Cognitive load theory concludes that the level of learnerspsila expertise influences mental effort directly. The recent developments of evaluating learner expertise by quantitative measurement techniques are discussed in this research. Cognitive efficiency, an optimal measurement technique of expertise, was developed by Kalyuga and Sweller to replace instructional efficiency in e-learning environment for dynamically adapting instruction. But mental effort, a factor of cognitive efficiency, is assessed by a node mode measurement technique which discontinues instruction and causes interference. This research suggests a new measurement technique of assessing and measuring learnerspsila learning effort in dynamic, real-time and non-interference approach for adaptive e-learning. The learning effort curve, a friendly interface in graphic format, is developed by this technique to enhance effective interaction between instructors and learners and navigate adaptive learning.