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    Virginia · Physician

    Virginia Physician CME Requirements and Audit Guide

    If you are a MD in Virginia and just received a continuing medical education audit notice from the Virginia Board of Medicine, take a slow breath. Audits are generally administrative reviews of records, not a finding that something is wrong.

    Virginia MDs are regulated by the Virginia Board of Medicine under Va. Code §54.1-2912.1; 18 VAC 85-20, with biennial renewal and a defined CME requirement: at least 30 hours of Type 1 continuing learning in the two years before renewal (18VAC85-20-235). That 30-hour requirement became effective February 27, 2025.

    Everything below is drawn from Va. Code §54.1-2912.1; 18 VAC 85-20, and the Virginia Board of Medicine CME guidance. It is educational only and is not legal advice.

    October 2026 Regulatory Update: Virginia CME technical correction

    Reviewed October 23, 2026

    Short answer: Virginia physicians need at least 30 hours of Type 1 continuing learning in the two years before renewal under 18VAC85-20-235. That 30-hour level became effective February 27, 2025. The October 2026 change is a technical correction, not a new reduction for all physicians.

    A fast-track amendment to 18VAC85-20-330, effective October 22, 2026, updates the office-based anesthesia provision. It now refers to four hours of continuing education on anesthesia topics within the 30 hours required each biennium, replacing an older reference to 60 hours, and deletes the phrase saying those hours were subject to random audit by the Board.

    Removing that phrase does not mean your hours cannot be checked. 18VAC85-20-235 still requires you to keep all supporting documentation for six years after renewal of an active license, and failure to meet the continuing learning rules may lead to disciplinary action. Keep your records ready.

    Virginia CME documentation checklist

    Use this list to keep a clean file for each biennium. Your own notice controls if the Board asks for records.

    1. Certificates for at least 30 Type 1 hours, each showing your name, the sponsor, the activity, the date and the credit awarded.
    2. If you provide office-based anesthesia covered by 18VAC85-20-330, certificates showing four hours on anesthesia topics within those 30 hours.
    3. A note of any first-renewal exemption you relied on.
    4. A one-page summary totaling hours by cycle.
    5. Copies kept for six years after the renewal they support.

    General educational information, not legal advice. Your notice, individual order and applicable rules control. Consider consulting a professional license defense attorney about your circumstances.

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    Quick facts

    Board
    Virginia Board of Medicine
    Renewal cycle
    Biennial
    Rule citation
    Va. Code §54.1-2912.1; 18 VAC 85-20
    Hour expectation
    At least 30 hours of Type 1 continuing learning per biennium (18VAC85-20-235)
    Pharmacology / prescribers
    Office-based anesthesia providers covered by 18VAC85-20-330: 4 hours on anesthesia topics within the 30 biennial hours. Check whether other topic rules apply to your practice.
    Records retention
    Keep all supporting documentation for 6 years after renewal of an active license (18VAC85-20-235)

    What the Virginia rule actually requires

    The specifics below come from Va. Code §54.1-2912.1; 18 VAC 85-20. Virginia evaluates the total CME requirement and any embedded mandatory topic CE separately.

    • At least 30 hours of Type 1 continuing learning within the two years before renewal (18VAC85-20-235)
    • Exemption for the first biennial renewal after initial Virginia licensure (18VAC85-20-235)
    • Office-based anesthesia providers covered by 18VAC85-20-330: 4 hours on anesthesia topics counted within the 30 hours
    • Keep supporting documentation for 6 years after renewal (18VAC85-20-235)
    • DEA MATE Act 8-hour SUD training one-time for DEA registrants
    • Virginia PMP queries required for controlled substance prescribers
    • Maintain board-recognized CME provider documentation (ACCME, AOA, or state-approved)

    How Virginia MD CME audits typically work

    After renewal, the Virginia Board of Medicine may ask you to document the hours you attested to. If you receive a request, it will usually come through the email or mailing address on file. Follow the cycle, documents and response date stated in your own notice. Under 18VAC85-20-235(D), failure to meet the CME rules may lead to disciplinary action.

