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FAQ: State CME Licensure Requirements for DOs


By Pennsylvania Medical Society; Updated Oct. 6, 2017


The following FAQ addresses DO (osteopathic) requirements for licensure. For MD (allopathic) requirements, click here.

What are the requirements for licensure?

The State Board of Osteopathic Medicine regulations state that to renew a medical license, a physician will need:

  • 100 total credit hours of CME in the two-year license cycle (with license cycles ending on Oct. 31 of each even year)
  • A minimum of 20 of the total credit hours in Category 1
  • 12 credit hours in the areas of patient safety or risk management (either Category 1 or Category 2)
  • 2 continuing education credits every two-year licensure cycle from a Department of Human Services' (DHS) approved course on the topic of mandated child abuse recognition and reporting for a license renewal OR three continuing education credits from a DHS approved course on the topic of mandated child abuse recognition and reporting for an initial license. This is a separate and distinct mandate outside of the CME requirements and is a condition of licensure. If the DHS approved course awards CME credits, however, those credits can also be applied toward the CME requirements.
  • A Pennsylvania bill signed into law on Nov. 2, 2016 — Act 124 of 2016 — requires dispensers or prescribers applying for an initial license and those applying for re-licensure to complete opioids continuing education. These are the specific requirements for the 2017-2018 licensure period:
    • Initial applicants—They must submit, no later than 12 months after obtaining an initial license or certification, documentation acceptable to the licensing board of the completion of at least two hours of education in pain management or identification of addiction and at least two hours of education in the practices of prescribing of opioids. The education may occur as part of the individual's professional degree educational program or continuing education program.
    • Physicians seeking re-licensure—They must complete at least two hours of continuing education in pain management, identification of addiction, or the practices of prescribing of opioids. These two hours count as part of the 100-hours required for continuing education, not in addition to the 100-hour requirement.
    • Prescribers who do not have their own DEA registration number—Prescribers without a DEA number and who don't use the registration of another person or entity as permitted by law to prescribe controlled substances are exempt from this education requirement.

    The State Board of Osteopathic Medicine will accept continuing education courses in either Category 1 or Category 2. Get additional details on this requirement—including how to access PAMED's opioids education—online here.

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What is the difference between Category 1 and Category 2 credit hours?

Category 1-A is defined by the American Osteopathic Association as those activities that have been approved by an AOA-accredited sponsor.

You will know an activity is Category 1 because all of the promotional materials will contain a statement similar to the following:

“This activity has been planned and implemented in accordance with the Essential Areas and policies of the AOA Council for Continuing Medical Education. The (sponsoring organization, such as the Pennsylvania Osteopathic Medical Association) is accredited by the Council for Continuing Medical Education to sponsor continuing medical education for physicians.”

Your CME certificate will also state that the activity has been approved for AOA Category 1-A credit.

Category 2 credit hours consist of CME that has been approved by one of the following:

  • An accredited provider of the Accreditation Council for Continuing Medical Education (ACCME)
  • A state medical society accredited provider
  • The American Association of Family Physicians (AAFP)

Physicians can also earn Category 2 credit hours by reading authoritative medical literature.

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How many credit hours need to be in patient safety or risk management?

Twelve (12) credit hours are needed in patient safety or risk management.

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Do the patient safety or risk management credit hours need to be in Category 1 or Category 2?

According to the regulations, the patient safety or risk management credit hours can be in either Category 1 or Category 2.

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If I have 12 Category 1 credit hours in patient safety or risk management topics, may I count these for both the Category 1 requirement and the patient safety/risk management requirement?

Yes. If any of the patient-safety credit hours that a physician has earned are AOA Category 1-A credit hours, they can be counted toward both the Category 1 requirement and the patient safety/risk management requirement.

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How do I know if a CME activity is patient safety or risk management?

The following list of topics that will satisfy the patient safety/risk management requirement:

  • Improving medical records and record keeping
  • Reducing medical errors
  • Professional conduct and ethics
  • Improving communication among physicians and with other health care personnel
  • Communication between physicians and patients
  • Preventive medicine education
  • Health care quality improvement

As long as the CME activity falls within these topics, you can count it toward the patient safety/risk management requirement. The course does not have to state, and very likely may not, that it is a patient safety or risk management course.

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Who will I need to report to in order to renew my license?

The State Board of Osteopathic Medicine is not requiring a report of CME at the time of license renewal. The license renewal form will contain an area for physicians to attest that they have completed the required hours.

By attesting that the requirement is completed, a physician may be subject to a random audit by the Osteopathic Board. If audited, a physician will need to show evidence of the completion of the required credit hours. Failure to produce the request evidence will result in a fine and possible suspension of license.

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How do I prove Category 2 credits if I am audited?

Category 2 credit hours must be documented in the form of a physician log or diary and forwarded to the American Osteopathic Association or the Pennsylvania Osteopathic Medical Association, if the physician is a member.

Documentation should include:

  • The date the activity was completed
  • A description of the activity (article title, resident teaching, consultation with peers, etc.)
  • Location (name of journal, hospital, home study, web site, etc.)
  • The number of credits claimed (actual time spent in the activity)

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If you have additional questions, please call the CME Office at (800) 228-7823, ext. 2623.

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