A handful of states now make physicians complete training on implicit bias before they can renew a medical license. This guide covers the implicit bias CME requirements we could confirm on official state sites, with the hours, how often you need them, and when each rule started.
We checked these requirements against each state’s medical board, health department, or legislature website. Rules change, so confirm with your state medical board before your renewal. For each state’s full CME rules, see our CME requirements by state hub.
The short answer
- Illinois, Michigan, and Washington require implicit bias or health equity training on a repeating schedule for physicians.
- Massachusetts and Maryland each require it once, with Maryland adding a structural racism requirement for the first renewal after April 1, 2026.
- New Jersey requires 1 credit each biennial cycle, but only for physicians who provide perinatal care to pregnant persons.
- Connecticut folds explicit and implicit bias into its cultural competency hour, due at the first renewal and at least once every six years.
- California takes a different approach: since January 1, 2022, CME courses themselves must include implicit bias content, rather than physicians logging a set number of hours.
Implicit bias CME requirements by state
The table lists only states where we confirmed the rule on an official source. Hours and frequency are for physicians (MD and DO) unless noted.
| State | Requirement | How often | Started |
|---|---|---|---|
| Illinois | 1 hour of implicit bias awareness training | Every renewal period | Renewals on or after January 1, 2023 |
| Michigan | 1 hour per year of the license cycle (2 hours for new applicants) | Every renewal | June 1, 2022 |
| Washington (MD) | 2 hours of health equity CE, which must include implicit bias training | Every four years | January 1, 2024 (WAC 246-919-445) |
| Massachusetts | 2 credits on implicit bias in healthcare | One time | June 1, 2022 |
| Maryland | Approved implicit bias training, plus structural racism training | One time (attested at renewal) | Implicit bias: first renewal after April 1, 2022. Structural racism: first renewal after April 1, 2026 |
| New Jersey | 1 credit on explicit and implicit bias, for physicians who provide perinatal care | Each biennial registration | Required starting with the period that began July 1, 2025 (law enacted 2021, P.L. 2021, c. 79) |
| Connecticut | 1 contact hour of cultural competency, which by statute includes explicit and implicit bias | First renewal, then at least once every six years | Bias language added by Public Act 22-33 (2022) |
| California | All CME courses with a direct patient care component must include implicit bias curriculum | Built into CME courses | January 1, 2022 |
State details
Illinois
Illinois law (20 ILCS 2105/2105-15.7) says health care professionals with CE requirements, including physicians licensed under the Medical Practice Act, must complete at least a one-hour implicit bias awareness course per renewal period. It applies to renewals on or after January 1, 2023, and the hour can count toward your total CME. IDFPR’s rule says the course must be repeated each renewal period and can be taken in a classroom, by webinar, or online.
IDFPR also notes a newer piece: starting July 1, 2026, professionals who report providing maternal health care services must take implicit bias training that includes maternal health risk factors for childbearing people from marginalized racial or ethnic groups.
Michigan
Michigan’s rule covers every profession licensed under the Public Health Code except veterinary medicine, which includes medicine and osteopathic medicine. LARA’s FAQ says renewing licensees need 1 hour for each year of the license cycle, and new applicants need 2 hours within the 5 years before the license is issued. The requirement took effect June 1, 2022. You can take all the hours in one sitting, and asynchronous webinars are acceptable under the 2023 rule revision.
Washington
Washington requires physicians to complete 2 hours of health equity continuing education every four years (WAC 246-919-445, effective January 1, 2024). The Department of Health says this training must include implicit bias training aimed at reducing bias during assessment and diagnosis. The 2 hours count toward the 200 hours of CME physicians report every four years.
Massachusetts
Board Policy 2021-04 requires applicants for initial licensure and physicians renewing their license to complete 2.00 credits on implicit bias in healthcare, beginning June 1, 2022. The Board’s current page calls it a one-time requirement, and the credits can apply toward your risk management credits.
Maryland
Under Health Occupations §1-225, Maryland practitioners attest at renewal that they completed an approved training program. The original implicit bias requirement applied to the first renewal after April 1, 2022. A 2025 change added structural racism, and the Board of Physicians says everyone renewing for the first time after April 1, 2026 must attest to a structural racism program. If you already completed implicit bias training for an earlier renewal, you don’t need to repeat that part. Programs must be ACCME-accredited or recognized by a health occupations board, and the state keeps a list of approved options.
