Michigan Board of Osteopathic Medicine & Surgery · OSTEOPATHIC

150 hours triennially. 60-hour Category 1 floor. 3-hour implicit bias training each cycle.

A source-verified guide to Michigan's CME requirements for osteopathic physicians — hours, mandatory topics, audit rules, and exemptions.

Updated April 2026Sourced from MBOM&S~1 min read
Licensed as an MD instead? Michigan regulates MDs through a separate board. See Michigan MD CME requirements →

Compiled by Atlas CME from official board sources · Last updated April 21, 2026

Mandatory topics

For osteopathic physicians, 150 hours is the total CME requirement. Michigan also requires a set of one-time topics that count toward the 150-hour total.

Pain Management[1]
3 hrs
Triennial
Minimum of 3 hours of CE in pain and symptom management per renewal cycle, with at least 1 of the 3 hours including controlled substances prescribing. Authority: MCL 333.17533(2) (requiring BOMS rulemaking for pain/symptom management) and MCL 333.16204 (interdisciplinary advisory committee). Implemented via LARA DO Licensing Guide. Counts toward the 150-hour total.
View sourceVerbatim from source
“A minimum of 3 hours of continuing education credit must be earned in pain”
R 338.143(1)(c) (2025 AACS, Eff. 5/8/2025) — implements MCL 333.17533(2)See source [1] in Primary Sources
Legal & Risk Management[1]
1 hr
Triennial
Minimum of 1 hour of CE in medical ethics required for all renewal cycles that began on or after 04/26/2021 (LARA DO Licensing Guide). Counts toward the 150-hour total.
View sourceVerbatim from source
“A minimum of 1 hour of continuing education credit must be earned in medical”
R 338.143(1)(b) (2025 AACS, Eff. 5/8/2025)See source [1] in Primary Sources
Implicit Bias[2]
3 hrs
Triennial
Implicit bias training — Mich. Admin. Code R 338.7004(2) requires 1 hour of implicit bias training for each year of the license cycle. For DOs on a 3-year cycle, this is 3 hours per renewal. R 338.7004(3): no carry-forward between cycles.
View sourceVerbatim from source
“minimum of 1 hour of implicit bias training for each year of the applicant's”
R 338.7004(2) — article-15-wide (applies to DOs)See source [2] in Primary Sources
Implicit Bias[2]
2 hrs
One-time
Initial licensure requirement — Mich. Admin. Code R 338.7004(1) requires 2 hours of implicit bias training within the 5 years immediately preceding issuance of the license. Applies to DOs applying for initial Michigan licensure.
View sourceVerbatim from source
“minimum of 2 hours of implicit bias training within the 5 years immediately”
R 338.7004(1)See source [2] in Primary Sources
Human Trafficking[3]
Hrs vary
One-time
One-time training in identifying victims of human trafficking required per Mich. Admin. Code R 338.120 and the LARA DO Licensing Guide. DOs must certify completion on renewal application prior to renewing. Per the LARA DO Licensing Guide (FAQ), this applies to osteopathic physician licensees. Layer 1 does not specify a fixed hour count.
View sourceVerbatim from source
“they have completed a one-time training in identifying victims of human trafficking”
LARA DO Licensing Guide rev 1/26/2026 / R 338.120 (rule layer now captured: michigan/osteopathic/admincode-r-338-111-to-143 — 'an individual seeking licensure or who is licensed shall have completed training in identifying victims of human trafficking')See source [3] in Primary Sources
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Conditional requirements

These rules apply only when the trigger described under each card is met (for example, holding a state-issued controlled substance registration or treating a specific patient population). Each cites the underlying statute or rule directly.

ConditionalOpioid/Substance Use[4]
Hrs vary
Triennial

Controlled substance licensees or DOs licensed to prescribe or dispense controlled substances in Michigan

View sourceVerbatim from source
“individual who is applying for or renewing a controlled substance license shall”
R 338.3135(1)See source [4] in Primary Sources
Accepted credit

Credit must come from an organization accredited by the ACCME, AMA, Michigan Medical Association, or AAFP. ACGME residency or fellowship time accrues toward the requirement. Teaching or presenting accredited CME can satisfy a portion of required hours.

