License renewal · Pennsylvania MD & DO
Pennsylvania Physician CME: 100 Hours, Patient Safety Credits and Child Abuse Reporting
How the 100 hours Pennsylvania physicians need every two years actually divide up, what genuinely counts toward the 12 patient safety and risk management hours, where MD and DO rules differ, and how the new one-time organ donation requirement fits into the 2026 renewals.
Reviewed October 2026 against 49 Pa. Code §§ 16.19, 16.108 and 25.271, the April 2026 final rulemakings of the State Board of Medicine and State Board of Osteopathic Medicine, and Pennsylvania Department of State renewal guidance
Short answer: Pennsylvania physicians must complete 100 hours of CME every two-year renewal cycle. At least 20 must be formal credit (AMA PRA Category 1 for MDs, AOA Category 1-A for DOs) and at least 12 must be in patient safety or risk management. Within the 100 you also need 2 hours of approved child abuse recognition and reporting training, 2 hours of opioid education if you prescribe under a DEA registration, and, since May 1, 2026, a one-time 2 hours in organ and tissue donation. DO licenses expire October 31, 2026; MD licenses expire December 31, 2026.
Key takeaways
- The 100 hours are a total, not a sum of separate buckets: a single Category 1 patient safety activity can count toward the 100, the 20-hour formal floor and the 12 patient safety hours at once.
- The child abuse and opioid hours count toward the 100 but cannot be counted toward the 12 patient safety and risk management hours.
- Both regulations give the same illustrative list of patient safety topics: medical records and recordkeeping, reducing medical errors, professional conduct and ethics, communications, preventive medicine and healthcare quality improvement.
- Child abuse training must come from a provider on the Department of State or Department of Human Services approved list, and the provider reports your completion electronically, which can take up to seven days.
- The organ and tissue donation requirement took effect May 1, 2026; it is a one-time 2-hour course built on a six-part board curriculum and counts toward the 100 hours.
- The State Board of Osteopathic Medicine's cycle ends October 31, 2026, two months before the State Board of Medicine's December 31, 2026 deadline.
The 100-hour budget, slice by slice
Pennsylvania's physician CME rules are issued under section 910 of the Medical Care Availability and Reduction of Error (MCARE) Act of 2002, the patient safety law under which the boards adopted the patient safety and risk management requirement. The State Board of Medicine implements it in 49 Pa. Code § 16.19, which requires MDs to show 100 credit hours completed during the preceding two-year period. The State Board of Osteopathic Medicine does the same for DOs in § 25.271.
The easiest way to plan is to treat the 100 hours as a budget with a few fixed lines and one large flexible line. The fixed lines are minimums, and several of them can be met by the same activity.
Formal Category 1 credit
MDs need AMA PRA Category 1; DOs need AOA Category 1-A. Any topic qualifies, so this floor is usually met by the clinical CME you already do.
Patient safety or risk management
Category 1 or 2. If the activity is also Category 1, it counts toward the 20-hour floor as well. Child abuse and opioid hours are excluded.
Child abuse recognition and reporting
Must be from a Department of State approved provider, which reports completion to the board for you.
Pain, addiction or opioid prescribing
Required if you hold a DEA registration or prescribe under another's. MDs: AMA PRA Category 1 or 2. DOs: AOA Category 1 or 2.
Organ and tissue donation
Effective May 1, 2026, completed once within the five-year window, using the board's six-part curriculum.
Category 1 or Category 2
At least 62 hours if nothing overlaps, more in practice because the mandated hours can double as Category 1 credit. Office management and practice building earn nothing.
The board's MD guidance excludes the child abuse and opioid hours only from the 12 patient safety hours. All three topic requirements still sit inside the 100, and the organ donation hours "may be attributed" to the biennial total under the 2026 rule. Nothing is added on top of 100.
MD vs DO: the same 100 hours, different rules underneath
Because both boards act under the same MCARE mandate, the headline numbers match. The details do not, and physicians who move between systems, or who hold both MD and DO colleagues to the same internal training plan, should know where they part ways.
