) | Yes 1 hour | Every renewal; maternal content from July 1, 2026 if you report maternal care |
| Michigan | Yes 1 hour per year of cycle | Yes 1 hour per year of cycle | Yes 1 hour per year of cycle | Yes 1 hour per year of cycle | Every renewal; 2 hours before a first license |
| Maryland | Yes Attestation | Yes Attestation | Yes Attestation | Yes Attestation | One-time; structural racism added at first renewal after April 1, 2026 |
| Massachusetts | Yes 2 credits | Not covered by the physician rule | Not covered by the physician rule | Not covered by the physician rule | Each initial and renewal application |
| Washington | Yes 2 hours health equity | Yes 2 hours health equity | Yes 2 hours health equity | Yes 1 hour health equity | Physicians and PAs every 4 years; nurses and pharmacists each renewal period |
| New Jersey | Yes 1 credit if you provide perinatal care | Yes 1 credit if perinatal | Yes 1 credit if perinatal | Not covered by the perinatal law | Each biennial renewal, within existing CE |
Sources: 20 ILCS 2105/2105-15.7; Mich. Admin. Code R 338.7004; Cal. Bus. & Prof. Code 2190.1 and BRN/PA Board rules; Md. Health Occ. 1-225; Massachusetts BORIM; RCW 43.70.613 and Washington board rules; N.J. P.L.2021, c.79; FSMB CME overview, August 2026.
Two patterns stand out. First, if you hold a license in Illinois or Michigan, profession barely matters: the rule follows the license, not the specialty. Second, in the other five states the answer depends on exactly who you are and what care you provide, so the detail sections below matter more than the grid. For the full renewal picture in your profession, including total hours and other mandatory topics, start from our United States hub.
Hours, content standards and attestations: three kinds of rule
Before reading the state detail, it helps to know which kind of rule you are dealing with, because each one changes what you actually have to do at renewal.
A set number of hours each cycle
Illinois, Michigan, Massachusetts, Washington and New Jersey. You must complete and record a specific amount of training before you renew. This is the type that gets checked in CE audits.
Confirm once that you completed approved training
Maryland. You attest on the renewal application that you completed a program on the state's approved list. Once done, it does not repeat.
Bias content inside other courses
California. The obligation sits mainly on CME and CE providers, who must weave implicit bias curriculum into their courses. Clinicians do not log a separate implicit bias hour (with one exception for newly licensed nurses).
"California physicians need one hour of implicit bias CME every renewal."
No separate hour exists. Business and Professions Code 2190.1(d) requires that CME courses contain implicit bias curriculum from January 1, 2022, with exemptions for courses without a direct patient care component and for providers located outside California.
"Michigan's training is a one-time requirement."
It applies at every renewal. LARA's FAQ is explicit that it is not one-time: 1 hour for each year of the cycle, every cycle.
"Maryland's implicit bias requirement is finished, so there is nothing new."
A 2025 law added structural racism training. Renewal applicants must attest to an approved implicit bias and structural racism program at their first renewal after April 1, 2026.
Illinois: one hour every renewal, now with maternal health content
Illinois has the clearest statute. Section 2105-15.7 of the Department of Professional Regulation Law requires every covered health care professional who has continuing education requirements to complete at least a one-hour course in implicit bias awareness per renewal period. The covered list runs to 24 practice acts, including the Medical Practice Act, Nurse Practice Act, Pharmacy Practice Act, Physician Assistant Practice Act, Illinois Dental Practice Act, and acts for psychologists, social workers, counselors, therapists, optometrists, podiatrists, respiratory care practitioners and genetic counselors.
IDFPR's rule fills in the detail. The requirement applies to renewals on or after January 1, 2023, is a condition of renewing, and must be repeated every renewal period. If you hold more than one covered license, you do not have to repeat the course for each one.
What the Illinois course must cover
The rule sets four content elements, so a general diversity session may not be enough:
- What implicit bias is and how it differs from explicit bias
- How implicit bias develops and operates
- Its effects and the harm it can cause
- How to recognize, interrupt and reduce it
The course may be delivered in a classroom, by webinar or online. Accepted sources include Division-approved CE providers, providers recognized under each licensing act, state, county and municipal agencies, federal agencies, accredited Illinois colleges and universities, and licensed health care institutions training their own staff. Training completed for another state, an accreditor or an employer can count if it meets these minimums.