New Jersey
N.J.S.A. 45:9-7.9 requires physicians who provide perinatal treatment and care to pregnant persons to include 1 credit on explicit and implicit bias in their CME for each biennial registration. If you practice obstetrics or otherwise care for pregnant patients, this applies to you. Physicians outside perinatal care aren’t covered by this statute. Our OB/GYN courses cover general clinical topics; check with the board on what qualifies for the bias credit.
Connecticut
Connecticut requires 50 contact hours every 24 months, and at the first renewal and at least once every six years after that, at least 1 contact hour in each of several topics. One of them is cultural competency, which the statute (Sec. 20-10b) now defines to include the effects of systemic racism, explicit and implicit bias, racial disparities, and the experiences of transgender and gender diverse persons. That language came from Public Act 22-33.
California
California doesn’t ask physicians to log a separate implicit bias hour. Instead, Business and Professions Code 2190.1 says that on and after January 1, 2022, CME courses must include curriculum on understanding implicit bias. Courses dedicated solely to research without a direct patient care component, and courses from providers located outside California, are exempt from that content rule.
States we checked without a general physician requirement
We didn’t find a general implicit bias CME requirement for physicians on the official sites for Minnesota or Delaware. Minnesota’s medical board lists 75 Category 1 hours every three years with no implicit bias topic. Delaware’s board requires 40 Category 1 hours per registration period plus separate mandatory training, none of it on implicit bias.
Nevada has two narrower rules worth knowing. Psychiatrists must complete at least 2 hours of cultural competency and diversity, equity, and inclusion instruction each biennial period. Physicians who provide or supervise emergency care in a hospital, or primary care, must complete 2 hours on stigma, discrimination, and unrecognized bias toward people with or at high risk of HIV within 2 years of starting that work. Neither is a general implicit bias rule for all physicians, so we left Nevada out of the table.
How to meet the requirement
Most of these states don’t preapprove individual courses. They set content standards and let you attest at renewal. A few practical habits help.
- Read your state’s rule for required content, since Maryland and New Jersey spell out specific topics.
- Keep your certificate with the date, provider, and course title in case you’re audited.
- Check whether the hours count toward your general CME total, which is true in Illinois, Washington, and Massachusetts.
- If you hold licenses in several states, look at each one separately, because frequency and hours differ.
A course that awards AMA PRA Category 1 Credit™ isn’t automatically a qualifying implicit bias course. The topic and content requirements are set by each state.
Travel Medical Seminars offers Audio-Digest self-study courses that award AMA PRA Category 1 Credit™ toward your general CME hours, in 10-credit and 20-credit formats you complete online at your own pace. We don’t claim they satisfy any state’s implicit bias mandate, so check with your board on what qualifies. You can browse all courses by specialty.
Sources
- Illinois Compiled Statutes, 20 ILCS 2105/2105-15.7 (Implicit bias awareness training)
- Illinois Administrative Code, 68 Ill. Adm. Code 1130.500
- IDFPR: Illinois Continuing Education Requirements
- Michigan LARA: FAQs for Implicit Bias Training (March 23, 2023)
- New Jersey Statutes, N.J.S.A. 45:9-7.9
- Maryland Board of Physicians: Implicit Bias and Structural Racism Training Requirements for License Renewal in 2026
- Maryland Code, Health Occupations §1-225
- Maryland Department of Health: Implicit Bias Resources
- Massachusetts BORIM: Policy 2021-04, CME on Implicit Bias in Healthcare
- Massachusetts BORIM: Continuing Medical Education on Implicit Bias in Healthcare
- Washington Administrative Code, WAC 246-919-445
- Washington State Department of Health: Health Equity Continuing Education
- Connecticut General Statutes, Chapter 370 (Sec. 20-10b)
- Connecticut DPH: Continuing Medical Education
- California Business and Professions Code section 2190.1
- Nevada Revised Statutes, Chapter 630 (NRS 630.253)
- Nevada Administrative Code, Chapter 630
- Minnesota Board of Medical Practice: Continuing Education
- Delaware Division of Professional Regulation: Continuing Education and Audit Information (Board of Medical Licensure and Discipline)
- Delaware Administrative Code, Title 24, 1700 (Section 12.0)

