Pain-management and opioid-prescribing CME mandates are written by state legislatures and state licensing boards. They differ in shape as well as in hour count, and they change often — two of the ten states below amended their rules during 2026.
So treat this as a dated snapshot. Every state entry was checked on September 17, 2026, and each names the board page, rule or statute it came from. Rules get amended, subsections renumbered, and board pages rewritten without notice. Confirm your own state’s requirement with your own board before you act on it — including before you act on anything you read here.
Two points up front. The federal DEA eight-hour obligation created by the MATE Act is separate from state CME, and neither satisfies the other — see our guide to MATE Act compliance for pain management physicians. And ten states appear here because ten were verified against primary sources; no pattern across them is a national norm.
How to find your own state’s requirement
The method matters more than the table, because the table ages and the method does not. Five steps give a defensible answer in any state.
- Start at the board, not at a search result. Open your state medical or osteopathic board’s own continuing-education page, then the rule it cites. Third-party summaries are the main source of wrong hour counts: for Illinois, the statute and the state agency’s FAQ say one hour while several commercial summaries say three.
- Work out which credential it attaches to. Some states condition it on holding a DEA registration, some on actually prescribing, some on direct patient care; at least one attaches it to a state controlled-substance registration rather than the license.
- Read the rule, not only the summary. Capture the citation, the effective date and the history line — the history line is where a 2026 amendment shows up.
- Check whether your degree has its own board. Usually one board licenses MDs and DOs under one rule; sometimes a separate osteopathic board writes its own, and the two differ.
- Record the clock and the date you checked. Note whether it is one-time, per cycle or on a longer interval, and when your cycle begins.
The ten states verified for this article
Each row states the requirement for physicians as its source states it. Board URLs appear as plain text rather than links, because links rot faster than rules do — the Medical Board of California pain page now 404s.
| State | Requirement as stated by the source | Source | Checked |
|---|---|---|---|
| California | One-time 12 hours of CME in pain management and the treatment of terminally ill and dying patients, due by the second license renewal. No recurring pain or opioid mandate for MDs. | Medical Board of California, Renew > CME page; Cal. Bus. & Prof. Code § 2190.5 (pathology and radiology exempt) | 2026-09-17 |
| Texas | Physicians in direct patient care: at least 2 hours of formal CME in pain management and opioid prescribing within one year of licensure, again at the second renewal, then at least once every 8 years. | Texas Medical Board, Continuing Education Requirements for Physicians; Tex. Occ. Code § 156.055 per the board page, amended by HB 2454 (86th Legislature) | 2026-09-17 |
| Florida | MDs registered with the DEA and authorized to prescribe controlled substances: a board-approved 2-hour course on prescribing controlled substances at each biennial renewal, counting within the total CE required by law. | Fla. Stat. § 456.0301; Florida Board of Medicine CME page. History line: “s. 1, ch. 2018-13; s. 1, ch. 2026-6” | 2026-09-17 |
| New York | Prescribers holding a DEA registration: at least 3 hours of coursework or training in pain management, palliative care and addiction once every three years, covering eight specified topics. Live, home-study and online formats allowed. | NYS Education Department, Office of the Professions, NYSDOH Mandatory Prescriber Education; N.Y. Public Health Law § 3309-a(3) | 2026-09-17 |
| Pennsylvania | MDs who hold or use another’s DEA registration: at least 2 hours of CE in pain management, the identification of addiction, or the practices of prescribing or dispensing opioids each biennial period, within the 100 required credit hours. | 49 Pa. Code § 16.19(b)(1). Source note: “amended April 24, 2026, effective April 25, 2026, 56 Pa.B. 2230” | 2026-09-17 |
