Collaborating Physician in California

If you are an NP or PA practicing in California, the need for a collaborating or supervising physician depends on your license type, practice setting, and the authority under which you practice. Understanding which rules apply to you is the first step toward building a compliant practice relationship.

California has changed its approach to NP and PA practice in recent years, particularly through AB 890 and SB 697. Traditional NPs may still practice under standardized procedures, while qualifying 103 and 104 NPs have additional options to practice without standardized procedures. PAs continue to practice under a written practice agreement with a supervising physician. For NPs and PAs, this distinction matters because the phrase “collaborating physician” does not describe exactly the same legal relationship for every California provider. The California Board of Registered Nursing (BRN) regulates NPs, while the Physician Assistant Board (PAB) regulates PAs. Physicians and surgeons are regulated by the Medical Board of California or the Osteopathic Medical Board of California. Each profession has its own statutes, regulations, and requirements.

In this guide, we explain when California NPs and PAs need physician involvement, what agreements should address, how AB 890 and SB 697 changed practice requirements, and what to consider when choosing a physician collaborator or supervisor.

Do California NPs need a collaborating physician?

It depends on how the NP is practicing.

California continues to allow NPs to practice under standardized procedures. In this traditional model, the NP’s practice is structured through standardized procedures developed with the physician or organization responsible for the practice. The BRN specifically states that becoming a 103 or 104 NP is optional and that NPs may continue practicing under standardized procedures.

California also created two additional NP categories through AB 890:

• 103 NPs may practice without standardized procedures in specified group settings where at least one physician and surgeon practices with the NP.
• 104 NPs may practice without standardized procedures outside those group settings, within the scope of their national certification and subject to the requirements of California law.

This means the answer to “Do I need a collaborating physician in California?” cannot be reduced to a single yes or no.

A traditional NP may need physician involvement through standardized procedures. A 103 NP has a different statutory framework and must practice in an eligible group setting. A qualifying 104 NP may practice without standardized procedures and is not required to maintain the same type of physician relationship, although California law still requires appropriate consultation, collaboration, and referral based on the patient’s condition.

What did AB 890 change for California nurse practitioners?

AB 890, enacted in 2020, created the 103 and 104 NP categories and established a pathway for qualifying NPs to practice without standardized procedures. The BRN subsequently adopted regulations implementing these provisions, which became effective January 1, 2023. Certain provisions were later amended by SB 1451 in 2024.

What is a 103 NP?

A 103 NP is a California NP who has met additional eligibility requirements and may practice without standardized procedures in qualifying group settings.

To qualify, an NP generally needs to:

• Hold a California NP certification and a national certification
• Complete a transition to practice of at least three full-time-equivalent years or 4,600 hours of clinical practice in California within the five years before applying
• Gain that experience after BRN certification as an NP (under SB 1451, it does not have to come from a single NP category)

An NP who has practiced in direct patient care for three full-time-equivalent years or 4,600 hours within the last five years may be deemed to have met this requirement.

Where a 103 NP can practice:

• Qualifying settings where one or more physicians practice with the NP without standardized procedures
  • These include settings such as clinics, most licensed health facilities, medical group practices, home health agencies, county medical facilities, and hospices
  • Correctional treatment centers and state hospitals are excluded

Physician involvement: A 103 NP does not need standardized procedures but must practice in a qualifying setting alongside at least one physician.

What is a 104 NP?

A 104 NP is a California NP who has practiced as a 103 NP and may practice without standardized procedures outside the 103 group settings.

To qualify, an NP generally needs to:

• Practice as a 103 NP in good standing for at least three full-time-equivalent years or 4,600 hours of direct patient care
• If they hold a Doctor of Nursing Practice, count direct patient care hours from the doctoral portion of their education toward this requirement, as long as those hours are in their area of national certification

Where a 104 NP can practice:

• Any setting, inside or outside the 103 group settings
• Within the population focus of their national certification and the limits of their education, training, knowledge, and experience

Physician involvement: A 104 NP does not need an ongoing physician relationship but must have a written consultation protocol and referral plan within 90 days of certification. 

The 104 application became available in 2026, although the BRN has continued updating implementation materials following statutory changes. Check the BRN’s AB 890 page for current details before applying.