    The board is not trying to catch you out. The purpose of the audit is to verify that the hours and topic content you attested to at renewal can actually be documented. Most audits close quietly when the records match what was reported.

    Documentation commonly requested

    Audit notices are usually specific about what they want. Read the notice slowly and make a checklist directly from it. The most common items requested for physicians include:

    • Certificates of completion that show your name, the accredited provider name and accreditation number, the activity title, the date, and the AMA PRA Category 1 or AOA Category 1-A hours awarded
    • Documentation of mandatory topic CME (opioid/pain management, controlled substance prescribing, ethics, child abuse recognition, human trafficking, implicit bias, end-of-life care, and any state-specific topics)
    • Transcripts from ACCME, AOA, AAFP, or specialty board CME records
    • Documentation of any approved exemption, extension, or alternative pathway you claimed
    • Proof of DEA MATE Act 8-hour SUD training for DEA registrants

    Pharmacology and controlled substance requirements

    For Virginia MDs with prescriptive authority, controlled substance prescribing CME is usually scrutinized closely. Current 18VAC85-20-235 does not itself list a separate pain-management or opioid hour requirement, so confirm with the Board whether any other topic rule applies to your prescribing.

    When you save controlled substance certificates, look for explicit topic language (controlled substance prescribing, opioid prescribing, pain management, SUD, or addiction) along with a clear statement of the contact hours awarded. A general clinical course that mentions a few drugs in passing is not the same as a topic-specific activity.

    • Save certificates that explicitly identify required topic content
    • Track controlled substance prescribing CE separately when required
    • Keep your DEA registration documentation alongside your CME records
    • Maintain proof of any state-required PMP/PDMP registration and queries

    Common pitfalls physicians run into

    • Counting Category 2 / non-accredited activities toward a Category 1 / Category 1-A requirement
    • Missing a state-mandated topic when total hours look fine on paper
    • Forgetting one-time mandatory trainings (human trafficking, child abuse, suicide prevention, MATE Act)
    • Submitting screenshots instead of clean PDF certificates
    • Letting board certification or DEA registration lapse while the state license is still active
    • Relying on memory instead of pulling certificates from the CME provider portal

    How to assemble a clean response

    The single most useful thing you can do right now is gather your records in one place. A folder on your desktop, a printed binder, or a shared drive all work. You don't need a complicated system. You just need to be able to find things.

    Name each PDF clearly with the date, course title, and hours awarded. Group certificates by category that maps to the board's request: Category 1 / Category 1-A general CME, controlled substance prescribing, state-mandated topics, and one-time trainings. Add a one-page cover sheet that summarizes total hours and points the reviewer to the matching documents.

    If your hours fall short

    How a shortfall is handled depends on the Board and your facts; makeup time is not guaranteed. Honest, prompt communication is far better than silence.

    If the shortfall is significant or repeated, the board may move toward formal action. At that point, calm documentation of how you are coming into compliance, plus a written plan to prevent recurrence, makes a meaningful difference.

    Possible outcomes

    • Audit closed with no action when documentation matches the attestation
    • Administrative request for additional or missing documentation, with a short window to respond
    • Opportunity to complete makeup hours when a small shortfall is identified
    • Civil penalty or fine for clear deficiencies, often paired with a remediation plan
    • Referral to formal discipline in cases of misrepresentation or repeated noncompliance
    • Voluntary surrender or non-renewal in the most serious cases, which is rare for first-time CME issues
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    Frequently asked questions

    Boards typically use the email and mailing address on file at renewal. Keep your contact information current and watch for official correspondence around or shortly after each renewal.

    Sometimes yes, often partially. Many states accept ABMS or AOA recertification CME as evidence of competence but still require state-specific topic CE such as opioid prescribing, child abuse, or human trafficking. Verify the current rule for your specialty and state.

    Activities accredited by ACCME (Category 1) or AOA (Category 1-A) and accompanied by a certificate that explicitly states the credit type and hours. Self-reported reading or non-accredited webinars typically do not count toward Category 1 or 1-A totals.

