California collaborating physician requirements are unlike those in any other state covered in this series. California is not a traditional restricted-practice state, and it is not a straightforward full-practice-authority state either. Assembly Bill 890, signed by Governor Newsom in 2020 and implemented beginning January 1, 2023, created three simultaneous frameworks for NP practice that operate in parallel. Traditional NPs practicing under standardized procedures still require physician involvement. Certified 103 NPs may practice in group settings without standardized procedures or a physician agreement. Certified 104 NPs, whose category became available January 1, 2026, may practice fully independently outside group settings.
For physicians entering collaboration roles in California, understanding which framework applies to each NP they work with is the first and most important step. The obligations differ significantly depending on the NP’s certification status under AB 890. This guide covers every relevant requirement a physician needs to understand in 2026, sourced directly from California Business and Professions Code and current BRN guidance.
California Collaborating Physician Overview: Where California Stands
California’s AB 890 framework creates a layered practice environment that is now fully operational for all three tiers. As of January 1, 2026, NPs meeting the qualifying experience requirements may apply for 104 NP status, making California the state with the most complex transitional NP framework in the country.
Governing Body
The California Board of Registered Nursing (BRN) governs NP certification, the 103 and 104 NP application pathways, standardized procedure oversight, and disciplinary matters under Business and Professions Code Chapter 6, Article 8 and Article 8.5. The Medical Board of California governs physician licensure and participates in standardized procedure oversight for traditional NP arrangements.
The Traditional Framework Remains Available
AB 890 did not eliminate the traditional NP practice model. NPs who have not applied for or received 103 or 104 certification from the BRN may continue to work under physician supervision with standardized procedures in their existing settings. There is no requirement for NPs to certify as 103 or 104 NPs to retain employment. The traditional model with standardized procedures remains fully available and legally compliant.
The Three-Tier NP Framework: Traditional, 103 NP, and 104 NP
California’s current NP practice landscape consists of three distinct categories operating simultaneously.
Traditional NPs
NPs who have not applied for or received 103 or 104 certification continue to practice under standardized procedures developed jointly with a supervising physician. This framework is governed by BPC § 2836.1 and requires physician involvement in developing, approving, and overseeing the procedures that define the NP’s scope.
103 NPs (BPC § 2837.103)
NPs who have completed at least 4,600 hours or three full-time equivalent years of clinical practice in California may apply to the BRN for 103 NP certification. A certified 103 NP may practice without standardized procedures but only in a group setting with at least one physician and surgeon. No individual physician collaboration agreement is required for a 103 NP. The physician’s presence in the group setting is a structural requirement of the setting, not a formal oversight obligation tied to the specific NP.
104 NPs (BPC § 2837.104)
NPs who have been certified and practiced as 103 NPs in good standing for at least three years may apply for 104 NP certification beginning January 1, 2026. A certified 104 NP may practice without standardized procedures outside of a group setting, within the population focus of their national certification. A 104 NP can open their own practice and practice fully independently. However, a 104 NP is still required under BPC § 2837.104(c) to consult and collaborate with other health care practitioners as clinically appropriate, including consulting with physicians when emergent conditions arise beyond the NP’s scope.
Traditional NPs and Standardized Procedures: The Active Collaboration Framework
For traditional NPs who have not obtained 103 or 104 certification, the standardized procedure is the legal instrument that governs the NP’s prescribing and clinical scope. This is the framework most relevant to physicians seeking active collaboration roles with NPs in California.
Under BPC § 2836.1, a nurse practitioner may furnish or order drugs or devices when those drugs are furnished or ordered in accordance with standardized procedures or protocols developed by the nurse practitioner and the supervising physician and surgeon. The standardized procedure must be consistent with the practitioner’s educational preparation or for which clinical competency has been established and maintained.
The Standardized Procedure Is a Jointly Developed Document
Unlike a prescriptive authority agreement authored primarily by one party, a California standardized procedure must be developed and approved by the supervising physician and surgeon, the nurse practitioner, and the facility administrator or the designee. All three parties participate in creating the document.