Do all California NPs need to become 103 or 104 NPs?

No.

The BRN expressly states that the 103 and 104 pathways are optional. NPs can continue practicing under standardized procedures even if they qualify for one of the newer classifications. Employers and facilities may also establish their own practice requirements.

For an NP deciding whether to pursue 103 or 104 certification, the appropriate pathway depends on the NP’s practice setting, professional goals, experience, and the requirements of the organization where the NP practices.

Do California PAs need a collaborating physician?

Yes. California PAs continue to practice with a supervising physician under a written practice agreement.

SB 697 changed how this relationship is structured. Effective January 1, 2020, the law replaced the former Delegation of Services Agreement with the Practice Agreement. The change removed several older supervision requirements, but it did not eliminate the physician relationship.

The California Physician Assistant Board states that a PA may not begin practicing independently after licensure until the PA has a supervising physician and a signed Practice Agreement.

What must a California PA Practice Agreement include?

Under Business and Professions Code section 3502.3, the Practice Agreement addresses matters including:

• The types of medical services the PA is authorized to perform
• Policies and procedures for adequate supervision
• Methods for continuing evaluation of the PA’s competency and qualifications
• Furnishing or ordering drugs and devices under applicable law
• Other provisions agreed upon by the PA and supervising physician

The agreement should therefore reflect the actual clinical services the PA will provide rather than functioning as a generic document.

Does a California supervising physician have to be physically present?

Not necessarily.

One of the important changes under SB 697 is that supervision of a PA does not generally require the supervising physician to be physically present. The practice agreement must establish adequate supervision, and the physician must be available by telephone or another electronic communication method when the PA examines a patient. The Physician Assistant Board’s updated regulations, effective October 1, 2024, also require the supervising physician to be available by telephone or other electronic communication at all times when the PA is providing medical services.

This gives California practices more flexibility in how physician supervision is structured. The physician still needs meaningful involvement in the relationship beyond signing the agreement.

The practice agreement should establish practical expectations for communication, availability, consultation, referrals, and other aspects of the PA-physician relationship. The California Physician Assistant Board specifically identifies these areas as part of adequate supervision.

What should an NP or PA look for in a collaborating or supervising physician?

Finding a physician with an active California license is only the beginning. The physician relationship should also make sense for the clinical services being provided and the way the practice operates.

We recommend considering:

Clinical alignment

Look for a physician whose experience is reasonably aligned with the services you provide. This is particularly important for specialized practices such as mental health, aesthetics, urgent care, women’s health, or other focused clinical services.

The agreement should accurately describe the services you will provide and establish an appropriate process for consultation or referral when a patient’s needs exceed your scope, training, or the terms of the practice arrangement.

Availability

A physician who is difficult to reach may not be a practical fit even if the agreement itself is well drafted.

For PAs, the Practice Agreement should establish how supervision and communication will work. California’s PA rules specifically address physician availability and communication as components of adequate supervision.

For NPs practicing under standardized procedures, the applicable standardized procedures should likewise reflect how consultation, referral, and physician involvement will occur in the actual practice.

Experience with your practice model

A physician who understands your clinical environment can make the relationship easier to manage. Consider whether the physician has experience with your patient population, procedures, telehealth model, prescribing responsibilities, or other services.

The aim is a professional relationship that matches the way care is actually delivered.

Clear expectations

Before entering into an agreement, both sides should understand:

• What services the NP or PA will provide
• How consultation will occur
• When the physician should be contacted
• How referrals will be handled
• How competency and performance will be evaluated when required
• How changes in services will be addressed
• What happens if either party wants to end the relationship

Clear expectations can prevent many of the operational problems that occur when the agreement says one thing while the practice operates another way.

What should be included in a California NP or PA collaboration agreement?

The exact document depends on the provider’s legal practice model.

For an NP practicing under standardized procedures, the standardized procedures should correspond to the NP’s actual scope of practice and the requirements of the practice setting.

For a PA, the written Practice Agreement must meet the requirements of California’s Physician Assistant Practice Act.

In either situation, the documentation should be specific enough to reflect real clinical operations.

Scope of services

The agreement should identify the services, procedures, patient populations, and other clinical activities that fall within the provider’s role.