    Only when they are accredited by an ACCME-recognized provider with a certificate that meets the board's standards. Save the certificate and the provider accreditation number, not just an attendance roster.

    Contact the CME provider for a duplicate as soon as possible. Many accredited providers keep records and can reissue certificates. If the provider is no longer in business, document your good-faith efforts and submit a brief explanation.

    Boards routinely grant short extensions when you ask in writing before the deadline. Late requests after the deadline are harder. If you need more time, ask early and explain why.

    Being selected for an audit is not an action against your license. Routine audits do not show on background checks or NPDB queries. Most close quietly when records match. Formal action is reserved for clear, documented noncompliance.

    Most routine audits do not require an attorney. If your audit moves toward formal discipline, a settlement conference, or a hearing, talking with a licensed attorney in your state is reasonable. While BoardWise cannot give legal advice, we can connect you with an independent attorney in our network who can.

    At least 30 hours of Type 1 continuing learning within the two years before renewal under 18VAC85-20-235, effective since February 27, 2025. The first biennial renewal after initial Virginia licensure is exempt. Read the official source.

    No such conclusion follows. The October 22, 2026 amendment removed a random-audit phrase from the office-based anesthesia rule. Physicians must still keep supporting documentation for six years, and noncompliance may lead to discipline. Read the official source.

    Yes. BoardWise offers optional attorney document review: once your response is drafted, we can match you with an independent attorney licensed in Virginia who reviews and suggests revisions before you submit anything to the board. It is a focused, limited-scope review rather than a full retainer, so you get a professional set of eyes on your wording, tone, and disclosures at a fixed fee. What does the attorney review cost? Pricing depends on the complexity of your matter and the scope of review, but most BoardWise lawyer reviews are approximately $250–$500. You’ll see the specific fee before deciding whether to proceed. Optional limited-scope attorney review may be available for an additional fixed fee. Attorney availability, conflicts review, eligibility requirements, and additional terms apply. If an attorney accepts the matter, the client will contract with and pay the independent attorney directly.

    Real Outcomes Reported by BoardWise Users

    BoardWise users have reported outcomes including:

    • Complaint dismissals
    • Successful responses to board inquiries
    • Passing continuing education audits
    • Early probation termination
    • Improved understanding of licensing board procedures

    Individual outcomes vary and depend on the facts of each case.

    Optional Attorney Document Review

    Before you send anything to the board, BoardWise can match physician in Virginia with an independent, state-licensed attorney for an optional limited-scope review of the document you prepared:

    • We match you with an independent attorney licensed in your state
    • They review and suggest revisions to your document before you submit it to the board
    • Focused, limited-scope review at a fixed fee rather than a full retainer
    • A second set of eyes on wording, tone, and anything that may need a closer look

    What does the attorney review cost? Pricing depends on the complexity of your matter and the scope of review, but most BoardWise lawyer reviews are approximately $250–$500. You’ll see the specific fee before deciding whether to proceed.

    Optional limited-scope attorney review may be available for an additional fixed fee. Attorney availability, conflicts review, eligibility requirements, and additional terms apply. If an attorney accepts the matter, the client will contract with and pay the independent attorney directly.

    Print & FedEx Overnight Delivery

    Finishing the document is only part of the job. BoardWise Document Delivery lets physician in Virginia send the finished packet straight to the board without a trip to the post office:

    • FedEx Overnight delivery for street addresses when your deadline is close
    • USPS Priority Express and USPS Certified Mail for P.O. Box board addresses
    • Printing, packaging, and postage handled for you, with tracking on every order
    • Confirmation and tracking details emailed to you as your package moves

    What does it cost? $150 for FedEx Overnight and $99 for USPS Priority Express or Certified Mail. You see the exact price and the full address details before you authorize the order.

    Printing and mailing are fulfilled by Mailform. You are responsible for meeting your own deadline, so keep an electronic copy and watch the tracking information.

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    BoardWise is not a law firm and does not provide legal advice or representation. This guide is educational only and reflects general practice in the United States. Your state licensing board is the official source for current requirements. If your situation involves formal discipline or a hearing, consider consulting a licensed attorney in your state.

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