| Illinois | Every prescriber licensed to prescribe controlled substances: 1 hour of CE on safe opioid prescribing practices during each pre-renewal period, countable toward the CE required to renew the professional license. No exemption for the first registration renewal. | 720 ILCS 570/315.5; IDFPR FAQ on the safe opioid prescribing CE requirement | 2026-09-17 |
| Ohio | No general pain, opioid or controlled-substance CME requirement for renewal. The biennial requirement is 50 CME hours, including 1 board-approved hour on the duty to report misconduct. Two practice-setting rules sit outside renewal. | Ohio Admin. Code 4731-10-02; Ohio Rev. Code § 4731.281 | 2026-09-17 |
| Georgia | Physicians with an active DEA certificate who prescribe controlled substances: at least one time, 3 or more hours of AMA or AOA PRA Category 1 CME addressing controlled substance prescribing practices — once in a career. Residency training permit holders excepted. | Ga. Comp. R. & Regs. r. 360-15-.01(4), effective January 1, 2018; Georgia Composite Medical Board CE page | 2026-09-17 |
| North Carolina | Physicians who prescribe controlled substances: at least 3 hours of controlled-substance-prescribing CME from the required 60 hours of Category 1 CME in each three-year cycle, every cycle. Residency training license holders excepted. The cycle begins on the birthday following license issuance. | 21 NCAC 32R .0101(b); NC Medical Board prescribing CME page. Amended effective April 1, 2020 | 2026-09-17 |
| New Jersey | Practitioners licensed by the Board of Medical Examiners, physicians included: 1 credit of CE on topics relating to opioid prescribing each biennial renewal cycle, from the cycle commencing July 1, 2019. The codified rule citation could not be confirmed from a primary state source, and the FAQ says the rules were still being amended. | NJ Division of Consumer Affairs, FAQ for Practitioners Licensed by the Board of Medical Examiners, FAQ 34 | 2026-09-17 |
Three footnotes. Ohio’s negative finding covers renewal only: office-based opioid treatment requires at least eight hours of Category 1 CME on substance use disorder and addiction every two years (Ohio Admin. Code 4731-33-03), and pain management clinics require at least twenty hours of category I CME in pain medicine every two years, including one or more courses on the potential for addiction (Ohio Admin. Code 4731-29-01). The Osteopathic Medical Board of California adds a recurring requirement MDs do not have: at least one of the 50 hours per two-year cycle on addiction to schedule II drugs or opioids, citing Bus. & Prof. Code § 2454.5. Pennsylvania’s State Board of Osteopathic Medicine carries a substantively identical two-hour rule at 49 Pa. Code § 25.271, with an express exemption for physicians holding no DEA registration. Where a row says nothing about a recent change, none was found in the pages read on September 17, 2026 — which is not proof that nothing changed.
Four structural categories, not one
Structure decides compliance as much as the hour count does. The verified ten fall into four categories:
- One-time in a career: California and Georgia.
- Every cycle, indefinitely: Florida, Pennsylvania, New York, North Carolina, Illinois and New Jersey — the ones physicians forget after the first cycle.
- Periodic, on a longer interval: Texas, whose eight-year gap is easy to miss.
- No renewal mandate, setting-specific rules instead: Ohio, where reading only the renewal rule and then opening a pain management clinic means reading the wrong rule.
Traps worth knowing before you buy CME
The requirement may not attach to your medical license. Illinois ties its hour to the Controlled Substances Registration renewal, not the medical license; track only the license cycle and you can be current on one credential and late on the other.
Most of these mandates are DEA-gated, not universal. Florida, Pennsylvania, New York, Georgia and Illinois condition the requirement on holding a DEA registration or controlled-substance authority; North Carolina, on actually prescribing. Texas and California reach physicians regardless of DEA status. Letting a registration lapse, or taking one out mid-cycle, can change your obligation.
A standalone attestation is not a carve-out from a general total. New York’s three hours sit on their own three-year clock as a Department of Health prescriber-education requirement, and New York imposes no general CME hour mandate on MDs, so calling them “three of your required hours” misstates it. Pennsylvania and North Carolina work the other way, drawing topic hours from a general total.
