California Requirements at a Glance
Practice Authority
California is a Reduced Practice state (per AANP classification). Standard NPs practice under standardized procedures with a collaborating physician.
AB 890 (2020, as amended by SB 1451, eff. 1/1/2025) established two voluntary certifications, 103 NP and 104 NP, that allow practice without standardized procedures.
Path to Independence
Yes, California NPs may pursue independent practice through the voluntary 103-to-104 NP pathway.
Hours Required for Independence
4,600 hours (or 3 FTE years) of direct patient care for 103 NP status. An additional 3 FTE years (or 4,600 hours) as a 103 NP going for their 104 NP status.
Physician-to-APC Provider Ratio Cap
4 NPs per physician for standardized-procedure furnishing (Standard NPs). No fixed cap applies to 103 or 104 NPs, since no physician supervision is required for that status.
Chart Review Requirements
No fixed statutory percentage. Instead, the standardized procedure must include a process for periodically reviewing the NP’s competence, including peer review.
Meeting Requirements
No fixed statutory cadence for Standard NPs. The collaborating physician must be reachable by telephone when the NP examines a patient; physical presence is not required. 103 and 104 NPs do not have a physician meeting requirement.
Geographic Requirements
None. Remote or telephone supervision is permitted for Standard NP. 103 or 104 NP have no geographic tie to a collaborating physician.
Prescriptive/Delegation Authority Agreement
For Standard NPs: a standardized procedure must be developed and approved by the collaborating physician, NP, and facility administrator/designee, It must be reviewed at least annually.
For 103/104 NPs: no agreement is required once certified. A one-time attestation of completed “transition to practice” is filed with the BRN instead
Schedule II Prescribing
Permitted for Standard NPs under a standardized procedure that includes a Schedule II-specific protocol; 103 and 104 NPs may prescribe independently within their certified scope of practice.
Physician Collaboration Eligibility Requirements
A collaborating physician in California must:
- Hold a full, active, unrestricted California physician and surgeon license
- Have comparable specialty/competency to co-develop and approve the NP’s standardized procedure
- For 103/104 NP transition-to-practice attestations only, confirm completion of transition-to-practice hours. SB 1451 doesn’t require the attesting physician to share the NP’s specialty or verify clinical competence for this role.
DEA Requirements / Application Process
Before applying for DEA registration, the NP must hold a BRN-issued furnishing number after completing the required pharmacology course. The DEA application requires both the NP’s RN license number and furnishing number.
These requirements apply to Standard, 103, and 104 NPs alike.
Boards, Trade Associations & Authoritative Links
Disclaimer: This page for general informational purposes only and is not legal or medical advice. California requirements are set by state law and board rule and may change; consult your own counsel before relying on this information. CollabDocs facilitates physician-APC introductions and does not practice medicine or guarantee outcomes except as stated in a signed services agreement.
Reviewed by the CollabDocs Compliance Team | Last reviewed August 5,2026
California Requirements at a Glance
Practice Authority
California is a Reduced Practice state (per AANP classification). Standard NPs practice under standardized procedures with a collaborating physician.
AB 890 (2020, as amended by SB 1451, eff. 1/1/2025) established two voluntary certifications, 103 NP and 104 NP, that allow practice without standardized procedures.
Path to Independence
Yes, California NPs may pursue independent practice through the voluntary 103-to-104 NP pathway.
Hours Required for Independence
4,600 hours (or 3 FTE years) of direct patient care for 103 NP status. An additional 3 FTE years (or 4,600 hours) as a 103 NP going for their 104 NP status.
Physician-to-APC Provider Ratio Cap
4 NPs per physician for standardized-procedure furnishing (Standard NPs). No fixed cap applies to 103 or 104 NPs, since no physician supervision is required for that status.
Chart Review Requirements
No fixed statutory percentage. Instead, the standardized procedure must include a process for periodically reviewing the NP’s competence, including peer review.
Meeting Requirements
No fixed statutory cadence for Standard NPs. The collaborating physician must be reachable by telephone when the NP examines a patient; physical presence is not required. 103 and 104 NPs do not have a physician meeting requirement.
Geographic Requirements
None. Remote or telephone supervision is permitted for Standard NP. 103 or 104 NP have no geographic tie to a collaborating physician.
Prescriptive/Delegation Authority Agreement
For Standard NPs: a standardized procedure must be developed and approved by the collaborating physician, NP, and facility administrator/designee, It must be reviewed at least annually.
For 103/104 NPs: no agreement is required once certified. A one-time attestation of completed “transition to practice” is filed with the BRN instead.
Schedule II Prescribing
Permitted for Standard NPs under a standardized procedure that includes a Schedule II-specific protocol; 103 and 104 NPs may prescribe independently within their certified scope of practice.
Physician Collaboration Eligibility Requirements
A collaborating physician in California must:
- Hold a full, active, unrestricted California physician and surgeon license
- Have a comparable speciality/competency to co-develop and approve the NP’s standardized procedure
- For 103/104 NP transition-to-practice attestations only, confirm completion of transition-to-practice hours. SB 1451 doesn’t require the attesting physician to share the NP’s specialty or verify clinical competence for this role.
DEA Requirements / Application Process
Before applying for DEA registration, the NP must hold a BRN-issued furnishing number after completing the required pharmacology course. The DEA application requires both the NP’s RN license number and furnishing number.
These requirements apply to Standard, 103, and 104 NPs alike.
Boards, Trade Associations & Authoritative Links
Disclaimer: This page for general informational purposes only and is not legal or medical advice. California requirements are set by state law and board rule and may change; consult your own counsel before relying on this information. CollabDocs facilitates physician-APC introductions and does not practice medicine or guarantee outcomes except as stated in a signed services agreement.
Reviewed by the CollabDocs Compliance Team | Last reviewed August 5,2026