Credit systemNotes
Board-approved credit
DOs onlymin 60 hrs
DOs must earn at least 60 of the 150 triennial hours through Category 1 programs (per the current rule R 338.143(1)(d), the 60-hour floor is Category 1 only; a separate cap allows a maximum of 90 hours through Category 2 programs). The prior 'Category 1 or Category 3' wording tracked the pre-2023 R 338.97 numbering and is superseded — corrected 2026-07-04 (C13). This 60-hour floor is notably lower than the 75-hour Category 1 floor that applies to MDs under the separate Board of Medicine rules.SourceR 338.143(1)(d) (2025 AACS, Eff. 5/8/2025; formerly R 338.97(1) pre-2023 renumbering)[1]
AOA Category 1-A
DOs onlymin 40 hrs
the current rule R 338.143(2)(a) (2025 AACS, Eff. 5/8/2025) — the acceptable-Category-1 activity for AOA/Michigan Osteopathic Association programs — sets a 40-hour minimum (and a 150-hour maximum) for this activity per renewal period. AOA-approved programs count as board Category 1 credit. This 40-hour AOA/MOA floor is a subset within the 60-hour board Category 1 floor under R 338.143(1)(d).SourceR 338.143(2)(a) (2025 AACS, Eff. 5/8/2025) — AOA/MOA activity, 40-hr minimum[1]
AMA PRA Category 1
DOs onlymax 110 hrs
the current rule R 338.143(2)(b) (2025 AACS, Eff. 5/8/2025) — the acceptable-Category-1 activity for AMA / ACCME (incl. joint-providership) / Michigan State Medical Society programs — caps this activity at 110 continuing education hours per renewal period. AMA PRA Category 1 Credit from ACCME-accredited providers counts as board Category 1 credit; DOs are not restricted to osteopathic-only credit.SourceR 338.143(2)(b) (2025 AACS, Eff. 5/8/2025) — AMA/ACCME/MSMS activity, 110-hr cap[1]
Documentation & audit

Record retention: DOs must maintain CE documentation for 4 years after applying for license renewal.[6] LARA may audit and request proof of compliance. Implicit bias training records must be retained for 6 years.[2]

Waivers & exemptions

BOMS may waive CE requirements if the licensee's failure to attend was due to disability, military service, absence from the continental United States, or other circumstance beyond the licensee's control.[8]

Newly licensed DOs may have a partial requirement during the first renewal cycle if licensed mid-cycle. Hours required are pro-rated.

FAQ
How many CME hours do Michigan DOs need?
Michigan DOs must complete 150 hours of CME per three-year license cycle.[5][6] At least 60 of those hours must be earned in Category 1 or Category 3 programs.[6] Mich. Admin. Code R 338.98 adopts AOA CME standards by reference, so AOA-approved programs count as Category 1 or 2; AMA PRA Category 1 credit from ACCME-accredited providers qualifies on equal footing.[6] CME records must be retained for 4 years after applying for license renewal;[6] implicit bias training records must be retained for 6 years.[2]
How is the Michigan DO rule different from the MD rule?
The only codified numeric difference between the Michigan Board of Osteopathic Medicine & Surgery and the Michigan Board of Medicine is the Category 1 floor: 60 hours for DOs[6] versus 75 hours for MDs.[7] Every other Michigan mandate — 3 hours of pain and symptom management including 1 hour of controlled-substance prescribing,[5] 1 hour of medical ethics,[6] implicit bias,[2] one-time human trafficking training, and controlled-substance awareness training[4] for CS licensees — applies substantively identically on both sides. The two boards remain separate agencies within LARA.
What does Michigan's implicit-bias rule require of DOs?
Michigan rule requires 1 hour of implicit bias training for each year of the license cycle.[2] Michigan DOs on a 3-year cycle must therefore complete 3 hours per renewal. An additional 2 hours of implicit bias training is required within the 5 years preceding initial licensure.[2] Implicit bias training hours do not carry forward between cycles,[2] and records must be retained for 6 years.[2]

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Other roles in Michigan

Osteopathic Physicians (DO) CME requirements in other states

Sources & Citations

Every mandatory topic and conditional requirement above cites the underlying statute or rule. Numbered references below correspond to the bracketed citations next to each requirement.