The Physician Determines Extent of Supervision
Under BPC § 2836.1(g)(2), a physician and surgeon may determine the extent of supervision necessary in the furnishing or ordering of drugs and devices. This provision gives the supervising physician discretion over how closely they will oversee the NP’s prescribing. The degree of supervision is not numerically prescribed but must be appropriate for the clinical context and the NP’s established competency.
Where the Standardized Procedure Must Be Maintained
Standardized procedures must be maintained at the practice location, reviewed periodically, and updated to reflect changes in the NP’s scope or the clinical environment. The physician and NP should both retain current copies. California does not require standardized procedures to be filed with the BRN or the Medical Board before the NP begins practice.
What Standardized Procedures Must Contain
A valid California standardized procedure must address all of the following:
1. Authorized Functions and Procedures
The document must describe the functions and procedures the NP is authorized to perform under the supervising physician’s oversight, including the specific acts of prescribing, dispensing, or ordering medications and devices.
2. Drug Categories and Devices
The standardized procedure must identify the categories of drugs, devices, or treatments the NP is authorized to furnish or order. The scope must be consistent with the NP’s educational preparation and clinical competency as established and maintained at that practice.
3. Supervision Process
The procedure must establish the degree and method of supervision that applies, including how the physician will be available for consultation and how patient care decisions requiring physician involvement will be handled.
4. Documentation Requirements
The standardized procedure must address recordkeeping for acts performed under it, consistent with applicable law and professional standards.
Physician Eligibility and the Extent-of-Supervision Standard
A California supervising physician for traditional NP arrangements must hold a current, active California physician and surgeon license. The physician must be competent in the clinical areas addressed in the standardized procedure.
No Ratio Limit
California does not impose a statutory ratio cap on the number of NPs a physician may supervise through standardized procedures. The physician determines the extent of supervision appropriate for each arrangement.
No Geographic Proximity Requirement
California does not impose a geographic proximity requirement on supervising physicians for traditional NP standardized procedure arrangements. The supervision model is defined in the standardized procedure and may include remote availability by telecommunications.
The 103 NP: Practice in Group Settings Without Standardized Procedures
A certified 103 NP represents a significant departure from the traditional NP oversight model. The physician’s formal role in developing and approving standardized procedures does not apply to certified 103 NPs.
What a 103 NP Can Do
Within the population focus of their national certification, a certified 103 NP may practice without standardized procedures, diagnose and treat patients, manage medications, and function under the exclusive licensure authority of the BRN without physician co-development of prescribing protocols.
The Group Setting Requirement
A 103 NP may only practice without standardized procedures in a group setting with at least one physician and surgeon. This includes health systems, clinics, medical groups, and similar organized practices where at least one physician is part of the practice structure. The physician does not need a formal written agreement with the 103 NP, and the physician is not the 103 NP’s supervising physician in the traditional sense.
The 104 NP: Full Independent Practice Beginning January 2026
The 104 NP category became available for applications beginning January 1, 2026. This is the most significant development in California NP practice in decades.
Eligibility Requirements
To apply for 104 NP certification, an NP must:
- Hold current 103 NP certification from the BRN
- Have practiced as a 103 NP in good standing for at least three years
Practice Authority
A certified 104 NP may practice without standardized procedures outside of a group setting, within the population focus of their national certification, which includes family, adult gerontology, neonatal, pediatrics, women’s health, and mental health. A 104 NP may open their own practice and function without any physician oversight requirement.
The Consultation Obligation That Remains
Even with full independent practice authority, a 104 NP is still required to consult with physicians when emergent conditions arise beyond the 104 NP’s clinical training. This is a professional practice standard, not a formal collaboration agreement requirement.
The First Wave of 104 NPs
Since the 103 NP pathway began in 2023, the first wave of NPs eligible for 104 certification became available in 2026. Some NPs with prior qualifying experience credited under SB 1451 achieved 104 status earlier than the general timeline. By 2026, a substantial portion of California’s NP community is expected to qualify for or already hold 104 certification.
SB 1451: The January 2025 Updates That Changed Eligibility
Senate Bill 1451, effective January 1, 2025, made several important adjustments to the AB 890 framework.
