Criterion 2 requires that the educational needs that underlie the professional practice gaps of learners be incorporated into the CME activities. However, the CME provider does not have to collect that needs data. There are many, many sources of needs data that relate to professional practice gaps. Determining if that data is relevant to the actual learners is a task for the CME provider. The ACCME's announcement of the Updated Criteria included some references that might be a place for the CME provider to start.