Maternal implicit bias from July 1, 2026
Public Act 104-0061, effective January 1, 2026, amended the statute so that, on and after July 1, 2026, licensees who report to IDFPR that they provide maternal health care services (defined as prenatal or postnatal care) must take an hour that includes potential maternal health risk factors for childbearing individuals in marginalized racial or ethnic groups with higher maternal mortality rates. This is not an extra hour. It changes what your one hour must contain. Obstetricians, family physicians who provide prenatal care, nurse midwives and labor and delivery nurses are the obvious groups, but the trigger is what you report, not your job title.
Menopause courses can count from 2027
A further amendment, Public Act 104-0755, takes effect January 1, 2027. It keeps the maternal health rule and adds that, from that date, a course covering perimenopause and menopause may count toward the one-hour implicit bias requirement. If you renew in 2027 or later, read your profession's renewal notice to see how IDFPR applies this alongside the maternal content rule.
Illinois physicians also have separate recurring topics (sexual harassment prevention, dementia and others). Those sit outside this article; see our Illinois physician CME guide for the full CME picture.
Michigan: one hour per year of your cycle, for almost every license
Michigan's requirement comes from a LARA administrative rule, not a statute, and it applies to every profession licensed or registered under the Public Health Code except veterinary medicine. That includes medicine, osteopathic medicine, physician assistants, nursing, pharmacy (including pharmacy technicians), dentistry, psychology, counseling, social work and the therapy professions.
First license
At least 2 hours of implicit bias training completed within the 5 years immediately before the license or registration is issued.
Every renewal
At least 1 hour for each year of the license cycle. On a 3-year license, that is 3 hours, which you may complete in one 3-hour session.
The current rule, last amended effective May 16, 2024, adds three practical points:
- No carryforward. Extra hours earned in one cycle cannot be moved into the next.
- No double counting of repeats. A course identical or substantially identical to one you already took in the same cycle earns no extra hours.
- It can overlap other CE. Unless your profession's rules say otherwise, the hours may also satisfy other CE requirements.
The rule also sets content standards: training must relate to reducing barriers and disparities in access to and delivery of health care, cover at least one listed topic area, and include strategies to reduce disparities and pre- and post-test implicit bias assessments. Accepted formats are live teleconferences or webinars with real-time interaction, live in-person sessions, and asynchronous (recorded or self-paced) teleconferences or webinars. Sponsors must fall into the rule's categories: nationally or state-recognized health organizations, state or federal agencies, board-approved education programs, accredited colleges and universities, and organizations specializing in diversity, equity and inclusion. LARA does not pre-approve programs, so it is up to you to check that a course meets the standards.
Michigan physicians have several other renewal topics, including pain and symptom management. Our Michigan physician CME guide covers the full renewal cycle.
California: a content rule for CME and CE, plus an hour for new nurses
California is the state most often described inaccurately. Assembly Bill 241 (2019) did not create an implicit bias hour for physicians. It amended Business and Professions Code 2190.1 so that, on and after January 1, 2022, all CME courses must contain curriculum that includes the understanding of implicit bias. Each course must address at least one of two things: examples of how implicit bias affects perceptions and treatment decisions and leads to disparities, or strategies to address how unintended biases lead to differences in treatment by race, ethnicity, gender identity, sexual orientation, age, socioeconomic status or other characteristics.
Two exemptions matter. Courses dedicated solely to research or other topics without a direct patient care component are exempt, and so are courses offered by providers not located in California. In practice, the obligation falls on providers, and a California physician meets it simply by taking ordinary CME.
Physician assistants
AB 241 applied the same approach to PAs through Business and Professions Code 3524.5. The Physician Assistant Board's rule, approved in January 2022 and operative April 1, 2022, provides that beginning January 1, 2022, any CME course with a direct patient care component must include curriculum on understanding implicit bias.
Registered nurses: two separate rules
For nurses there are two layers. First, under section 2736.5 (also from AB 241), BRN-approved CE courses must contain curriculum on implicit bias, with an exemption for courses without a direct patient care component. Second, AB 1407 (2021) added a stand-alone hour: all licensees must complete one hour of implicit bias training within the first two years of licensure. This matters because California RNs are otherwise exempt from CE during their first two years. The amended rule took effect July 1, 2024, and the Board decided not to allow exemptions from this hour.
Pharmacists: cultural competency, not implicit bias
California pharmacists do not have an implicit bias renewal rule. Instead, since January 1, 2024, at least one of the 30 renewal hours must be a cultural competency and humility course focused on lesbian, gay, bisexual, transgender, gender nonconforming and queer patients. The topics overlap, but a general implicit bias course does not automatically meet this specific requirement.
