California NP Scope of Practice: 103, 104, and Standardized Procedures

The California nurse practitioner scope of practice is defined by three separate categories: traditional NPs who work under standardized procedures written with a supervising physician, “103” NPs who can drop those procedures inside approved group settings, and “104” NPs who can practice independently in any setting. What you are allowed to do — assess, diagnose, order tests, treat, prescribe — is broadly similar across the three, but where you can do it, whether a physician has to be involved, and what paperwork has to exist before you touch a patient are very different. Practicing outside your authorized category is a disciplinable offense, so the category matters as much as the clinical skill.

The Shared Base Every California NP Works From

There is no single regulation that lists every procedure a California NP may perform. Scope builds in layers. Title 16, Section 1485 of the California Code of Regulations places NPs within the scope of practice defined by the Nursing Practice Act for all registered nurses.¹ That base RN scope, in Business and Professions Code Section 2725, covers direct patient care, administering medications and treatments ordered by a physician, skin tests and immunizations, drawing blood, assessing patient conditions, and initiating emergency procedures or treatment changes under standardized procedures.²

NP education, national certification, and (depending on category) either a written agreement or statutory authority add the advanced practice functions on top: physical exams, diagnosing, ordering and interpreting diagnostic tests, developing and managing treatment plans, and prescribing medications and devices within the NP’s population focus.³ Procedures like suturing, wound debridement, and joint injections are permitted where the NP has formal training and can demonstrate proficiency, and more advanced procedures may need additional credentialing at the practice site.

One boundary applies across all three categories: you cannot practice beyond your clinical education, training, and national certification, no matter how many years of experience you have.

Traditional NPs Under Standardized Procedures

Before AB 890, every California NP practiced under standardized procedures. These are written agreements developed jointly by the NP, a supervising physician, and the facility administrator. They spell out which services the NP can provide, which medications the NP can prescribe, and how much physician oversight is required.⁴ This framework still applies to any NP who has not obtained 103 or 104 certification.

Two structural limits define traditional practice. No physician can supervise more than four NPs at the same time. And while the physician does not have to be in the room, they must be reachable by phone during patient encounters.

Prescribing follows the same pattern. Traditional NPs can furnish Schedule II through Schedule V controlled substances, but only the specific drugs written into the standardized procedure.⁴ Schedule II and III drugs carry an added condition: they must be furnished under a patient-specific protocol approved by the treating or supervising physician.

103 NPs: No Standardized Procedures, But Only in Group Settings

AB 890, signed into law in September 2020, created the 103 category for NPs who have completed a transition-to-practice period of at least three full-time equivalent years, or 4,600 hours of direct patient care.⁵ An NP who has practiced in direct patient care for that amount of time within the last five years can be deemed to have met the requirement, with attestation from a licensed physician, a certified 103 NP, or a certified 104 NP.³

The benefit is that a 103 NP can practice without standardized procedures and can prescribe within their area of national certification without a written physician agreement listing each drug. The constraint is location. A 103 NP must work in a setting where at least one physician also practices. Approved settings are:

Clinics as defined in Health and Safety Code Section 1200
Health facilities as defined in Health and Safety Code Section 1250, except correctional treatment centers and state hospitals
Medical group practices, including professional medical corporations, medical partnerships, and medical foundations
Home health agencies and hospice facilities

A 103 NP working in a nursing corporation cannot drop standardized procedures.⁵ And if a 103 NP’s national board certification expires, they must immediately revert to practicing under standardized procedures.

104 NPs: Full Independent Practice

The 104 category lets an NP practice outside the group settings 103 NPs are restricted to, meaning fully independent operation is possible. The qualifications are steeper. In addition to meeting all 103 requirements, a 104 NP must hold a master’s degree in nursing or a related clinical field, or a doctoral degree in nursing, and must have practiced as an NP in good standing for at least three additional years beyond the transition-to-practice period.⁶ That is a minimum of six years of NP practice before full independence. The BRN has discretion to lower the additional experience requirement for NPs holding a Doctor of Nursing Practice degree, based on experience gained during doctoral education.