For example, a practice offering aesthetic procedures should not rely on a generic agreement that was originally written for primary care. The clinical services and applicable policies should match the actual practice.

Prescribing and medication-related responsibilities

Medication management should be addressed consistently with California law and the provider’s applicable authority.

PAs have specific statutory requirements concerning furnishing and ordering drugs and devices, including additional requirements that can apply to controlled substances.

NPs should likewise ensure that their furnishing authority and practice arrangements are consistent with the NP’s California certification and applicable standardized procedures or AB 890 authority. Certification as a 103 NP does not automatically provide furnishing authority, so an NP without an existing furnishing number must apply for one separately.

Consultation and referral

A strong agreement should make it clear when the NP or PA should seek physician input and when referral to another healthcare professional is appropriate.

For 104 NPs, California law expressly addresses consultation, collaboration, and referral based on the patient’s clinical condition. For PAs, the Practice Agreement establishes the framework for adequate supervision, including communication, availability, consultations, and referrals.

Changes in scope

Your agreement should be reviewed when the practice changes substantially.

Adding new procedures, expanding into a new clinical specialty, changing patient populations, or opening additional locations can create new compliance questions. An agreement that accurately reflected the practice two years ago may not accurately describe the practice today.

How does telehealth affect physician collaboration in California?

Telehealth does not eliminate the need to comply with California’s scope-of-practice and supervision requirements.

For PAs, the practice agreement still establishes the framework for adequate supervision, and the supervising physician’s availability requirements continue to apply. Physical presence is generally not required solely because a PA is practicing under supervision, but the parties must follow the requirements of the Practice Agreement and California law.

For NPs, the applicable rules depend on whether the NP is practicing under standardized procedures or under the 103 or 104 framework.

Telehealth practices should also address patient location, licensure, prescribing, documentation, privacy, and other applicable federal and state requirements. Providers practicing across state lines should review the laws of each jurisdiction involved rather than assuming California rules apply everywhere.

What should California NPs and PAs know about business structure?

Physician collaboration is only one part of California practice compliance. The way a healthcare business is owned and operated can also affect whether the arrangement is lawful.

California maintains restrictions on the corporate practice of medicine. The Medical Board of California states that unlicensed persons and entities cannot control professional medical decisions, and certain business structures that allow non-physicians to own or control a medical practice are prohibited.

The structure of a medical practice can be particularly important for NPs and PAs who are starting or expanding a business.

Professional medical corporations and ownership

California permits certain professional medical corporations and other physician-owned structures, subject to applicable requirements. The Medical Board explains that professional medical corporations must comply with California’s ownership and corporate requirements.

An MSO can provide administrative services in an appropriate structure, but it cannot improperly control clinical decision-making. The Medical Board specifically identifies areas such as diagnosis, treatment, referrals, medical records, and other professional decisions as matters that cannot be controlled by unlicensed entities.

Because business structures can be highly fact-specific, NPs and PAs establishing a practice should obtain legal advice before finalizing ownership, management, compensation, and contracting arrangements.

How should collaborating physician compensation be structured?

Compensation for physician collaboration or supervision should be reviewed carefully before the agreement is signed.

California law prohibits compensation that functions as payment for patient referrals. Business and Professions Code section 650 generally prohibits offering, giving, receiving, or accepting consideration as compensation or an inducement for referring patients. The statute also addresses certain arrangements based on a percentage of revenue when compensation is for services rather than referrals and is commensurate with the value of those services.

That means there is no single compensation model that is automatically appropriate for every physician relationship.

A flat fee, hourly arrangement, or another structure may be appropriate depending on the services being provided and the facts of the relationship, but the arrangement should be reviewed for compliance with California fee-splitting restrictions and any applicable federal requirements.

If the practice bills Medicare or another federal healthcare program, additional federal fraud and abuse laws may apply.

What records should NPs, PAs, and physicians maintain?

Good documentation should demonstrate how the practice actually operates.

Depending on the practice model, relevant records may include:

• Current standardized procedures
• Current PA Practice Agreements
• Documentation of physician or PA credentialing
• NP certification and furnishing information
• Policies and procedures
• Competency evaluations
• Consultation and referral procedures
• Relevant quality improvement documentation
• Professional liability coverage documentation
• Records relating to changes in scope or practice location

The important principle is consistency. If the agreement says that a physician is available for consultation but there is no workable process for contacting that physician, the documentation does not accurately describe the practice.

