License renewal · Michigan MD & DO
Michigan Physician CME: 150 Hours With Ethics, Pain Management and Implicit Bias Rules
What a Michigan MD or DO must complete for each three-year renewal, how the two boards' rules differ, how the implicit bias hours fit inside the cycle, and which one-time trainings sit outside the 150 hours.
Reviewed October 2026 against Mich Admin Code R 338.2441-2443 (Board of Medicine; R 338.2443 amended March 2026), R 338.141-143 (Board of Osteopathic Medicine and Surgery, amended May 2025), R 338.7004, R 338.3135, MCL 333.17033 and LARA licensee FAQs
Short answer: Michigan physicians must complete 150 hours of CME in the three years immediately before each license renewal. Within those hours, MDs need at least 75 Category 1 hours and DOs at least 60, and both need 1 hour of medical ethics and 3 hours of pain and symptom management (including 1 hour on controlled substance prescribing). Separately, every licensee must complete 1 hour of implicit bias training for each year of the license cycle, and physicians must have completed one-time human trafficking training and, if they hold a Michigan controlled substance license, opioid and controlled substance awareness training.
Key takeaways
- The 150-hour total comes from MCL 333.17033 for MDs and the matching osteopathic section; the detail lives in two separate rule sets, R 338.2441-2443 (Board of Medicine) and R 338.141-143 (Board of Osteopathic Medicine and Surgery).
- Both rule sets were updated recently: the DO rules took effect May 8, 2025, and the MD continuing education rule (R 338.2443) was amended effective March 19, 2026.
- Implicit bias is "1 hour for each year" of the cycle, not "1 hour in each year": LARA confirms a single 3-hour program can cover a 3-year license, and the hours may also count toward your 150.
- Michigan's implicit bias rule requires training to include strategies to reduce disparities and pre- and post-test implicit bias assessments, so check any program against those features before relying on it.
- There is no carryover: hours must be earned in the 3 years immediately preceding the renewal application, and implicit bias hours expressly cannot roll into the next cycle.
- LARA audits a sample of licensees after each renewal period, and real 2018 osteopathic board minutes show CME shortfalls resolved with probation, make-up hours and fines of $3,050 to $8,000.
Where Michigan's 150-hour rule comes from
The Public Health Code lets the Board of Medicine require proof of at least 150 hours of board-approved continuing education in the three years before a renewal application, in subjects related to medicine and including medical ethics. The same section directs the board to set, by rule, a required number of hours in pain and symptom management. The osteopathic board works under a parallel section of the code (MCL 333.17533).
The statute only sets the frame. The rules that tell you what actually counts are in the Michigan Administrative Code, and each board has its own set. For MDs, R 338.2441 sets the 150 hours and record keeping, and R 338.2443 sets the topic minimums, Category 1 and Category 2 activities and their caps. For DOs, R 338.141 and R 338.143 do the same job. The implicit bias rule sits in a third place, the Public Health Code general rules that apply to almost every licensed profession.
That split is why so many Michigan CME summaries online are incomplete. Many health-system pages list the MD numbers and stop, or still describe the DO rules as they stood before the May 8, 2025 amendments. If you want the national picture of how other states handle physician renewal, our physician license renewal guide covers California, Texas, Florida and New York; this page stays with Michigan.
Two 2025-2026 House bills would change the physician CME statute. HB 4920 would cut the requirement from 150 to 120 hours from January 1, 2027, but as of October 2026 it has not left the House Health Policy Committee. HB 4790, which would require the boards to make a CME course on women's midlife health (including menopause management) available and encourage physicians to take it, without adding a mandatory hour, passed the House in March 2026 and is in the Senate Health Policy Committee. Neither changes what you need today.