| Rule | MD: State Board of Medicine | DO: State Board of Osteopathic Medicine |
|---|---|---|
| Regulation | 49 Pa. Code § 16.19 | 49 Pa. Code § 25.271(c) |
| CME period for 2026 renewal | January 1, 2025 to December 31, 2026 | November 1, 2024 to October 31, 2026 |
| License expires | December 31 of even-numbered years | October 31 of even-numbered years |
| 20-hour formal floor | AMA PRA Category 1 | AOA Category 1-A |
| Remaining hours | Category 1 or 2 | AOA Category 1-A, 1-B or 2, or AMA Category 1 or 2 |
| Patient safety example topics in rule | Yes (same six example areas) | Yes (same six example areas) |
| Opioid hours credit type | AMA PRA Category 1 or 2 | AOA Category 1 or 2 |
| Organ donation hours | CME meeting AMA PRA Category 1 or 2 standards | CME meeting AOA Category 1 or 2 standards |
| Discipline for noncompliance | Section 41(6), Medical Practice Act of 1985 | Section 15(a)(6), Osteopathic Medical Practice Act |
Sources: 49 Pa. Code §§ 16.19 and 25.271; State Board of Osteopathic Medicine 2026 Renewal Guide; State Board of Medicine renewal information; 16A-4960 and 16A-5337 final rulemakings; both boards' organ and tissue donation notices.
What trips up MDs
The regulation's topic list is illustrative ("may include topics such as"), so MDs still have to judge whether an activity is genuinely about safety or risk rather than relying on a title. MDs also renew two months after DOs, which can create false confidence when colleagues talk about deadlines in October.
What trips up DOs
The 20-hour floor must be AOA Category 1-A specifically. AMA PRA Category 1 credit is accepted for the remaining hours but does not fill the 1-A floor. DOs with mostly hospital-based AMA credit should check their 1-A total early.
What actually counts toward the 12 patient safety and risk management hours
This is the question most requirement summaries skip. The rule itself is short: at least 12 of the 100 hours must be in patient safety or risk management, completed as Category 1 or Category 2 activities. Both boards' CME sheets add one firm exclusion: the child abuse hours and the opioid hours cannot be counted toward the 12.
Both regulations also give the same list of example subject areas, introduced with the words "may include topics such as". The list is illustrative rather than exhaustive, but it is the clearest official guide to what the boards have in mind.
| Example area in §§ 16.19(b)(1) and 25.271(c)(1) | Typical activities that fit | Why it is a safety or risk topic |
|---|---|---|
| Improving medical records and recordkeeping | Documentation quality, EHR copy-forward risks, informed consent records | Records drive handoffs, defense of care and audit outcomes |
| Reducing medical errors | Diagnostic error, medication safety, root cause analysis, test-result follow-up | The core purpose of the MCARE Act |
| Professional conduct and ethics | Boundaries, disclosure of adverse events, conflicts of interest | Conduct failures are a leading source of complaints and claims |
| Improving communication | Handoffs, closed-loop communication, shared decision-making | Communication breakdowns contribute to many adverse events |
| Preventive medicine | Screening intervals, missed-follow-up systems, infection prevention | Prevents harm from omissions rather than errors of action |
| Healthcare quality improvement | QI methods, audit and feedback, safety culture | Builds system-level defenses against repeat harm |
Source: 49 Pa. Code §§ 16.19(b)(1) and 25.271(c)(1) (subject areas); examples in the middle and right columns are ours, for illustration.
For MDs and DOs alike, the practical test is whether the activity's main content is preventing harm to patients or managing clinical and liability risk. A cardiology update with a ten-minute safety segment is a cardiology update. A full session on anticoagulation reversal errors is plausibly a patient safety activity. Many Pennsylvania hospitals and CME sponsors label sessions as meeting the patient safety and risk management requirement; that label is helpful, but it is the sponsor's view, not a board ruling, and the Medicine board's sheet states that it does not recommend or endorse CME courses.
The 12 patient safety hours must be Category 1.
They can be Category 1 or Category 2 under both regulations. Category 2 claims need your own record of the activity title, subject, dates and credits claimed.
The 12 hours are on top of the 100.
They are part of the 100. A Category 1 patient safety activity also counts toward the 20-hour formal floor.
The child abuse course is a safety course, so it counts toward the 12.
The Medicine board's CME sheet says the child abuse and opioid hours cannot be counted toward the 12.
Any course with "risk" in the title qualifies.
Office management and practice building earn no CME credit at all under §§ 16.19 and 25.271, however they are titled. Billing or revenue courses are the usual trap.
Child abuse recognition and reporting: 2 hours, reported by the provider
Under Act 31 of 2014, every Pennsylvania physician is a mandated reporter and must complete 2 hours of approved child abuse recognition and reporting education for each biennial renewal, counted within the 100 hours. Applicants for an initial license complete 3 hours instead. The board will not grant an exemption just because children are not part of your practice.