Content changes even when hour counts do not. Florida’s two-hour requirement is unchanged in count and frequency, but Chapter 2026-6, effective July 1, 2026, added the treatment of pain for patients with sickle cell disease to the statutory topic list. A 2025-compliant course may not cover the 2026 list.
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The federal DEA obligation is separate
The MATE Act eight-hour training requirement is codified at 21 U.S.C. § 823(m) (formerly § 823(l)) and imposed, in the statute’s words, “as a condition on registration” to dispense controlled substances. It conditions your federal DEA registration, satisfied by a one-time attestation on DEA Forms 224 and 224a at your first applicable registration or renewal. State pain or opioid CME is a condition of state licensure or state controlled-substance registration, enforced by a state board on a state clock.
The two overlap — one accredited eight-hour course can often be applied toward both — but they are legally distinct. Completing your state’s two hours does not satisfy the DEA attestation, and attesting to the DEA does not satisfy your state. DEA recommends keeping training certificates even though it does not require you to submit them.
What to keep in your file
For each activity, keep the certificate showing the accredited provider, activity title, completion date, credit type and number of credits; note which obligation you applied it to, since one course may count toward a state topic requirement, a general CME total and your DEA attestation; and file a dated copy of the rule you relied on. Boards audit against their rule as it read during your cycle, not as it reads today.
Our clinical reference on interventional pain procedures maps the procedure classes and their evidence, how to choose an accredited pain management CME program covers what separates accredited training from a weekend badge, and CME-accredited pain training versus a pain medicine fellowship is for anyone weighing subspecialty training. Prescribers treating patients remotely should review telehealth pain management.
Frequently asked questions
Does every state have a pain-management CME requirement?
Not uniformly, and this article cannot answer it for the whole country. Of the ten states verified on September 17, 2026, nine impose some pain, opioid or controlled-substance CME obligation on physicians; Ohio imposes none for renewal, though it attaches substantial requirements to two practice settings. States outside those ten are not described here.
Does the MATE Act eight-hour training satisfy my state requirement?
No. The MATE Act requirement is a condition on your federal DEA registration under 21 U.S.C. § 823(m); state requirements are conditions of state licensure or state controlled-substance registration. One accredited course may be applied toward both if it matches each set of criteria, but satisfying one obligation does not discharge the other.
How often do these requirements come around?
It depends on the state; general CME cycles differ too. Among the verified states, California renews biennially with 50 CME hours, Texas requires 48 credits every 24 months, Pennsylvania 100 per biennium, North Carolina at least 60 Category 1 hours every three years, Georgia not less than 40 biennially, and Ohio 50 per registration period. New York imposes no general CME hour mandate on MDs. The Illinois cycle length and New Jersey’s total could not be confirmed.
Will an Empire course count toward my state requirement?
That is a question for your board. Check four things in the rule first: whether it demands a board-approved course specifically, as Florida’s does, or accepts Category 1 CME generally, as Georgia’s and North Carolina’s do; whether the content maps to the rule’s topic list; whether your state accepts your intended format; and how the credits are designated.
Where Empire fits, and what to verify yourself
Empire Medical Training’s Pain Management Training program, THE Pain Show, is accredited for 25.25 AMA PRA Category 1 Credits™ and jointly provided by AKH, Inc, and Empire Medical Training. The agenda and full accreditation statement sit on the course page, alongside the rest of the pain management curriculum and programs such as trigger point injection training.
What we will not tell you is that those credits satisfy a named state mandate. Your board’s rule decides that, and the rules differ on the point that matters most: some accept Category 1 CME from any accredited provider, and at least one verified state requires a course the board itself approved. So read the rule against the activity’s accreditation statement and content before you register, then keep the documentation described above. CME is also not a grant of authority: it does not expand your legal scope of practice, does not itself confer privileges, and does not confer subspecialty board eligibility in pain medicine.