MD vs DO: two rule sets behind the same 150 hours
Michigan licenses MDs through the Board of Medicine and DOs through the Board of Osteopathic Medicine and Surgery, both administered by the Department of Licensing and Regulatory Affairs (LARA). The headline numbers match, but the mix of credit you can use does not. The biggest practical differences are the Category 1 floor, the DO requirement for osteopathic (AOA or MOA) credit, and how teaching, committee work and publishing are classified.
| Requirement | MD (Board of Medicine) | DO (Osteopathic Medicine and Surgery) |
|---|---|---|
| Total per 3-year cycle | 150 hours | 150 hours |
| Category 1 minimum | 75 hours | 60 hours |
| Osteopathic credit | Not required (AOA and MOA programs count as Category 1) | At least 40 hours from AOA or MOA approved programs |
| Approved program sponsors | ACCME (including joint providership), AMA, AAFP, AOA, MOA, Michigan State Medical Society; up to 150 hours | AOA or MOA (up to 150 hours); AMA, ACCME (including joint providership) or MSMS capped at 110 hours |
| Medical ethics | At least 1 hour | At least 1 hour |
| Pain and symptom management | At least 3 hours, 1 on controlled substance prescribing | At least 3 hours, 1 on controlled substance prescribing |
| Implicit bias counts toward 150 | Yes (R 338.2443(1)(e)) | Yes (R 338.143(1)(e), since May 2025) |
| Passing a specialty board exam | 50 hours Category 1 | 50 hours Category 1 |
| Maintenance of certification activities not otherwise approved | Up to 30 hours Category 1 | Up to 30 hours Category 1 |
| Residency or clinical training | 50 hours per year, up to 150 (5 months' enrollment in a 12-month period) | 50 hours per year, up to 150 (5 months' enrollment per year) |
| Teaching | Category 2: 2 hours per 50-60 minutes, up to 48 | Category 1: 2 hours per lecture or consultation, up to 90 |
| Peer-reviewed article (primary author) | Category 2: 6 hours, up to 24 | Category 1: 10 hours, up to 90 |
| Category 2 ceiling | Sum of activity caps (48 + 24 + 24 + 24 + 18) | 90 hours (presentations only, 10 hours each) |
| Keep CME records | 4 years after applying for renewal | 4 years after applying for renewal |
Source: Mich Admin Code R 338.2441 and R 338.2443 (R 338.2443 history: 2026 MR 6, effective March 19, 2026); R 338.141 and R 338.143 (2025 MR 11, effective May 8, 2025).
Two points in that table trip people up. First, a DO who takes all of their credit from ACCME-accredited courses will fall short: AMA, ACCME and MSMS credit is capped at 110 hours for DOs, and at least 40 hours must come from osteopathic programs. Second, the 2025 DO amendments added a 90-hour ceiling on Category 2 and made clear that programs from non-ACCME providers working in joint providership with ACCME-accredited providers count. The current MD rule lists the American Academy of Family Physicians alongside the AMA, ACCME and others as approving bodies.
The ethics hour and the three pain management hours
Both topic requirements sit inside the 150 hours, not on top of them. An accredited Category 1 activity on prescribing ethics can count toward the 150, the Category 1 floor and a topic minimum at the same time, provided its content genuinely matches the topic.
Medical ethics: at least 1 hour
The MD and DO rules each require a minimum of 1 hour in medical ethics per renewal cycle, and LARA's licensee FAQs repeat the point for both professions. The rules do not define a list of qualifying ethics topics, so the safest evidence is a certificate whose title or learning objectives make the ethics content obvious: professional boundaries, informed consent, conflicts of interest, end-of-life decisions, truthfulness with patients. Because the statute names medical ethics as a CME subject, the hour still needs to come from an activity that otherwise qualifies under R 338.2443 or R 338.143, which in practice usually means a Category 1 program.
Pain and symptom management: at least 3 hours
Both boards require at least 3 hours in pain and symptom management, and at least 1 of those hours must cover controlled substance prescribing. Both rules list qualifying topic areas, which include the public health burden of pain, Michigan pain and controlled substance laws, pain definitions, basic sciences and pharmacology, specific pain conditions, non-pharmacological and pharmacological management, quality pain care and Michigan pain management resources. A course on Michigan's MAPS requirements and safe opioid prescribing would typically fit the controlled substance hour; a general palliative care update would fit the other two.
This requirement applies to every renewing MD and DO, whether or not you prescribe controlled substances. It is separate from the one-time opioid awareness training covered later, which applies only to controlled substance licensees.