Two practical points matter more than the content. First, the renewal course must be approved by the Department of State's Bureau of Professional and Occupational Affairs, in consultation with the Department of Human Services, and taken from an approved provider; the Department of State also accepts training approved by the Department of Human Services. Courses that are on neither list do not count. Second, you do not upload a certificate: the provider reports your completion electronically to the board, and the Department warns this can take up to seven days. A course finished the day before your deadline may not show in PALS in time.
If you also hold a New York license, the two states' requirements are not interchangeable. Our New York vs Pennsylvania mandated reporter training guide covers approved providers, exemptions and the differences in detail.
Opioid education: 2 hours at renewal, 4 hours for new licensees
The opioid requirement comes from the Achieving Better Care by Monitoring All Prescriptions Program (ABC-MAP) Act as amended by Act 124 of 2016. At each renewal you need at least 2 hours in pain management, identification of addiction, or the practices of prescribing or dispensing opioids. The hours count toward the 100.
The 2026 rulemakings wrote the scope into the regulations. For MDs, the 2 hours apply if you hold a current DEA registration or use the DEA registration of another. For DOs, a physician who neither holds a current DEA registration nor uses another's to prescribe controlled substances is expressly exempt. The Medicine board's rule states that the state's PA-SUPPORT curriculum satisfies the renewal requirement but is not required curriculum; the osteopathic rule names PA-SUPPORT in its initial-licensure opioid provisions.
New licensees have a separate, one-time obligation: 4 hours (2 in pain management or identification of addiction, and 2 in prescribing or dispensing opioids), completed within one year of obtaining the license. Under the 2026 rules this initial requirement, like the renewal hours, applies only to holders of a current DEA registration or those who use another's. For MDs it can be met through the medical degree program, with verification included in the Verification of Medical Education.
The federal MATE Act requirement is different again: a one-time 8 hours on substance use disorders for DEA registrants, attested on the DEA registration form. An AMA PRA or AOA credited activity that covers the Pennsylvania topics can count toward both, but check the certificate content. Our MATE Act 8-hour training guide explains who is deemed compliant and how to document it.
Organ and tissue donation: the one-time requirement from May 1, 2026
The newest line in the budget comes from 20 Pa.C.S. § 8628, which requires physician and nurse training in organ and tissue donation and recovery. Both boards finalized their rules in spring 2026: effective May 1, 2026, MDs and DOs must complete at least 2 credit hours in the organ and tissue donation and recovery process. It is a one-time requirement, and the 2 hours count toward the biennial 100.
The course must follow the six-part curriculum the boards developed with Pennsylvania's two federally designated organ procurement organizations, CORE and Gift of Life Donor Program: the donation and transplantation system, tissue donation, organ donation, determining death and family communication, caring for families, and organ donor management. A general transplant lecture will not do.
| Your situation | When the 2 hours must be verified |
|---|---|
| Initially licensed before May 1, 2026 | Within 5 years of license renewal |
| Initially licensed on or after May 1, 2026 | Within 5 years of initial licensure |
| Reactivating an expired or inactive license on or after May 1, 2026 | Once, within 5 years of reactivation |
Source: 49 Pa. Code § 16.19(c)(1) as amended by 16A-4960 (MD); § 25.271(c)(6) as amended by 16A-5337 (DO).
For most established physicians the deadline is not this renewal, but there is a good reason to do it now: the 2 hours count toward this cycle's 100 either way, and the curriculum is fixed, so there is nothing to wait for. Keep the certificate; DOs must retain documentation of attendance from an organ procurement organization, and the MD rule adds organ procurement organization certification to the list of acceptable Category 1 documentation.
2026 renewal dates and the cycle you are in
Pennsylvania physician renewals are filed through the Pennsylvania Licensing System (PALS). The osteopathic board's 2026 guide says renewals are available 60 days before expiration, and the State Board of Medicine emails renewal notices about 60 days before its December 31 expiration.
One-time 2 hours, counted inside the 100, for MDs and DOs.
Roughly 60 days before the October 31 expiration.
CME period: November 1, 2024 to October 31, 2026. Physician and surgeon renewal fee: $450.
Roughly 60 days before the December 31 expiration. Allow up to seven days for child abuse course reporting before you file.
CME period: January 1, 2025 to December 31, 2026. Compact (IMLC) licensees renew in PALS first, then through the IMLC.
Physicians who hold an expedited license through the Interstate Medical Licensure Compact should follow the two-step order the State Board of Medicine describes: submit the Pennsylvania renewal in PALS, then complete the compact renewal. The same guide tells renewing physicians not to upload CME certificates; proof is requested only if you are audited.