Separately, California's Dignity in Pregnancy and Childbirth Act requires hospitals, alternative birth centers and primary care clinics to give perinatal providers evidence-based implicit bias training, with refreshers every two years. That is an employer obligation, not a license renewal rule, but it can be useful evidence of training if a board or employer asks.
Challenge to California's CME implicit bias rule
A physician and the group Do No Harm challenged section 2190.1(d) on First Amendment grounds. The Ninth Circuit affirmed dismissal on July 25, 2025, treating required CME content as government speech, and denied rehearing on December 29, 2025. A petition for certiorari (Khatibi v. Yip, No. 25-1240) was distributed for the Supreme Court's September 28 and October 9, 2026 conferences; when we checked the docket on October 13, 2026, it showed no grant or denial. The requirement remains in force while the petition is pending.
Source: Supreme Court of the United States, docket No. 25-1240
Maryland, Massachusetts, Washington and New Jersey
These four states each take a narrower or different route. Read the card for any state where you hold a license.
One-time attestation, now including structural racism
Under Health Occupations 1-225, as amended by HB 783 (Chapter 478, 2025), renewal applicants for any license or certificate from a health occupations board must attest to completing an implicit bias and structural racism training program approved by the Cultural and Linguistic Health Care Professional Competency Program. The attestation applies only at your first renewal after April 1, 2026. Under Health-General 20-1306, approved programs must be recognized by a health occupations board or accredited by the ACCME or ACPE, and the Program provides its list of approved programs on request.
2 credits on implicit bias in health care
Since June 1, 2022, physicians applying for or renewing a license need at least 2 credits on implicit bias in health care, counted within the 10 risk management credits already required. Two 1-credit courses are acceptable if together they meet the Board's goals and objectives. AMA PRA Category 1 or Category 2 credit may be used.
Health equity CE that must include implicit bias
RCW 43.70.613 required each board to adopt health equity CE rules by January 1, 2024, with training at least once every four years. The Department of Health's model standard requires implicit bias training that identifies strategies to reduce bias during assessment and diagnosis. Physicians and PAs need 2 hours every four years; nurses need 2 hours each renewal period; pharmacists need 1 hour each renewal cycle.
1 credit on explicit and implicit bias
P.L.2021, c.79 requires physicians, PAs, and professional and practical nurses who provide perinatal care to include 1 credit on explicit and implicit bias within their existing CE as a condition of biennial renewal. Midwives have a parallel requirement, and hospitals with maternity services must run their own bias training program.
Maryland's Board of Nursing confirms that the trainings are required only once: if you already attested to implicit bias training at an earlier renewal, you do not repeat it, but you still need the structural racism component at your first renewal after April 1, 2026.
Washington's boards set the detail. The Medical Commission adopted 2 hours every four years for physicians and PAs, within existing CME, effective January 1, 2024. The Pharmacy Commission set at least 1 hour per renewal cycle for pharmacists and pharmacy technicians, without changing total hours. For nurses, the Board of Nursing gave existing RNs and LPNs until their 2026 renewal date to complete the first 2 hours; new applicants have until their second renewal.
Some states require cultural competency rather than implicit bias. FSMB lists Oregon (1 hour of cultural competency each year for Oregon Medical Board licensees), the District of Columbia (2 hours of LGBTQ cultural competency), Nevada (a one-time 2 hours on HIV-related stigma, discrimination and unrecognized bias for physicians and PAs who provide or supervise emergency medical services in a hospital or primary care facility) and Connecticut (cultural competency as an optional risk management topic). Treat these as their own requirements, not as implicit bias rules.
What changed and what is coming: 2022 to 2027
Most of the confusion online comes from pages written before 2026. These are the dates that change what you need to do.
CME courses with a patient care component from California providers must include implicit bias curriculum.
Michigan renewals on or after this date need implicit bias training; Massachusetts physicians need 2 credits.
All covered Illinois health licensees renewing on or after this date need the one-hour course.
Medical Commission rules for physicians and PAs take effect (pharmacists follow on January 18, 2024); California pharmacist cultural competency hour begins.
BRN regulation requires 1 hour of implicit bias training within the first two years of licensure.
Applies at your first renewal after this date, across all health occupations boards.
Licensees who report maternal health care must cover maternal health risk factors in their hour.