Prior Experience Now Counts
SB 1451 allows 103 NP applicants to count clinical experience obtained before January 1, 2021 toward the 4,600-hour threshold. This experience is not limited to a single certification category. This retroactive credit accelerated 103 NP eligibility for NPs with substantial prior practice experience and contributed to the earlier-than-expected wave of 103 to 104 NP transitions in 2025 and 2026.
Patient Disclosure Requirements Simplified
Under the updated rules:
- 103 and 104 NPs are no longer required to verbally inform patients that they are not a physician; written notice is sufficient
- The specific Spanish-language phrase previously required has been removed
- The requirement to notify patients of their right to see a physician has been removed
Prescriptive Authority and Controlled Substances in California
Traditional NPs
Traditional NPs may prescribe medications, including controlled substances, within the scope defined by the standardized procedure. The pharmacology course requirement under BPC § 2836.1(g) must be satisfied. The supervising physician determines the extent of supervision for controlled substance prescribing within the standardized procedure framework.
103 and 104 NPs
Certified 103 and 104 NPs may prescribe Schedule II through V controlled substances within their population focus and national certification scope, as authorized by the BRN. No physician delegation or agreement is required for controlled substance prescribing by certified 103 or 104 NPs.
All NPs prescribing controlled substances in California must register with CURES (California’s Controlled Substance Utilization Review and Evaluation System) and comply with applicable DEA and state controlled substance registration requirements.
The Corporate Practice of Medicine Doctrine
California enforces a strict corporate practice of medicine doctrine that prohibits unlicensed entities from employing physicians or controlling medical decision-making. For NP-operated clinics in California, this doctrine creates significant structural considerations regardless of the NP’s AB 890 certification tier.
Even 104 NPs with full independent practice authority cannot structure their clinics in ways that violate the corporate practice of medicine doctrine. Physicians considering collaboration arrangements or service agreements with any California NP clinic should have the clinic’s corporate structure reviewed by California healthcare counsel before signing. Corporate practice of medicine violations carry significant regulatory exposure for both the physician and the clinic.
Where Physician Collaboration Still Applies in California
Despite California’s significant movement toward NP independence, physician collaboration remains active in several important contexts:
- Traditional NPs: Any NP who has not obtained 103 or 104 certification continues to require standardized procedures developed and approved with a supervising physician.
- Physician assistants: PAs in California continue to require a written supervision or collaboration agreement with a supervising physician under BPC § 3516 et seq. PA oversight requirements were not changed by AB 890.
- Institutional or payer requirements: Health systems, hospitals, and managed care organizations may impose physician collaboration requirements beyond what state law mandates, even for 103 and 104 NPs.
- Emergency consultation: 104 NPs are required to consult with physicians when emergent conditions arise beyond their scope, creating an ongoing clinical relationship with physicians regardless of formal oversight requirements.
Common Compliance Mistakes California Collaborating Physicians Make
- Treating a 103 NP as a traditional NP. A physician who develops standardized procedures for a certified 103 NP is creating documents that are not required and may create unnecessary liability by suggesting the physician is responsible for overseeing that NP’s prescribing.
- Standardized procedures not updated when scope changes. Traditional NP standardized procedures must reflect the actual scope of the NP’s practice. Documents that authorize clinical activities the NP no longer performs, or fail to address new services the NP has added, are not current.
- Corporate practice of medicine not addressed. Physicians who sign any services agreement with a California NP clinic should have the clinic’s corporate structure reviewed by healthcare counsel. Corporate practice of medicine violations carry significant regulatory exposure.
- Not verifying NP certification tier before structuring the arrangement. A traditional NP who obtained 103 certification after the arrangement was formed no longer needs the standardized procedure developed under the old arrangement. Arrangements must match the NP’s current status.