Similarly, a practice should not continue relying on an agreement that no longer reflects the services being provided.

What happens if a California NP or PA is audited or investigated?

California licensing boards have authority to investigate complaints and potential violations of the laws governing their respective professions.

The best preparation is maintaining accurate records throughout the relationship, well before any inquiry begins.

For NPs and PAs, that means keeping agreements current, maintaining appropriate documentation, and making sure the actual clinical workflow matches the written arrangement.

If a licensing board contacts you about an investigation, it is important to take the inquiry seriously and consider obtaining advice from an attorney experienced in California healthcare licensing and regulatory matters. The appropriate response will depend on the circumstances of the investigation.

What has changed for California NPs and PAs?

California’s approach to advanced practice continues to evolve.

For NPs, AB 890 created the 103 and 104 categories, while subsequent legislation has modified portions of the implementation and eligibility requirements. The BRN continues to update its materials as these changes take effect.

For PAs, SB 697 replaced the former Delegation of Services Agreement with the Practice Agreement and changed several supervision requirements. California’s Physician Assistant Board subsequently adopted regulations to implement the law, with the SB 697 implementation regulations approved by the Office of Administrative Law in July 2024 and effective October 1, 2024.

Because these requirements can change, NPs and PAs should rely on current information from the applicable California licensing board and California statutes rather than older templates or summaries.

How can NPs and PAs find the right collaborating physician in California?

The right physician relationship depends on the provider’s license, practice model, clinical specialty, location, availability, and applicable California requirements.

Before selecting a physician, we recommend confirming:

1. The physician’s California license is current and appropriate for the relationship.
2. The physician’s clinical background aligns with the services you provide.
3. The physician understands the applicable NP or PA practice requirements.
4. The physician can meet the availability and communication expectations of the arrangement.
5. The agreement accurately describes your actual scope and responsibilities.
6. The compensation arrangement has been reviewed for applicable fee-splitting and referral restrictions.
7. The relationship can accommodate future changes in your practice.

For PAs, the supervising physician relationship is part of the required Practice Agreement framework. For NPs, the need for physician involvement depends on whether the NP is practicing under standardized procedures, as a 103 NP, or as a 104 NP.

How CollabDocs Can Help

At CollabDocs, our team includes NPs and PAs, so we understand that finding a physician is only one part of setting up a practice. The relationship also needs to fit the provider’s specialty, state requirements, clinical responsibilities, and long-term practice plans.

Since 2020, we have helped APPs connect with collaborating physicians across the country. Our network includes more than 3,500 physicians, and we help providers navigate the process of identifying a California collaborating physician who fits their practice needs.

For California providers, that means starting with the right question: What type of physician relationship does my license and practice model actually require?

Whether you are a traditional NP working under standardized procedures or a PA establishing a Practice Agreement, understanding that distinction can help you build the right relationship from the beginning.

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References

California Board of Registered Nursing

• California Board of Registered Nursing. AB 890: Nurse Practitioner Practicing Without Standardized Procedures.
• California Board of Registered Nursing. Advanced Practice and Certification.
• California Board of Registered Nursing. Nurse Practitioner Practice Information.
• California Code of Regulations, Title 16, Division 14, Article 8: Nurse Practitioners.

California Physician Assistant Board

• California Physician Assistant Board. Physician Assistant Practice Act.
• California Physician Assistant Board. SB 697 Frequently Asked Questions.
  
• California Physician Assistant Board. Frequently Asked Questions for Physician Assistant Applicants.
  
• California Physician Assistant Board. Laws and Regulations.

Medical Board of California

• Medical Board of California. Physician and Surgeon Practice Information.

California Legislature

• California Business and Professions Code, Section 650.
• California Business and Professions Code, Sections 2837.100–2837.105.
• California Business and Professions Code, Section 3502.3.

Federal Resources

• U.S. Department of Health and Human Services, Office of Inspector General. Fraud and Abuse Laws.

Disclaimer: This article is intended for general educational purposes and does not constitute legal advice. California laws and regulations may change. Providers should verify current requirements with the applicable licensing board and consult qualified legal counsel regarding their specific circumstances.