A perimenopause and menopause course may count toward the one-hour requirement.
Choosing a course your board will accept
The single biggest risk with implicit bias training is taking a course that does not count. Every state above limits who can provide qualifying training, and the limits differ.
| State | Who can provide qualifying training | Pre-approval list? |
|---|---|---|
| Illinois | Division-approved CE providers, providers recognized under each act, government agencies, accredited colleges, licensed health care institutions; must also meet your profession's CE rules | No single list; check your profession's CE sponsor rules |
| Michigan | Recognized health organizations, government agencies, board-approved programs, accredited colleges, DEI-focused organizations | No; LARA does not pre-approve |
| California | Built into courses from approved CME/CE providers; new-nurse hour from a BRN-approved provider | Provider approval, not course lists |
| Maryland | Programs approved by the state competency program; must be board-recognized or accredited by the ACCME or ACPE | Yes; the Program provides its approved list on request |
| Massachusetts | Courses meeting Board goals; AMA PRA Category 1 or 2 | Board suggests examples |
| Washington | Training meeting the model health equity standard, delivered by trainers with health equity expertise | DOH lists example trainings |
| New Jersey | Within existing CE for your profession; facility programs must allow CE credit | No |
Sources: 68 Ill. Adm. Code 1130.500; LARA FAQ and R 338.7004; Cal. B&P 2190.1 and 16 CCR 1452; Maryland MHHD; Massachusetts BORIM; RCW 43.70.613; N.J. P.L.2021, c.79.
Our own courses are education. Where a course is useful is in building real understanding of the topic, or in supporting a board-ordered or employer-requested learning plan, after you have checked what your board accepts.
Proving completion if your board audits you
Implicit bias hours are easy for boards to check because they are a named requirement. Michigan is the most specific: submitting your renewal counts as certifying compliance, you must keep documentation for 6 years, and if selected for audit you need a completion certificate or a self-attestation showing the date, sponsor name, program title and your name. Illinois makes completion a condition of renewal, and Maryland relies on your signed attestation, so in both states a missing certificate becomes a problem only when someone asks for it.
Find your renewal date and cycle length
In Michigan the hour count depends on cycle length; in Illinois and Maryland the dates of July 1, 2026 and April 1, 2026 decide whether new content applies to you.
Confirm what your profession's board accepts
Check the provider rules in the table above before you pay for a course, not after.
Match content, not just the title
Illinois has four required elements and, from July 2026, maternal content for some licensees. Michigan requires pre- and post-test implicit bias assessments. Washington requires implicit bias strategies for assessment and diagnosis.
Save the certificate the day you finish
Store it with your other renewal records, named by state and cycle, so a multistate audit does not turn into a search.
Attest accurately
Only attest once the training is complete. If you are short, contact the board before renewing rather than after.
If an audit does go wrong, our guide to what happens after a failed CE audit explains the usual board process and how to respond.
Mistakes that cause renewal problems
- Assuming Michigan's rule is one-time. It repeats every cycle and scales with cycle length, so a 3-year license needs 3 hours.
- Counting the same course twice in Michigan. A repeat of a course you already took in the same cycle earns no additional hours.
- Treating a general diversity session as the Illinois hour. The course must cover the four elements in the IDFPR rule, and maternal content if you report maternal care after July 1, 2026.
- Forgetting Maryland's new component. Licensees who completed implicit bias training in 2022 still need structural racism training at their first renewal after April 1, 2026.
- New California RNs skipping CE altogether. The usual two-year exemption does not cover the one-hour implicit bias requirement.
- Using an out-of-state course to "prove" California compliance. Providers outside California are exempt from the content rule, so their courses may contain no implicit bias content at all. Normally this does not affect the physician, but do not cite such a course as implicit bias training elsewhere.
- Keeping certificates in only one place. Multistate licensees can be audited by different boards years apart; Michigan alone expects 6 years of records.
Your implicit bias renewal checklist
- List every state where you hold an active license, including compact privileges you rely on
- For each one, find your row and column in the matrix above
- Note whether the rule is an hour count, an attestation or a content standard
- Check whether the July 1, 2026 (Illinois) or April 1, 2026 (Maryland) dates apply to your next renewal
- Confirm the provider meets your board's rules before enrolling
- Download and file the certificate with the date, sponsor, title and your name visible
- Review your profession's full renewal requirements on our physician, nursing, pharmacist or PA renewal pages
Health Equity, Implicit Bias and Respectful Care
A self-paced course of about 3 hours for US physicians, PAs, nurses, pharmacists and other licensees. It covers health equity as a professional duty, non-discrimination law including Section 1557, bias in clinical judgment, algorithms and the medical record, disability access, and responding to bias from patients and colleagues, with a section on state implicit bias and health equity rules. It ends with a 20-question scenario assessment and a reflective account. It is education and does not replace training your board requires from an approved provider.