Implicit bias: one hour for each year, not in each year
Michigan's implicit bias requirement took effect on June 1, 2022 and applies across licensed health professions, not only physicians. For renewal, a licensee must have completed at least 1 hour of implicit bias training for each year of the license cycle, which for a three-year physician license means 3 hours. New applicants need 2 hours completed within the 5 years before the license is issued.
one hour FOR each year of the license or registration cycleLARA, Implicit Bias Training FAQs
That wording is the key to planning. LARA explains that the hours do not have to be spread one per calendar year: a single 3-hour program inside the cycle satisfies a 3-year license. What you cannot do is carry hours over, because the rule says implicit bias hours earned in one cycle cannot be used in the next, and repeating substantially identical training in the same cycle earns no extra credit.
What the training must contain
This is the part most summaries leave out. R 338.7004 requires training to relate to reducing barriers and disparities in access to and delivery of health care, to cover at least one of four listed topic areas (such as the historical basis and present consequences of bias, or current research on bias in health care), and to include both strategies to reduce disparities and the administration of pre- and post-test implicit bias assessments. Acceptable sponsors include nationally or state-recognized health-related organizations, state or federal agencies, board-approved CE programs, accredited colleges and universities, and organizations specializing in diversity, equity and inclusion. Live, interactive webinars, live in-person sessions and asynchronous webinars all qualify. LARA does not pre-approve programs.
How it interacts with your 150 hours
Both physician rule sets now say that implicit bias training completed under R 338.7004 in the 3 years before renewal may be used toward the CME requirement. For DOs this was added by the May 2025 amendments. If you choose an AMA PRA Category 1 or AOA Category 1 implicit bias program that includes the required assessments, the same 3 hours can serve the implicit bias rule, the 150-hour total and the Category 1 floor.
Keep the implicit bias certificate for 6 years, not 4: the general rule sets a longer retention period than the physician CME rules. If audited, you provide either a completion certificate or a self-attestation showing the date, sponsor, program title and your name. For how Michigan compares with California, Illinois and other states that require implicit bias training, see our implicit bias training by state guide.
Planning the three-year cycle year by year
Because every hour must fall in the three years immediately before your renewal application, it helps to plan backwards from the expiration date printed on your license in MiPLUS. LARA sends renewal notices roughly 90 days before expiration and you cannot renew earlier than that. The timeline below is one practical way to spread the work; nothing in the rules requires this exact order.
Complete the 1-hour medical ethics activity and the 3 hours of pain and symptom management (with the controlled substance prescribing hour clearly labeled). Start a folder for certificates. Aim for about 50 hours, mostly Category 1.
Complete the 3 hours of implicit bias training in one program or in pieces, checking that it includes pre- and post-test assessments. DOs should confirm they are on track for at least 40 AOA or MOA hours. Record any board exam, residency months, teaching or committee service you plan to claim.
Add up Category 1 (75 MD / 60 DO minimum), check Category 2 caps, remove anything duplicated in the same cycle, and fill gaps with Category 1 programs. Confirm your human trafficking certificate and, if you hold a controlled substance license, your opioid awareness certificate are on file.
Submitting the application certifies that you comply. CME is not uploaded with the renewal. Renewing late within the 60-day grace period costs a $20 late fee per license type; after that the license lapses as of the original expiration date.
LARA randomly audits after each renewal period. Keep CME proof 4 years, implicit bias proof 6 years and opioid training proof for 3 renewal periods plus 1 year.
A DO renewing in 2027
Dr. A holds a Michigan DO license and a controlled substance license, both renewing in early 2027. Her qualifying window is the three years before she submits the application. She passed her specialty recertification exam in 2025 (50 Category 1 hours), took a 3-hour AOA Category 1 implicit bias program with pre- and post-tests (counting toward implicit bias, Category 1 and the 40 osteopathic hours), and completed a 3-hour AOA pain management module with a 1-hour controlled substance prescribing segment. Add a 1-hour ethics session, 41 hours of AOA conference credit and 52 hours for teaching residents (26 scheduled lectures or clinical consultations at 2 hours each, Category 1 for DOs and within the 90-hour cap), and she reaches 150 hours, all Category 1, with 47 AOA hours. Her human trafficking and opioid awareness certificates from earlier cycles are still in her file.
