• Collaborating physicians in California must hold unrestricted licenses and actively supervise NPs and PAs under strict legal standards.
• State laws AB 890 and SB 697 redefine physician collaboration by requiring tailored agreements and continuous oversight documentation.
• Noncompliance such as poor documentation, excessive supervisees, or passive oversight can trigger audits, penalties, and disciplinary action.

For those of us practicing in California, the requirements surrounding NP and PA collaboration with physicians are more than a matter of compliance. They are the foundation for maintaining safe, lawful, and sustainable clinical operations. In recent years, changes in state legislation have significantly altered how these professional relationships are structured. As a healthcare attorney and consultant, I often work with clients navigating these complexities while trying to structure their practices correctly from the beginning or reconfigure existing ones.

Two major pieces of legislation AB 890 and SB 697 have introduced new frameworks for how nurse practitioners and physician assistants engage with collaborating physicians. Understanding these laws is critical. They do not merely change a few administrative tasks; they impact scope of practice, business ownership models, and risk exposure. Whether you are a provider, physician, clinical director, or compliance officer, it’s imperative to know the rules that apply to your category of licensure and your organization’s structure.

What has become clear is that California’s approach is highly specific. The terms “collaboration,” “supervision,” and “delegation” are not interchangeable in legal contexts here. Each carries its own implications under the Business and Professions Code and the respective regulatory boards. That is why professionals must approach this topic with a high level of precision.

In California, NPs and PAs are regulated by different boards. Nurse practitioners fall under the jurisdiction of the Board of Registered Nursing (BRN), while physician assistants are regulated by the Physician Assistant Board (PAB). Physicians, of course, answer to the Medical Board of California. This triad of regulatory oversight creates a unique and often fragmented structure, especially for group practices or multi-provider clinics.

AB 890 and SB 697 are the cornerstones of recent regulatory changes. AB 890 amended the scope of NP practice in 2020, creating pathways for certain categories of NPs to operate with expanded authority in defined conditions. SB 697, passed in 2019, altered the structure for physician assistant practice agreements by eliminating the long-standing Delegation of Services Agreement (DSA) and replacing it with more flexible practice arrangements. Each law must be interpreted within the context of multiple overlapping statutes within the California Business and Professions Code.

An important point for professionals to note is that compliance does not end at the state level. Medicare, Medi-Cal, private insurers, and DEA rules overlay additional criteria that may restrict or expand what a practitioner can do in practice. This often requires reconciling policy across multiple domains.

AB 890 created two classifications of nurse practitioners under California law. A “103 NP” is a practitioner who has completed the required transition to practice period under physician collaboration. This includes a minimum of three years or 4,600 hours of clinical experience. Once this phase is completed and verified, the practitioner can apply to be recognized as a “104 NP.” The 104 designation allows them to work in defined settings without a collaborating physician.

However, this expanded scope is not universal. It only applies to certain environments, such as federally qualified health centers, group practices with physicians, and entities that provide services under contract with the state. Private practices that fall outside those categories cannot utilize 104 NPs without ongoing physician collaboration. Moreover, the BRN requires formal certification under this pathway, which involves documentation of experience, settings, and attestation by previous supervising physicians.

For 103 NPs still in transition, a formal collaboration agreement is required. This agreement must specify scope, protocols, referral relationships, and mechanisms for communication. It’s not a template document. It needs to be tailored to the NP’s training, role, and the risk profile of the services provided.

SB 697 altered the operating structure for PAs by removing the DSA as a legal requirement and introducing the Practice Agreement as the foundational document. This legislative change provides more flexibility but increases the importance of careful drafting. The agreement must define the scope of services, supervision parameters, and procedures for performance evaluation.

Unlike NPs, PAs are still subject to a supervising physician relationship. Although the law no longer requires the DSA, it does not remove the need for ongoing physician participation. The agreement must describe how that oversight is delivered, whether through regular meetings, retrospective chart review, or co-signatures in certain cases.

Another key regulatory factor is the limitation on how many PAs a physician can supervise concurrently. While this was formerly rigid, it is now subject to evaluation based on physician capacity and practice setting. However, professional liability, insurer policies, and institutional rules may still impose numerical or procedural limits.

In California, the role of a collaborating or supervising physician is defined by law and must be consistent with the scope of the physician’s license and specialty. The physician must be available for consultation, provide oversight, and participate in ongoing quality assurance processes. This role is not passive. It is subject to documentation and audit.

Physicians who act as collaborators must hold a valid, unrestricted license with the Medical Board of California and be in good standing. Disciplinary actions, probation, or lapses in malpractice coverage may disqualify them from legally engaging in these roles. Additionally, there are limitations on the number of NPs or PAs a physician may work with at one time, and exceeding those thresholds may expose all parties to disciplinary action.

