WASHINGTON — Senate Majority Leader Bill Frist acknowledged yesterday that he may not have met all the requirements needed to keep his medical license active — even though he gave paperwork to Tennessee officials indicating that he had.

The state of Tennessee requires its licensed physicians to complete 40 hours of continuing medical education every two years. Dr. Frist, a heart-lung surgeon who is considering a 2008 presidential run, submitted a license renewal with the Tennessee Health Department stating he has fulfilled that requirement.

Responding yesterday to repeated requests from the Associated Press, a Frist spokesman said the Republican senator may not have done his continuing education after all and had contacted the Tennessee Board of Medical Examiners to see if corrective steps were necessary.

“As a result of a change in Tennessee’s regulations several years after Dr. Frist came to the Senate, he may be required to complete additional continuing medical education hours,” a spokesman, Matt Lehigh, said in a statement. “A representative of the Tennessee Board of Medical Examiners has been contacted, and Dr. Frist will meet every requirement of the Board.”

Mr. Lehigh indicated that he thought Dr. Frist was unaware of a change that Tennessee officials enacted in November 2002, which required continuing education for doctors who want to keep active licenses.

Starting with renewal applications filed in January 2005, the state required doctors to have completed 40 hours of continuing education in the two years that preceded their filing.

A renewal application that Dr. Frist filed with the Tennessee Board of Medical Examiners in February of this year specifically mentions the continuing education requirement and bears his signature.

Courses or programs are supposed to follow guidelines set by the American Medical Association or the American Academy of Family Physicians, according to Tennessee rules. Approved training generally includes attending accredited conferences or workshops and seminars. Doctors in Tennessee are required to retain proof that they participated in such programs in case the Board of Medical Examiners decides to audit them. Doctors do not have to submit such evidence when they renew their license every two years.

Dr. Frist is retiring from the Senate at the end of the year to consider a presidential run. As a senator, Dr. Frist does not maintain a medical practice but routinely emphasizes his experience as a doctor.

Dr. Frist recently took blood-pressure tests on Iowans during a visit to the state that holds the first presidential caucuses. He also keeps the letters “M.D.” next to his name on his Senate office door and has been known to keep a doctor’s bag and lab coat on hand on the campaign trail or in his Capitol Hill office.

Those sometimes come in handy. Dr. First has aided accident victims and sick tourists and also has gone on medical missions to Africa.

He was widely criticized last year for injecting himself into the debate over the brain-damaged Florida woman whose feeding tube was removed, Terri Schiavo. Dr. Frist viewed a videotape of the woman, then publicly questioned the diagnosis of her doctors. An autopsy later confirmed their judgment and not his.

A Nashville lawyer who represents doctors in trouble with the Tennessee Board of Medical Examiners, Dan Warlick, said a case such as Dr. Frist’s would likely be taken seriously.

“They have been routinely revoking licenses for physicians who have misrepresented to the board what they have done,” Dr.Warlick said.