One-time trainings that sit outside the 150 hours
Michigan has two trainings that physicians complete once rather than every cycle. Neither has to count toward the 150 hours, though a CME activity that meets the training standards can serve both purposes. The federal MATE Act training is a third, separate obligation for DEA registrants.
Human trafficking identification
A one-time training separate from CME. It must cover types and venues of trafficking, identifying victims in health care settings, warning signs in adults and minors, and reporting resources. It can be a course, webinar or a qualifying journal article. New applicants since December 2021 must complete it before licensure.
Opioid and controlled substance awareness
Required of anyone applying for or renewing a Michigan controlled substance license. It must cover use of MAPS and state and federal prescribing and dispensing law. Existing licensees had until the end of the first renewal cycle beginning after January 4, 2019; new licenses since September 1, 2019 require proof first.
MATE Act 8 hours
A one-time, 8-hour training on treating and managing opioid or other substance use disorders, attested on your next DEA registration submitted on or after June 27, 2023. It does not replace either Michigan training.
The human trafficking rules are R 338.2413 for MDs and R 338.120 for DOs, adopted under MCL 333.16148. LARA's FAQs describe it as "a one-time training that is separate from the continuing education requirement" and note that it counts toward CME only if the activity also meets the CME rules. No minimum length is set. If audited, you can show a provider certificate or a self-certification listing the provider, training name and date, or the article's title, author and journal details.
The opioid awareness rule, R 338.3135, was written by the Board of Pharmacy and applies to prescribers who hold a Michigan controlled substance license. Michigan's Prescription Drug and Opioid Abuse Commission recommended it as a one-time training, and the rule asks you to keep proof for 3 renewal periods plus 1 additional year, which is longer than any other Michigan physician record. The training complements, rather than replaces, the statutory duty to register with MAPS and to obtain and review a MAPS report before prescribing or dispensing a Schedule 2 to 5 controlled substance in more than a 3-day supply.
For the federal requirement, DEA's letter to registrants sets out who must complete the 8 hours and when. Our MATE Act 8-hour training guide explains which past training counts and how the attestation works.
What counts as Category 1 and Category 2 credit
Category 1 is where most hours come from. For MDs it means programs approved or offered by the ACCME (including joint providership), AMA, AAFP, AOA, MOA or Michigan State Medical Society, plus three special routes: 50 hours for passing a specialty board certification or recertification exam, up to 30 hours for other activities required to maintain specialty certification, and 50 hours per year (up to 150) for enrollment in a qualifying clinical training program for at least 5 months in a 12-month period. Proof is a letter or certificate showing your name, the hours, the sponsor and the completion date.
For MDs, Category 2 is a short, closed list: clinical instruction of medical students or residents when teaching is not your primary job (up to 48 hours), an initial scientific presentation (2 hours, up to 24), a peer-reviewed article (6 hours as primary author, 3 as secondary, up to 24), an initial textbook chapter (5 or 2 hours, up to 24) and committee service such as peer review or a state or national board, with at least 50% attendance (18 hours). Independent reading of journals is not on the MD list, so unaccredited self-study does not count toward the 150.
For DOs, many of those same activities are Category 1 rather than Category 2, with higher caps: teaching or precepting (up to 90), committee work (15 hours per committee per year, up to 90), inspections and specialty board clinical exams (up to 90), supervising a disciplinary limited licensee (up to 50) and publications (10 or 5 hours, up to 90). DO Category 2 covers only initial presentations to an osteopathic organization, at 10 hours each, within the overall 90-hour Category 2 ceiling.
Extra hours from this cycle roll into the next one.
There is no carryover. Hours must be earned in the 3 years immediately preceding the renewal application (R 338.2441(2); R 338.141(2)), and R 338.7004 expressly bars carrying implicit bias hours forward.
You need one implicit bias hour in each calendar year.
The rule is 1 hour for each year of the cycle. LARA confirms one 3-hour program completed within the cycle satisfies a 3-year license.
LARA approves CME courses, so anything on a provider list is fine.
LARA does not approve CME courses. It is your responsibility to make sure what you complete meets R 338.2443 or R 338.143 (LARA MD FAQ).