New licensees, retirees, reactivations and hardship waivers
- First renewal after initial licensure: exempt from the 100-hour total for the biennial period in which you were first licensed in Pennsylvania. The DO board's 2026 guide applies this to licenses issued November 1, 2024 to October 31, 2026. The child abuse requirement is treated as applying to every renewal; the DO guide states it has no exemption.
- Temporary training license holders: exempt from the CME total while the training license is current.
- Retired physicians who treat only immediate family, and active-retired status: both regulations exempt retired physicians whose care is limited to immediate family members. The DO board's 2026 guide says Active-Retired licensees are exempt from all continuing education except the 2 Act 31 child abuse hours and the 2 Act 124 opioid hours.
- Inactive status: exempt while inactive, but reactivating an inactive or lapsed license requires proof of CME for the preceding biennium.
- Disciplinary suspension: not an exemption; suspended physicians must still meet the requirement.
- Hardship waiver: available in whole or part for serious illness, military service or other good cause, if public safety and welfare are not jeopardized. Requests must be written, documented and, per the board CME sheets, submitted 90 days before the cycle ends.
Proof, audits and the documents the board accepts
At renewal you certify that you completed the required CME. You do not file the certificates. The board then audits a random sample of renewals, and if you are selected you must produce the documentation; electronic submission is accepted. Failure to comply can lead to disciplinary proceedings.
The Medicine board's CME sheet is specific about what good evidence looks like. A board certification or an AMA PRA certificate on its own is not proof of compliance; you need the supporting certificates. Each certificate should show your name, the course title, the date, the credit hours, the provider and the credit category, with all dates inside the cycle. For Category 2, record the activity title, subject, dates and credits; 60 minutes of participation equals 1 credit, rounded to the nearest quarter hour, and the board publishes a Category 2 reporting form.
Keep everything for at least two years after you complete the CME or after the renewal it supported, whichever is later. There is no state CME tracking system doing this for you: the boards state that licensees are responsible for tracking their own credits. If an audit does go wrong, our guide on what happens after a failed CME audit walks through the usual next steps.
An internist checks her budget in November 2026
Dr. R is an MD with a DEA registration, licensed in Pennsylvania since 2015. Her tracker shows 88 hours: 52 AMA PRA Category 1, including a 6-hour diagnostic error series; 2 hours of Act 31 child abuse training; 2 hours of opioid prescribing; and 32 hours of Category 2 activities, including a 4-hour hospital ethics grand rounds series. Her formal floor is met. Her patient safety total is 6 hours from the diagnostic series plus the 4 hours of ethics grand rounds, so 10 of 12, and her child abuse and opioid hours cannot be added to it. She needs 12 more hours overall, at least 2 of them in patient safety. She chooses a 2-hour organ donation course built on the board curriculum (counted toward the 100 now, and the one-time requirement is done), a 4-hour medication safety activity and 6 hours of clinical CME. She then confirms her child abuse completion appears in PALS before filing.
Illustrative scenario, not a real physician. Rules applied: 49 Pa. Code § 16.19 and State Board of Medicine CME guidance.
Common mistakes with Pennsylvania physician CME
- Counting the child abuse or opioid hours toward the 12. They count toward the 100 only. A physician who relied on them can find themselves 4 hours short of patient safety credit at audit.
- Assuming any AMA credit fills the DO floor. DOs need 20 hours of AOA Category 1-A specifically.
- Taking child abuse training from an unapproved provider. Only providers on the Department of State or Department of Human Services approved lists report to the board; a certificate from anyone else does not satisfy Act 31.
- Leaving Act 31 to the last week. Provider reporting can take seven days, and PALS may flag the renewal as deficient in the meantime.
- Taking a general transplant lecture for organ donation. The requirement is tied to the board's six-part curriculum.
- Logging Category 2 without notes. Category 2 hours stand only on your contemporaneous record of title, subject, date and time.
- Using hours from the wrong window. DO hours completed before November 1, 2024, or MD hours before January 1, 2025, do not count for the 2026 renewal.
A pre-filing checklist for your 2026 PALS renewal
Confirm your window
DO: November 1, 2024 to October 31, 2026. MD: January 1, 2025 to December 31, 2026. Remove anything outside it from your total.
Total the 100 and the formal floor
Count all hours, then confirm at least 20 are AMA PRA Category 1 (MD) or AOA Category 1-A (DO).
