California NP Standardized Procedures and Autonomous Practice

California nurse practitioners can practice without standardized procedures by earning one of two certifications created by Assembly Bill 890: the 103 NP designation, which allows autonomous practice in specified group settings where a physician also works, and the 104 NP designation, which extends that authority to any clinical setting, including a solo practice.¹ Both were signed into law in 2020 and sit alongside the older standardized-procedure framework, which still governs NPs who haven’t pursued or don’t yet qualify for either designation. If you’re planning your path to autonomous practice in California, the requirements, sequence, and ongoing obligations below are what actually control whether and where you can practice on your own.

The Two Autonomous Practice Tiers

AB 890 built autonomous practice as a two-step ladder, and you cannot skip the first rung.

103 NP (BPC 2837.103): Practice without standardized procedures in specified group settings where one or more physicians also practice.²
104 NP (BPC 2837.104): Practice without standardized procedures in any setting, including a solo practice operated through a nursing corporation.³

Every autonomous NP starts as a 103. After holding 103 NP certification in good standing for at least three years, you become eligible to apply for 104 NP status.¹ The sequence is deliberate: the legislature wanted a supervised proving period before granting the broader independence that 104 status carries.

Qualifying for 103 NP Certification

The core requirement is 4,600 hours of direct patient care, roughly three full-time years, completed under conditions the Board of Registered Nursing takes seriously:¹

Location: Every hour must be completed in California.
Timing: All hours must fall within the five years immediately before your application date.
Sequence: Hours count only if you had already been certified as an NP by the Board when you worked them.
Nature of work: Direct patient care only. Administrative time and teaching don’t count.

You also need active national certification from a recognized certifying body in the population focus that matches your practice area. Hours in adult-gerontology primary care won’t qualify you if your national certification is in family practice.

The five-year window catches applicants off guard. An NP who took time away from clinical work may have plenty of total hours on paper but not enough inside the qualifying window. Count backward from your intended application date before you file.

The statute also expects mentorship during those hours, not solo work with a nominal supervisor. An experienced provider should be available for consultation during your clinical workflow, guiding diagnostic reasoning and clinical judgment even if they aren’t co-signing every chart. If your work history amounted to practicing alone with no accessible mentor, documenting the mentorship element becomes a problem.

How Hours Get Verified

You don’t submit a log of hours. In your application, you list the physicians or other providers who can vouch for your transition-to-practice hours, and the Board emails them directly to attest.¹ Before you apply, confirm that your attesters have current contact information and know a request is coming.

Applying Through BreEZe

Both 103 and 104 applications go through the Board’s BreEZe online portal.⁴ The application fee is $500.⁵ As of early 2026, the Board’s posted processing time for NP certifications is about four weeks, though that figure moves with application volume.⁶

You can track status through your BreEZe account. Once approved, your license record in the Board’s public verification database updates to show the 103 NP or 104 NP designation. Do not start practicing without standardized procedures until that designation actually appears on your license.

Where a 103 NP Can Practice

The 103 designation is not blanket authority. You must work in one of the settings named in BPC 2837.103, and at least one physician must also practice in that setting:²

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
Certain congregate living facilities described in Health and Safety Code Chapter 2.5
Medical group practices, including professional medical corporations, physician-controlled corporations, medical partnerships, and medical foundations
Home health agencies
Licensed hospice facilities

The correctional and state hospital exclusion matters. If you work in the state prison health system, 103 status does not remove your standardized-procedure requirements there. The physician-presence rule is practical rather than physical: a physician must practice in the same organization, but they don’t need to be in the room during your patient encounters.

Moving Up to 104 NP

Three years in good standing as a 103 NP opens the door to 104 status, which lets you practice in settings outside the 103 list, including opening your own practice.¹³

The broader authority comes with additional structure. A 104 NP must maintain a written referral plan specific to their practice area, addressing situations that exceed their competence, patients not responding to treatment, rare conditions, atypical diagnostic presentations, and emergencies after initial stabilization.³ Physician consultation is required for emergent conditions requiring prompt intervention, problems not resolving as anticipated, history or lab findings that don’t match the clinical picture, and whenever a patient asks for it. The NP alone remains responsible for the services provided; a consultation does not create a physician-patient relationship.

The 104 designation also makes you eligible for organized medical staff membership, including voting rights in the department to which NPs are assigned, subject to bylaws and conflict-of-interest policies.³

What Autonomous NPs Can Do

Both tiers share the same clinical scope, set out in BPC 2837.103(c). The 104 NP just exercises that scope in more places. Authorized functions include:²

Conducting advanced patient assessments
Ordering, performing, and interpreting diagnostic tests, with radiology imaging you order and use in treatment, and lab work limited to what CLIA and BPC Section 1206 allow
Establishing primary and differential diagnoses
Ordering, administering, dispensing, and furnishing medications, including over-the-counter drugs, legend drugs, and Schedule II through V controlled substances
Initiating treatment plans that include nonpharmacological interventions such as durable medical equipment, nutrition plans, blood products, home health, hospice, and physical or occupational therapy
Certifying disability under Unemployment Insurance Code Section 2708 after a physical exam
Delegating tasks to medical assistants under existing delegation statutes

The hard boundary sits at your own qualifications. You cannot practice beyond your clinical education, training, national certification, and areas of concentration.³ A family NP certified in primary care doesn’t get to perform surgery just because the statute’s language is broad. National certification defines the outer edge.