In my experience, the most common errors occur when physicians assume this role casually or without understanding the responsibilities involved. Failure to maintain documentation, review performance, or be available for consultation can be treated as a violation of the standard of care. Legal exposure is not theoretical; it is real and quantifiable when regulatory boards conduct investigations.

A collaboration or practice agreement must be formalized in writing. These agreements should not be copied from other providers or sourced from online templates. They must reflect the actual clinical activities, procedures, and medications involved in the NP’s or PAs’ day-to-day duties.

Required elements include a clear statement of the scope of services, criteria for medical decision-making, medication and prescribing protocols, and emergency response procedures. Agreements should also include performance benchmarks and review schedules. Failing to update agreements when the scope changes is another common point of regulatory failure.

Retention of these agreements is critical. In California, documents must typically be retained for a minimum of seven years, and in some cases longer, depending on institutional or federal requirements. If an NP or PA changes practice settings, these documents should be archived and made available for board review if requested.

Physician involvement must be continuous and active. This includes periodic chart review, random case audits, and formal performance evaluations. Although California does not mandate co-signatures in every case, there are situations where institutional policy or insurance panels require them.

From a compliance standpoint, it is essential to document these interactions. Meeting minutes, email correspondences, and signed evaluations create a verifiable trail of collaboration. These records are often requested during Medical Board or BRN audits, and their absence may be interpreted as failure to supervise. Documentation must match operational reality to withstand scrutiny.

An effective agreement must go far beyond boilerplate. It should include detailed descriptions of services performed, how procedures are delegated, and what happens in exceptional circumstances such as equipment failure, patient complications, or inter-provider conflict.

The scope of practice section must be explicitly tied to the training and certifications of the NP or PA. For example, if cosmetic injectables are part of the service offering, the agreement must specify the types of agents used, adverse reaction protocols, and prescriptive authority for antidotes or reversal agents.

The prescribing section should mirror DEA registration status and include protocols for scheduled substances, if applicable. Each section should reflect clinical reality and not merely serve as a compliance checkbox. An agreement that is overly generic will not withstand legal review.

For both NPs and PAs, the scope of services must be consistent with state law, board regulation, and facility-specific privileges. Aesthetics, urgent care, mental health, and primary care each have their own protocols and limitations. Delegation of services must be formally approved by the collaborating physician and documented.

Protocols should be evidence-based and include criteria for escalation. Standing orders may be used for common services, but they must be reviewed regularly and signed by the physician. Deviations must be tracked and justified. Compliance software can help, but internal oversight is still critical.

California law permits telehealth and remote supervision under certain conditions, but these models require robust infrastructure. Collaborating physicians must still be available for consultation and must ensure that chart review and performance evaluations occur at the same frequency as in-person models.

Remote charting systems must be secure and HIPAA-compliant. Role definitions must be clear across sites, and multi-location practices need unified protocols. Lack of clarity in remote roles often leads to regulatory exposure and liability risk. Providers must also consider licensing restrictions in other states if operating across state lines.

Collaborating physicians must carry malpractice coverage that aligns with their role. For those involved in aesthetics, obstetrics, or urgent care, the coverage must include procedures delegated to NPs and PAs. Occurrence-based and claims-made policies each have implications for long-term risk.

NPs and PAs should also carry individual policies, and all providers should have indemnification clauses clearly defined in their agreements. In group practices or MSO structures, these clauses often intersect with employment agreements and corporate bylaws. Risk must be distributed in a way that aligns with operational control and clinical responsibility.

Documentation of coverage limits and certificate retention is also part of a good compliance plan. During audits or litigation, the absence of insurance records can complicate the defense of otherwise lawful conduct.

Boards regularly audit collaboration and supervision arrangements. Common citations include failure to document oversight, exceeding scope of practice, and incomplete practice agreements. Providers must stay informed about enforcement trends and recent board decisions.

Many of these actions can be prevented through regular compliance reviews and legal audit checklists. Maintaining a proactive relationship with counsel and compliance experts is the most reliable safeguard against licensure threats. Ignorance of the law is not a viable defense during a board inquiry.

Peer-reviewed complaint systems and quality assurance committees are other tools that help detect and address issues early. Proactive remediation is always better than reactive damage control.

California’s prohibition on the corporate practice of medicine complicates employment structures. Physicians must be owners or employees of professional medical corporations. NPs and PAs can generally not own such entities, although they can participate in MSOs that handle administrative functions.