Audit your 12 patient safety hours
List each activity and ask whether its main content is patient safety or risk management. Exclude child abuse and opioid hours.
Check the three topic mandates
Act 31 completion visible in PALS; 2 opioid hours if you hold or use a DEA registration; organ donation done or scheduled within your five-year window.
File the evidence, not just the totals
Save each certificate and your Category 2 log in one folder per cycle, and keep it at least two years after renewal.
For how Pennsylvania compares with California, Texas, Florida and New York, and how to handle licenses in several states, see the physician license renewal guide.
Clinical Risk Management
A self-paced, roughly 3-hour course on identifying, assessing and controlling clinical risk, high-risk clinical domains, escalation, and working with risk management after an incident, finishing with a reflective account. It is supporting education for physicians who want a structured grounding in the subject matter behind Pennsylvania's patient safety and risk management requirement. It does not award AMA PRA or AOA credit, so it cannot be counted toward the 12 hours or the 100.
Our courses are education.
Frequently asked questions
Can online CME count toward Pennsylvania's 100 hours?
Yes. Neither regulation limits the format of Category 1 or Category 2 activities for MDs. What matters is the credit designation on the certificate. DOs should check that activities intended for the 20-hour floor carry AOA Category 1-A designation, which the osteopathic board's CME sheet says is obtained by attending formal, face-to-face educational programs, so check the designation before relying on online activities for that floor.
Does Pennsylvania use CE Broker to track physician CME?
The State Board of Medicine and State Board of Osteopathic Medicine renewal materials do not refer to CE Broker. You attest to completion in PALS, child abuse providers report directly to the board, and the boards say licensees are responsible for tracking their own credits and producing proof if audited.
Can extra hours carry over to the next cycle?
No carryover provision appears in either regulation. Both require proof of 100 hours completed during the preceding biennial period, so hours earned in one cycle do not roll into the next.
I do not prescribe controlled substances. Do I still need the opioid hours?
Not if you neither hold a DEA registration nor prescribe under another person's or entity's registration. The 2026 final rules state this scope for both MDs and DOs. If you hold a DEA registration, the 2 hours apply even if you rarely prescribe opioids.
Does board certification or MOC satisfy the Pennsylvania requirement?
Not by itself. The State Board of Medicine's CME sheet says board certification or a PRA certificate alone does not prove compliance; you need the supporting CME certificates, and the Act 31 and organ donation requirements must still be met specifically.
What happens if I renew late or practice on an expired license?
Practicing after the expiration date without renewing is practicing without a current license, and the boards can impose late fees and other penalties. The osteopathic regulation sets a late renewal fee for anyone who practices after failing to renew on time. File before October 31 (DO) or December 31 (MD).
Is grand rounds Category 1 or Category 2?
It depends on the sponsor. Many hospital grand rounds are certified for AMA PRA Category 1 credit through the hospital's CME office, and the certificate or transcript will say so. If no credit was designated, you can generally claim it as Category 2 with your own record of the title, subject, date and time.
Official sources
- Pennsylvania Code: 49 Pa. Code § 16.19, Continuing medical education (State Board of Medicine)
- Pennsylvania Code: 49 Pa. Code § 25.271, Requirements for renewal (State Board of Osteopathic Medicine)
- Pennsylvania Code: 49 Pa. Code § 16.108, Child abuse recognition and reporting training
- Pennsylvania General Assembly: Medical Care Availability and Reduction of Error (MCARE) Act, Act 13 of 2002
- Independent Regulatory Review Commission: State Board of Medicine final rulemaking 16A-4960, Education and Volunteer Services
- Independent Regulatory Review Commission: State Board of Osteopathic Medicine final rulemaking 16A-5337, Education and Volunteer Services
- State Board of Medicine: Continuing Medical Education Requirements, MD Unrestricted License
- State Board of Osteopathic Medicine: Continuing Medical Education Requirements, Osteopathic Physician
- State Board of Osteopathic Medicine: 2026 Renewal Guide
- Pennsylvania Department of State: Renewal Information for the State Board of Medicine
- State Board of Medicine: IMLC Renewal Guide 2026
- State Board of Medicine: Organ and Tissue Donation and Recovery Process Continuing Education
- State Board of Osteopathic Medicine: Organ and Tissue Donation and Recovery Process Continuing Education
- State Board of Medicine: Notice Regarding Opioid Education (Act 124 of 2016)
- Pennsylvania Department of State: Act 31 Child Abuse Recognition and Reporting Training
- DEA Diversion Control Division: MATE Act training requirement letter to registrants
Checked October 2026.