Schedule II authority is where autonomy makes the most practical difference. Under standardized procedures, furnishing Schedule II controlled substances required a patient-specific protocol approved by the supervising physician.⁷ With 103 or 104 status, that requirement is gone. You prescribe on your own judgment, with no physician name on the prescription and no co-signature. Federal DEA registration is a separate requirement, covered below.

Notice and Referral Duties to Patients

Autonomous practice comes with transparency rules. Both 103 and 104 NPs must verbally inform every new patient, in a language the patient understands, that a nurse practitioner is not a physician. You also must prominently post a notice in at least 48-point Arial font in a conspicuous public location at your practice site, stating that NPs are licensed and regulated by the Board of Registered Nursing and giving the Board’s phone number and website.¹ NPs working in facilities operated by the California Department of Corrections and Rehabilitation are exempt.

Both tiers also carry a referral obligation: if a patient presents with a condition beyond your education and training, you must refer them to a physician or other appropriate provider.² Failing to refer when you should have is one of the more straightforward routes to a board complaint.

Federal and Payment Pieces

California practice authority doesn’t do the federal work for you.

DEA registration. You need a separate DEA registration to prescribe controlled substances, and the DEA relies on your state authorization to prescribe them.⁸ If you already had a DEA number under standardized procedures, it carries over, though the registered address should match your current practice location.

MATE Act training. For DEA registrations and renewals after June 2023, all registered practitioners other than veterinarians must complete eight hours of training on treating and managing patients with opioid or other substance use disorders. NPs who graduated from an accredited program within the past five years may satisfy this through their graduate curriculum if it included equivalent training. Everyone else has to complete the eight hours through an approved entity before their next DEA renewal.⁹

Medicare reimbursement. Autonomous status does not change your payment rate. Medicare pays NP services at 85 percent of the physician fee schedule when provided outside a hospital or skilled nursing facility, whether you practice independently or under physician oversight.¹⁰ Factor the 15 percent reduction into revenue projections from the start if you’re opening a practice.

Setting Up a Solo Practice

A 104 NP opening a solo practice in California cannot form a standard LLC. State law requires licensed health professionals to use a professional corporation, and for NPs that means a nursing corporation. At least 51 percent of the corporation must be owned by California-licensed registered nurses, and the corporate name must include “nursing” or “registered nursing.” Formation involves filing articles of incorporation with the Secretary of State and registering with the Board of Registered Nursing.

Some NPs choose S-corporation tax treatment for their nursing corporation, which can reduce self-employment taxes depending on income. An S-corp is a tax election filed with the IRS, not a separate legal structure. Talk to a tax professional who works with healthcare practice entities before deciding, because the payroll and reasonable-compensation compliance overhead is not trivial for a small practice.

Professional liability insurance is not optional. Every NP practicing without standardized procedures must carry professional liability insurance appropriate to their practice setting.² Annual premiums typically run from a few hundred to a few thousand dollars depending on specialty and location. Claims-made policies are cheaper year to year but require tail coverage (often 1.5 to 2 times the annual premium as a one-time payment) if you change carriers or close the practice; occurrence-based policies cost more annually and avoid that problem. For a new practice that may reorganize in its first few years, occurrence coverage often makes better financial sense.

Keeping the Designation

California requires all NPs to complete 30 contact hours of continuing education every two years for license renewal. NPs with prescriptive authority must include three hours on Schedule II controlled substances, covering addiction risks. NPs who provide primary care to a patient population that is 25 percent or more age 65 or older must dedicate at least 20 percent of their CE hours to gerontology or dementia care. The MATE Act’s eight federal hours are a separate one-time obligation tied to DEA registration, not a substitute for the recurring state Schedule II training.

The Board of Registered Nursing can act against any NP who exceeds their scope, fails to meet notification requirements, neglects the referral obligation, or practices without appropriate liability insurance. Available sanctions include public reprimands, fines, mandatory remedial education, practice restrictions or probation, license suspension, and revocation. When the Board has clear evidence that continued practice would pose immediate and serious harm to the public, it can impose an emergency suspension before finishing the full investigation.

The most common trouble spot for newly autonomous NPs isn’t dramatic scope violations. It’s the paperwork: letting the posted notice slide, skipping the verbal disclosure to a new patient, or (for 104 NPs) not maintaining a written referral plan. These feel like housekeeping until a complaint arrives and the Board starts working through the checklist.

1
California Board of Registered Nursing. Assembly Bill 890
2
California Legislative Information. California Business and Professions Code BPC 2837.103
3
California Legislative Information. California Business and Professions Code BPC 2837.104
4
California Board of Registered Nursing. Advanced Practice and Public Health Nurse Certification
5
California Board of Registered Nursing. Fee Schedule
6
California Board of Registered Nursing. Processing Times
7
California Board of Registered Nursing. Nurse Practitioner Expanded Furnishing Authority for Schedule II Controlled Substances
8
Drug Enforcement Administration. Registration Q and A
9
Drug Enforcement Administration. Opioid Use Disorder – MATE Act
10
Centers for Medicare and Medicaid Services. Advanced Practice Registered Nurses