Our courses are education.
Frequently asked questions
Do I need implicit bias training if I hold a license in Michigan but practice in another state?
Yes. Michigan's rule applies to anyone renewing a license under the Public Health Code, wherever they practice. If you keep the Michigan license active, you need 1 hour for each year of the cycle at renewal.
Can one course satisfy several states at once?
Often, if it meets each state's content and provider rules. Illinois explicitly accepts training completed for other states or accreditors if it meets its minimums, and Michigan lets the hours overlap other CE. Maryland is stricter because the program must be on its approved list.
Does implicit bias training add hours to my total CE requirement?
Usually not. Illinois, Massachusetts, Washington and New Jersey count it within existing hours. Michigan allows it to satisfy other CE unless your profession's rules prohibit that.
Are dentists and therapists covered too?
In Illinois and Michigan, yes: both rules reach dentists, psychologists, counselors, social workers and the therapy professions. Maryland covers every health occupations board. California, Massachusetts and New Jersey rules are narrower.
Is Illinois maternal implicit bias training a separate hour?
No. From July 1, 2026, licensees who report providing prenatal or postnatal care must take an implicit bias hour that includes maternal health risk factors. It replaces the content of the standard hour rather than adding a second one.
Will the Supreme Court case end California's requirement?
Not unless the Court takes the case and rules against the state. When we checked the docket on October 13, 2026, the certiorari petition in Khatibi v. Yip showed no grant or denial and the Ninth Circuit's decision upholding the rule stood, so the requirement remains in effect.
Do Texas, Florida or New York require implicit bias training for renewal?
The FSMB August 2026 overview lists no implicit bias CME requirement for physicians in Texas, Florida or New York, and we found none for nurses or pharmacists in the official sources we reviewed. Each has its own mandatory topics, so check your board's current renewal requirements.
Official sources
- Federation of State Medical Boards: Continuing Medical Education Board-by-Board Overview (updated August 2026)
- Illinois General Assembly: 20 ILCS 2105/2105-15.7, Implicit bias awareness training
- Illinois Administrative Code: 68 Ill. Adm. Code 1130.500, Implicit Bias Awareness Training
- Illinois General Assembly: Public Act 104-0061 (maternal health content, effective January 1, 2026)
- Illinois General Assembly: Public Act 104-0755 (perimenopause and menopause course, effective January 1, 2027)
- Michigan LARA: Implicit Bias Training Frequently Asked Questions
- Michigan Administrative Code: R 338.7001 to R 338.7005, Public Health Code General Rules (implicit bias training standards)
- California Legislative Information: Business and Professions Code section 2190.1
- California Board of Registered Nursing: Adopted regulation text, 16 CCR 1450 and 1456 (implicit bias in CE courses)
- California Board of Registered Nursing: OAL approval of 16 CCR 1452, Continuing Education Requirements; Exemptions
- Physician Assistant Board of California: OAL notice of approval, 16 CCR 1399.616, Approved Continuing Medical Education Programs (implicit bias)
- California State Board of Pharmacy: Board meeting materials, December 2023 (cultural competency CE, B&P 4231)
- Supreme Court of the United States: Docket No. 25-1240, Khatibi v. Yip
- Maryland Department of Health, Office of Minority Health and Health Disparities: Implicit Bias and Structural Racism Training for Healthcare Professionals
- Maryland Board of Nursing: Implicit Bias and Structural Racism Training Notice
- Massachusetts Board of Registration in Medicine: FAQ for Implicit Bias in Healthcare CME
- Washington State Legislature: RCW 43.70.613, Health equity continuing education
- Washington Administrative Code: WAC 246-12-830, Health equity continuing education model rules
- Washington State Register: WSR 23-24-033, Medical Commission health equity CE for physicians and PAs
- Washington State Register: WSR 24-01-101, Pharmacy Commission health equity CE
- Washington State Board of Nursing: Continuing Competency
- New Jersey Legislature: P.L.2021, c.79 (explicit and implicit bias training for perinatal care)
Checked October 2026.