Independence is not absolute. The statute requires physician consultation in four situations: emergent conditions requiring prompt medical intervention, problems that are not resolving as expected, clinical findings inconsistent with the overall picture, and any time a patient asks for it.⁶ Every 104 NP must also maintain a written referral plan for complex cases and emergencies, with specific criteria for when referral is appropriate.

Timing matters if you are planning around this category. The BRN began accepting 103 applications but has stated it will not be able to certify 104 NPs until 2026.⁵

Prescribing Across the Three Categories

California calls NP prescribing “furnishing.” Every NP who wants to prescribe, in any category, needs a furnishing number from the BRN, which requires an advanced pharmacology course covering drug selection, dosage, and patient management.⁷

For traditional NPs, the standardized procedure is the ceiling on what can be furnished. For 103 and 104 NPs, prescribing runs within the area of national certification, without a standardized procedure. NPs furnishing controlled substances in either lane must register with the DEA. NPs who furnish Schedule II drugs must also complete additional continuing education on Schedule II controlled substances as established by the BRN.⁴

All NPs with furnishing authority must use the Controlled Substance Utilization Review and Evaluation System, California’s prescription drug monitoring program. You must check a patient’s CURES history the first time you prescribe a controlled substance to them, within 24 hours before each subsequent prescription, and at least once every six months while the substance remains part of the treatment plan.⁸ The requirement covers Schedule II through V.

Keeping Your Scope: National Certification Cannot Lapse

The expanded scope for 103 and 104 NPs is tied to active national certification. National certification renews every five years, and the exact requirements depend on the certifying body. AANP-certified NPs must complete 1,000 practice hours in their population focus and 100 continuing education contact hours, including at least 25 hours in advanced pharmacology.⁹ ANCC-certified NPs need 75 continuing education hours, with at least 25 in advanced pharmacology, and at least 60 of those hours from formally approved CE providers.¹⁰

If national certification lapses, a 103 or 104 NP must stop practicing without standardized procedures immediately and revert to the traditional supervised model.⁵ The underlying RN license also has its own 30-hour continuing education requirement per two-year renewal cycle, and it has to stay active because NP certification sits on top of it.¹¹

What Happens if You Practice Outside Your Category

The BRN investigates complaints involving professional misconduct, negligence, substance abuse, or criminal activity. The most common infractions involve improper prescribing, inadequate recordkeeping, and practicing beyond the authorized scope of certification. Outcomes range from fines and probation to suspension or revocation, and criminal conduct like fraud or controlled substance diversion can also draw prosecution separate from any BRN action.

The consequences compound for 103 and 104 NPs. Their expanded scope depends on maintaining national certification and meeting the statutory criteria, so a disciplinary finding can cascade. Losing a furnishing number does not just limit prescribing; it can effectively end the ability to practice in a setting that requires prescriptive capability. Disciplinary records are public and searchable through the Department of Consumer Affairs’ BreEZe system.¹²¹³

1
Cornell Law Institute. California Code of Regulations Title 16 1485 – Scope of Practice
2
California Legislative Information. California Business and Professions Code 2725
3
California Legislative Information. California Business and Professions Code 2837-103
4
California Legislative Information. California Business and Professions Code 2836-1
5
California Board of Registered Nursing. Assembly Bill 890
6
California Legislative Information. California Business and Professions Code 2837-104
7
California Board of Registered Nursing. Advanced Practice and PHN Certification
8
Medical Board of California. CURES Mandatory Use
9
AANPCB. Recertification
10
American Nurses Credentialing Center. ANCC Certification Renewal Handbook
11
California Board of Registered Nursing. Continuing Education for License Renewal
12
California Board of Registered Nursing. License Verification
13
State of California. BreEZe