Human trafficking training counts as 1 hour of CME.
It is a separate, one-time requirement. It counts toward CME only if the activity also qualifies under the CME rules.
Repeating the same course each cycle earns full credit each time.
Across cycles it can, but within one renewal period credit is not given for a program identical or substantially equivalent to one already credited.
Renewal, audits and what a shortfall costs
When you submit a renewal application, that submission is your certification that you meet the CME rule. You do not upload certificates; the board does not keep CME records for you. LARA may then select a sample of renewed licensees and ask for proof, and failing to meet the rule is a violation of MCL 333.16221(h), which exposes the licensee to disciplinary sanctions.
| Record | How long to keep it | Acceptable proof |
|---|---|---|
| CME (MD and DO) | 4 years after applying for renewal | Sponsor letter or certificate with your name, hours, sponsor and date; activity-specific proof for exams, teaching, publications |
| Implicit bias | 6 years after applying | Completion certificate or self-attestation with date, sponsor, title and your name |
| Human trafficking | No period set; keep it for as long as you hold the license | Provider certificate or self-certification; article details if you read a journal article |
| Opioid and controlled substance awareness | 3 renewal periods plus 1 year | Completion certificate or self-attestation with date, provider, training name and your name |
Source: R 338.2441(3); R 338.141(3); R 338.7004; R 338.2413 and R 338.120; R 338.3135(3).
Five CME deficiency cases resolved the same day
The board's Disciplinary Subcommittee resolved five administrative complaints for deficient continuing education. In each, the physician was placed on probation to complete the deficient credits, which could not be applied toward current CE requirements for license renewal, and fined between $3,050 and $8,000, payable within 60 days. The minutes record: "Probation will be automatically discharged upon completion of the deficient CE and payment of the fine." Failure to comply would lead to suspension.
Source: LARA, Board of Osteopathic Medicine & Surgery Disciplinary Subcommittee approved minutes, December 6, 2018
The pattern in that example is common: a public disciplinary action, a fine and make-up hours that do not help the next cycle. If you are short of hours before renewal, both rule sets allow a waiver request, which must reach the department at least 30 days before the board's last regularly scheduled meeting before your license expires. If you have already been selected for audit and cannot document everything, our guide to what happens after a failed CME audit walks through the response.
Common mistakes
- DOs relying only on ACCME credit. AMA, ACCME and MSMS credit is capped at 110 hours for DOs, and 40 hours must be AOA or MOA.
- A pain course without a labeled prescribing hour. Auditors need to see that at least 1 of the 3 hours covered controlled substance prescribing; vague titles make that hard to show.
- Implicit bias training without the assessments. Michigan requires pre- and post-test implicit bias assessments; a short lecture with no assessment may not meet R 338.7004.
- Counting hours earned before the 3-year window. A conference just outside the window does not count, and there is no carryover.
- Discarding implicit bias or opioid certificates after 4 years. Their retention periods are longer than the CME rule's.
- Treating a waiver as automatic. It is a request to the board with a fixed deadline, not an extension you can assume.
Before you renew in MiPLUS
- 150 hours dated within the 3 years before the date you will submit the application
- Category 1 total of at least 75 (MD) or 60 (DO), with at least 40 AOA or MOA hours for DOs
- 1 hour of medical ethics clearly identified on a certificate
- 3 hours of pain and symptom management, including 1 hour on controlled substance prescribing
- 3 hours of implicit bias training with pre- and post-test assessments, completed within this cycle
- Category 2 hours within each activity cap (and within 90 hours in total for DOs)
- Human trafficking certificate on file
- Opioid and controlled substance awareness certificate on file if you hold a controlled substance license, plus your MAPS registration
- MATE Act attestation ready for your next DEA registration, if not already done
- All certificates saved in one folder you can send within days of an audit letter
Medical Ethics for Physicians (AMA Code of Medical Ethics)
A self-paced course built around the AMA Code: the patient-physician relationship, truthfulness, end-of-life decisions, dual roles, industry relationships and controlled substance prescribing, telemedicine, and how ethics cases move through a medical board. It ends with a scenario-based assessment and a written reflection. It is useful for physicians who want a structured refresher beyond the one required hour, or who are preparing for a board inquiry. It does not award AMA PRA Category 1 Credit, so it does not count toward Michigan's Category 1 minimum or, on its own, the required ethics hour.