Whether a physician is a W-2 employee or a 1099 contractor depends on the facts of the arrangement. Regulatory agencies will look at behavioral control, financial relationships, and contractual language. Misclassification can lead to penalties. Proper classification also impacts payroll taxes, workers’ compensation, and labor law compliance.

Compensating collaborating physicians must be done within the bounds of fair market value. Payments tied to a percentage of collections or volume may be interpreted as fee-splitting, which is prohibited. Hourly or flat fee models are safer but must be documented.

Stark and Anti-Kickback regulations also apply if Medicare billing is involved. Even in private pay practices, similar restrictions may be imposed by commercial carriers. Legal review of all agreements is essential before implementation. Compliance with both state and federal rules is non-negotiable.

Only licensed physicians can own and control professional medical corporations. However, NPs and PAs can partner with MSOs to manage operations. This structure must be carefully planned to ensure no control of medical decision-making is delegated to unlicensed individuals or entities.

The role of the collaborating physician in governance must be defined clearly. If the physician is also the medical director, their scope of control increases, and liability expands accordingly. Corporate documents must be reviewed to ensure consistency with clinical agreements and compensation structures.

California requires that clinical and administrative records be retained for at least seven years. Electronic systems must be secure, backed up, and accessible in the event of an audit or subpoena. This includes EMRs, contracts, credentialing files, and communication logs.

Practice agreements, performance reviews, and logs of physician interactions should be maintained separately from the patient record but linked through shared systems. Retention policies should be stated in writing and understood by all team members. A single missing document can compromise an otherwise compliant operation.

When a regulatory board initiates an inquiry, the provider must respond within specific timeframes and with complete documentation. Delays or omissions are treated as violations in themselves. Cooperation and completeness are essential to resolving matters efficiently.

Preparation involves rehearsing audit protocols with staff, updating agreements regularly, and maintaining current contact logs and chart review summaries. A well-prepared provider is far more likely to resolve issues without disciplinary outcomes. Legal counsel should be consulted at the first sign of inquiry.

Choosing a collaborating physician is not only about finding someone with the right license. The physician must have appropriate clinical experience, a clean disciplinary record, and availability that matches the needs of the NP or PA. Misalignment in goals or availability can create operational problems.

References, in-person interviews, and trial periods are all best practices. Contract terms should include exit strategies and performance metrics. Compatibility in clinical philosophy can also improve long-term collaboration.

Regular meetings, shared EMR notes, and performance evaluations create a sustainable workflow. Conflict resolution plans should be built into the agreement, not addressed ad hoc. When roles and responsibilities are clear from the start, misunderstandings are minimized.

Clinical review should be more than a box-checking exercise. Case discussions, adverse event analysis, and trend identification are all part of effective oversight. These discussions are critical for both compliance and quality improvement.

Collaboration thrives in an environment of mutual learning. Both parties should pursue continuing education in relevant areas. CME alignment can enhance quality assurance, and co-learning opportunities build professional trust and long-term collaboration.

Providers should regularly assess their knowledge against current clinical standards and board expectations. Encouraging formal and informal feedback helps keep the team clinically sharp. Education budgets should reflect these priorities.

California’s model for NP and PA collaboration will likely continue to evolve, particularly under pressure from national trends and scope-of-practice reform efforts. While laws may shift, the fundamentals of safe and lawful collaboration remain the same: clarity, documentation, availability, and mutual accountability.

For those of us working in this space, the most valuable investment is a strong foundation. With the right agreements, aligned expectations, and proactive compliance, NP and PA practice can expand within legal bounds while maintaining high standards of care. Practices that treat collaboration as a strategic asset rather than a formality will be best positioned for growth. Success is rooted not in shortcuts, but in structure.

At Collaborating Docs, we believe strong physician partnerships are essential to safe, compliant, and effective NP and PA practice. In a regulatory landscape as complex as California’s, having the right physician collaborator is not only a legal requirement, it’s a strategic decision that impacts patient care, license protection, and long-term professional success.

We were founded with a single mission: to make the collaboration process simpler, faster, and fully compliant for advanced practice providers across the country. Since 2020, our team has helped facilitate thousands of successful collaborations by connecting NPs and PAs with experienced physicians who offer more than just signatures. Every match is based on specialty alignment, regulatory standards, and a shared commitment to clinical integrity.

Our network includes over 2,000 vetted collaborating physicians, and we take pride in creating partnerships that go beyond state minimums. Whether supporting a solo provider or helping a growing practice stay compliant across multiple locations, we ensure that every collaboration meets the highest standards of quality and professionalism.

For those seeking a physician collaborator in California or any other state, our team is here to make that process seamless and reliable. We invite you to connect with us to get matched with the right physician and take the guesswork out of compliance. Let’s build the right foundation together.