  1. https://ars.apps.lara.state.mi.us/AdminCode/DownloadAdminCodeFile?FileName=R%20338.111%20to%20R%20338.143.pdf
    Source
    Show verbatim text
    “A minimum of 3 hours of continuing education credit must be earned in pain”R 338.143(1)(c) (2025 AACS, Eff. 5/8/2025) — implements MCL 333.17533(2)
    “A minimum of 1 hour of continuing education credit must be earned in medical”R 338.143(1)(b) (2025 AACS, Eff. 5/8/2025)
  2. Mich. Admin. Code R 338.7004 — Implicit Bias Training Standards
    Primary sourceAccessed 2026-04-21
    Show verbatim text
    “The licensee or registrant shall retain documentation of meeting the requirements of this rule for a period of 6 years after the date of applying for licensure, registration, or renewal.”R 338.7004(6)
    “minimum of 1 hour of implicit bias training for each year of the applicant's”R 338.7004(2) — article-15-wide (applies to DOs)
    “minimum of 2 hours of implicit bias training within the 5 years immediately”R 338.7004(1)
  3. https://www.michigan.gov/lara/-/media/Project/Websites/lara/bpl/Osteopathic-Medicine/Licensing-Info-and-Forms/DO-Licensing-Guide-FAQ-12626.pdf
    Source
    Show verbatim text
    “they have completed a one-time training in identifying victims of human trafficking”LARA DO Licensing Guide rev 1/26/2026 / R 338.120 (rule layer now captured: michigan/osteopathic/admincode-r-338-111-to-143 — 'an individual seeking licensure or who is licensed shall have completed training in identifying victims of human trafficking')
  4. Mich. Admin. Code R 338.3135 — Opioids and Controlled Substances Awareness Training
    Primary sourceAccessed 2026-04-21
    Show verbatim text
    “Applicants for or those renewing controlled substance licenses must complete opioids and controlled substances awareness training meeting these standards: (a) Training content must cover: (i) Utilizing the MAPS. (ii) State and federal laws regarding prescribing and dispensing controlled substances.”R 338.3135(1)
    “individual who is applying for or renewing a controlled substance license shall”R 338.3135(1)
  5. MCL 333.17533 — Osteopathic Physician Continuing Education
    Primary sourceAccessed 2026-04-21
    Show verbatim text
    “Notwithstanding the requirements of part 161, the board may require a licensee seeking renewal of a license to furnish the board with satisfactory evidence that during the 3 years immediately preceding an application for renewal the licensee has attended continuing education courses or programs approved by the board and totaling not less than 150 hours in subjects related to the practice of osteopathic medicine and surgery and designed to further educate licensees.”MCL 333.17533(1)
  6. Mich. Admin. Code R 338.141 — Osteopathic License Renewals; Continuing Education
    Primary sourceAccessed 2026-04-18
    Show verbatim text
    “Submission of an application for renewal constitutes the applicant's certification of compliance with the requirements of this rule. The licensee shall maintain documentation of satisfying the requirements of this rule for 4 years after the date of applying for license renewal. Failure to satisfy this rule is a violation of section 16221(h) of the code, MCL 333.16221.”R 338.141(3)
    “A minimum of 60 credit hours of the total 150 credit hours of the continuing education requirement shall be earned in the programs, or a combination of the programs, specified as category 1 or category 3 programs in R 338.94.”R 338.97(1)
    “The board approves and adopts the standards, requirements, guidelines, and procedures adopted in January, 1989, by the committee on continuing medical education of the American osteopathic association for evaluating osteopathic continuing education. The board shall consider a program that is approved by the committee on continuing medical education of the American osteopathic association as a category 1 or category 2 continuing education course or program approved by the board.”R 338.98
  7. Mich. Admin. Code R 338.2443 — MD Acceptable Continuing Education
    Primary sourceAccessed 2026-04-17
    Show verbatim text
    “A minimum of 75 continuing education credits must be obtained through category 1 programs listed in subrule (2) of this rule.”R 338.2443(1)(d)
  8. MCL 333.16205 — Waiver of Continuing Education
    Primary sourceAccessed 2026-04-18
    Show verbatim text
    “A board which requires evidence of attendance at educational programs as a condition to license renewal may waive those requirements if, upon written application, the board finds the failure of the licensee to attend was due to the licensee's disability, military service, absence from the continental United States, or a circumstance beyond the control of the licensee which the board considers good and sufficient.”MCL 333.16205(1)

This page is provided for general educational purposes and reflects the best available information as of the last reviewed date above. CME requirements change. Atlas CME is not affiliated with the Michigan Board of Osteopathic Medicine & Surgery, or any other state medical board, licensing authority, or professional organization. Physicians are solely responsible for verifying their own current CME requirements directly with their state medical board before relying on any information presented here.

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