Our courses are education.
Frequently asked questions
Do Michigan residents and fellows need to complete 150 hours of CME?
Physicians in a qualifying postgraduate or clinical training program earn 50 Category 1 hours for each year of enrollment (at least 5 months in a 12-month period), up to 150 hours per renewal period, under both the MD and DO rules. A full three years of training can therefore cover the hour total, but the ethics, pain management and implicit bias requirements still have to be met.
Does passing my board recertification exam count toward Michigan CME?
Yes. Passing a certification or recertification exam from a recognized specialty board is worth 50 Category 1 hours, once per renewal period, for both MDs and DOs. Other activities required to maintain certification that are not already approved programs can add up to 30 hours.
Can I complete all three implicit bias hours in one sitting?
Yes. LARA's FAQ explains the rule means one hour for each year of the cycle, so a single 3-hour program completed within the cycle satisfies a 3-year license, as long as it includes the required content and pre- and post-test assessments.
My Michigan license lapsed. How much CME do I need to relicense?
For an MD, R 338.2437 requires 150 hours completed in the 3 years before the relicensure application, meeting the same topic rules. If the license has been lapsed 3 years or more, you also need fingerprints plus either a license in good standing in another state or Canadian province or, within the past 3 years, passing the SPEX or completing a qualifying postgraduate or re-entry program; after 5 years or more without another active license, you need both the SPEX and one of those programs.
Do CME hours I earned for another state's license count in Michigan?
Usually, if the activity is Category 1 from a sponsor Michigan recognizes and falls within your 3-year window. Michigan's own topic requirements still apply, so a course that satisfied another state's ethics or prescribing mandate counts only if its content also fits Michigan's ethics or pain and symptom management rules.
Does Michigan's opioid awareness training satisfy the DEA MATE Act requirement?
Not automatically. The Michigan training is about MAPS and prescribing law and has no fixed length, while the MATE Act requires 8 hours on substance use disorder treatment and management. Some programs can satisfy both, but check each set of standards separately.
When can I submit my Michigan renewal?
LARA sends renewal notices about 90 days before your license expires, and you cannot renew before that window opens. You then have a 60-day grace period after expiration with a $20 late fee; after that the license lapses back to the original expiration date.
Official sources
- Michigan Legislature: MCL 333.17033, Renewal of license; continuing education; pain and symptom management
- Michigan Administrative Code: Board of Medicine General Rules, R 338.2401 to R 338.2443 (including R 338.2413, R 338.2437, R 338.2441, R 338.2443)
- Michigan Administrative Code: Osteopathic Medicine and Surgery General Rules, R 338.111 to R 338.143 (2025 MR 11, effective May 8, 2025)
- Michigan Administrative Code: Public Health Code General Rules, R 338.7001 to R 338.7005 (R 338.7004 Implicit bias training standards)
- Michigan Administrative Code: Board of Pharmacy Controlled Substances, R 338.3101 to R 338.3199q (R 338.3135 Opioids and other controlled substances awareness training standards)
- Michigan Legislature: MCL 333.16148, Rules and training standards including identifying victims of human trafficking
- Michigan Legislature: MCL 333.7303a, Prescribing controlled substances; MAPS registration and report
- LARA Bureau of Professional Licensing: Michigan Medical Doctor FAQs (revised September 16, 2024)
- LARA Bureau of Professional Licensing: Michigan Osteopathic Medicine and Surgery FAQs (revised September 16, 2024)
- LARA Bureau of Professional Licensing: Implicit Bias Training FAQs
- LARA: Michigan Prescription Drug and Opioid Abuse Commission, approved minutes, April 12, 2018
- LARA: Board of Osteopathic Medicine & Surgery Disciplinary Subcommittee, approved minutes, December 6, 2018
- Michigan Legislature: House Bill 4920 of 2025, status and history
- Michigan Legislature: House Bill 4790 of 2025, status and history
- U.S. Drug Enforcement Administration, Diversion Control Division: Letter to registrants on the MATE Act training requirement
Checked October 2026.