Protocol · NP · California
Practice Protocol for Nurse Practitioners in California
Required. California law names the instrument a Standardized Procedures. Below: the board that governs it, what it must contain, and the terms it has to carry.
A three-tier pathway to full independence. Standardized procedures (Tier 0) are supervised; a 103 NP drops the agreement but must practice in a group that includes a physician; a 104 NP is fully independent. 104 NP licenses could be issued as early as Jan. 1, 2026; as of Aug. 2026 the Board of Registered Nursing's AB 890 page still used pre-2026 phrasing.
Independent practice requires: '103 NP' tier (Bus. & Prof. Code §2837.103): national NP board certification + a 'transition to practice' of ≥3 full-time-equivalent years OR ≥4,600 hours of direct patient care within the preceding 5 years (need not be consecutive, per SB 1451 (2025)) — unlocks practice without standardized procedures, but only within a group practice setting that includes ≥1 physician; '104 NP' tier (Bus. & Prof. Code §2837.104): after ≥3 years practicing as a 103 NP in good standing (Board may reduce this for DNP holders) — unlocks fully independent practice outside any group/physician-integrated setting, including hospital medical staff privileges.
What a California Standardized Procedures must contain
Governed by the California Board of Registered Nursing and the California State Board of Pharmacy. Each numbered item is a statutory requirement the Standardized Procedures must satisfy.
Unless the Nurse Practitioner holds current certification from the California Board of Registered Nursing ("BRN") to practice without standardized procedures under Business and Professions Code § 2837.103 or § 2837.104, the Nurse Practitioner shall practice pursuant to written standardized procedures developed jointly by the Physician, the Nurse Practitioner, and Practice administration, as required by Business and Professions Code §§ 2835.5 and 2836.1 and Title 16, California Code of Regulations § 1474. The standardized procedures shall identify the drugs, devices, and treatments the Nurse Practitioner may furnish or order, the circumstances under which the Physician's consultation is required, and the method by which the Nurse Practitioner's competence will be periodically evaluated.
Where the Nurse Practitioner practices under standardized procedures, the Physician's supervision does not require physical presence and is satisfied by (a) collaborating on and approving the standardized procedures, and (b) being available in person or by telecommunication at the time a patient is examined. Where the Nurse Practitioner instead practices without standardized procedures under § 2837.103 or § 2837.104, this Agreement does not impose supervision requirements beyond what that certification independently permits, and the terms of this Section apply only to the extent consistent with that certification. The Parties shall retain a current copy of the standardized procedures, or of the Nurse Practitioner's § 2837.103/2837.104 certification, at each practice location, and shall produce it to the California Board of Registered Nursing upon request.
- The Standardized Procedures also carries 1 scope, 1 education and 1 registration clauses, authored in the document itself.
Terms it has to carry
Ratio, proximity, chart review, meeting and prescribing terms the Standardized Procedures has to carry, from California's supervision rules.
Proximity
Tier 0 — standardized-procedures NP: Available remotely (no on-site requirement)
Bus. & Prof. Code §2836.1: physical presence is NOT required, but the physician must be available by telephonic contact at the time of the patient examination. No mileage/radius standard is codified.
103 NP: No proximity requirement
No distance requirement on individual encounters — the only 'proximity' element is being part of a group practice that includes ≥1 physician, not a per-encounter availability standard.
104 NP: No proximity requirement
No proximity requirement of any kind — fully independent practice.
Supervision ratio
Tier 0 — standardized-procedures NP: Up to 4 at a time
Bus. & Prof. Code §2836.1: 'no physician and surgeon shall supervise more than four nurse practitioners at one time.' Does not apply to 103 or 104 NPs, since neither has a formal 1:N supervision relationship.
Chart review
Not codified — left to the agreement
Meeting cadence
Not codified — left to the agreement
Prescriptive authority
Covered by the practice agreement · controlled substances permitted
Requires CE including a Schedule-II-specific component for NPs authorized to furnish Schedule II. The 103/104 resolution above rests on absence-of-cross-reference analysis, not an explicit BRN interpretive statement — reasonably solid but not a first-hand agency confirmation.
Written agreement
Required
Branches by tier. Tier 0 (default): 'standardized procedures' required (Bus. & Prof. Code §2836.1), jointly developed with a physician per content requirements in 16 CCR §1474. 103 NP: no standardized procedures, but must practice within a group that includes ≥1 physician. 104 NP: no agreement of any kind — full independence.
Practice ownership (corporate practice of medicine)
Licensee-only ownership required — General CPOM baseline (Bus. & Prof. Code §2400) applies, but NPs have a real same-profession carve-out: Bus. & Prof. Code §2775 recognizes 'nursing corporations,' and Corp. Code §13401.5(f), CONFIRMED via direct fetch, requires RNs/NPs hold ≥51% of shares, with the remainder open to 11 listed allied licensees (physicians, PAs, psychologists, chiropractors, acupuncturists, midwives, etc.). This lets an NP majority- or wholly-own their own practice ENTITY — a separate question from whether their CLINICAL practice still needs a physician relationship (Tier 0 does; 103/104 don't).
Corp. Code §13401.5(f)'s subsection letter and ≥51% structure are confirmed via a dedicated follow-up fetch, superseding the original secondary-sourced hedge.
Sources for the supervision rules (11)
- Bus. & Prof. Code §2836.1 — Standardized procedures (Tier 0), 4-NP ratio cap
- Bus. & Prof. Code §2837.103 — '103 NP' transition-to-practice tier
- Bus. & Prof. Code §2837.104 — '104 NP' fully independent tier
- Bus. & Prof. Code §2400 — General CPOM bar
- Bus. & Prof. Code §2775 — Nursing corporations
- Corp. Code §13401.5(f) — Nursing corporation ownership percentages, confirmed verbatim
- Health & Safety Code §11165.4 — CURES consultation mandate
- 16 CCR §1474 — Standardized procedure content requirements (secondary-sourced for exact text)
- AB 890 (2020) — created the 103/104 NP independent-practice pathway
- SB 1451 (2024, Ch. 481, signed 9/22/2024, eff. 1/1/2025) — clarified that transition-to-practice hours need not be consecutive; enabled 104 NP licensure from 1/1/2026
- AB 583 (eff. 7/1/2026) — grants NPs death/fetal-death-certificate attestation authority; outside this file's supervision-requirements scope, noted for completeness only, not otherwise reflected below
About California's rules
California's NPs reach genuine full independence (AB 890/SB 1451, ~6 years total) and CNMs need zero physician involvement for definitionally 'low-risk' pregnancy care — no hours threshold. NPs/PAs may also majority-own their own practice corporations (Corp. Code §13401.5), cutting against the assumption that CA's strict, actively-enforced CPOM regime (2026 AG settlements against Carbon Health, Aspen Dental) blocks all non-physician ownership. CRNA is order-based, not supervision-based. Esthetician laser use is a flat criminal misdemeanor — no delegation pathway exists.
Other clinicians in California: see the state overview.