This paper describes the experience of creating a continuing professional education on-line risk management program that is designed to meet Florida's educational requirements for licensure as a risk manager in health-care settings and details the challenges faced when the in-class didactic program of 15 eight-hour sessions is reformatted as an on-line program. Structuring instructor/learner interactivity remains a challenge, especially if the program allows learner control and is a key feature in marketing the program. The article presents the dilemmas for state regulators as they work to determine if the on-line program meets legislative intent and statutory requirements because the learning platform does not have a clock function that accumulates time for each learner. While some details reflect the uniqueness of the 120-hour educational requirements for risk managers in Florida, the experience of the authors provides insight into the development of continuing professional education distance learning programs that are multidisciplinary and move primarily from a time-based format into a curriculum that uses time as only one dimension of the evaluation of learning. (Contains 1 table and 1 note.)