California Collaborating Physician Requirements: Quick Reference
NP Practice Framework
- Traditional NPs: Must practice under standardized procedures developed with a supervising physician; physician oversight applies
- 103 NPs (BPC § 2837.103): Practice without standardized procedures in group settings with at least one physician; no individual physician agreement required
- 104 NPs (BPC § 2837.104): Full independent practice outside group settings; consultation with physicians for emergent conditions required; first eligible January 1, 2026
Standardized Procedure Requirements (Traditional NPs)
- Developed and approved jointly by supervising physician, NP, and facility administrator
- Must address: authorized functions, drug categories, supervision process, documentation
- Maintained at practice location; not filed with state boards
- Physician determines extent of supervision
Physician Eligibility
- Active California MD or DO license
- Competent in the clinical areas covered by the standardized procedure
- No ratio limit; no geographic proximity requirement
SB 1451 Changes (January 1, 2025)
- Pre-2021 clinical experience now counts toward 4,600-hour 103 NP threshold
- Patient disclosure requirements simplified for 103 and 104 NPs
PA Collaboration
- PAs still require physician supervision or collaboration under BPC § 3516 et seq.
Corporate Practice of Medicine
- California’s strict CPOM doctrine requires proper medical entity structure for all NP-operated clinics
Clinics Also Need to Understand California Collaboration Requirements
While this guide primarily covers the physician collaboration framework in California, these regulations directly affect NP-operated clinics, medspas, and healthcare practices at every stage of the AB 890 transition. In many cases, clinic owners researching California collaboration rules are trying to understand whether their NP’s certification tier still requires a physician, whether a standardized procedure needs to be maintained, or whether the 103 group setting requirement affects their clinic structure.
Need Help Finding a California Collaborating Physician?
For clinics with traditional NPs who still practice under standardized procedures, the next challenge is finding a qualified supervising physician who understands the California standardized procedure framework, is prepared to jointly develop and approve the required documents, and understands the corporate practice of medicine requirements. Whether you are launching a new clinic with a traditional NP, restructuring an existing arrangement as your NPs transition to 103 or 104 status, or navigating the PA collaboration requirements that remain active regardless of AB 890, having the right physician relationship in place matters.
If your clinic is actively looking for a California collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across California to simplify the physician matching process while supporting standardized procedure drafting, scope compliance, and long-term collaboration needs.
Final Thoughts
California collaborating physician requirements reflect a state in active, phased transition toward NP independence. The traditional standardized procedure model remains fully available and fully legally required for NPs who have not certified under 103 or 104 status. For those NPs, physician collaboration remains a genuine, documented, and supervisory obligation. For 103 and 104 NPs, the physician’s role has changed materially from active oversight partner to group setting presence or emergency consultation resource.
For physicians entering the California market, the most important step is identifying which tier the NP falls into before determining what the arrangement should look like. The compliance obligations and documentation requirements differ significantly across tiers, and applying the wrong framework to the wrong NP creates exposure in both directions.
Build a Compliant California Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in California? If you are a licensed California physician interested in a structured, compliant collaboration arrangement with an NP-operated clinic, Collaborating Physician handles the infrastructure so you do not have to figure it out alone. The platform connects licensed physicians with vetted clinics across California and 50-plus other states. Every arrangement is built to meet state-specific requirements, including California’s standardized procedure framework under BPC § 2836.1, the AB 890 certification tier distinctions, PA supervision obligations under BPC § 3516, and California’s corporate practice of medicine requirements. Physicians receive compliance support throughout the collaboration, not just at the start. Applications take under ten minutes. Clinic matches typically happen within 24 to 48 hours. There is no cost to physicians at any stage.
If you are a clinic owner who found this page, we have something for you as well. Collaborating Physician also matches California clinics with qualified, vetted supervising physicians who understand the AB 890 framework, the standardized procedure requirements for traditional NPs, and the group setting structural requirements for 103 NPs. Whether you are launching a new clinic, managing the transition as your NPs move from traditional to 103 or 104 status, or replacing a physician whose arrangement is ending, the network is active and placements happen within 24 to 48 hours. For clinics looking for a collaborating physician, get matched fast.
Disclaimer: This content is for educational and informational purposes only. It does not constitute legal or medical advice. California healthcare regulations are actively evolving under AB 890 and related legislation. Always verify current requirements directly with the California Board of Registered Nursing, the Medical Board of California, and a qualified California healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a California NP always need a supervising physician?
It depends on the NP’s certification status. Traditional NPs who have not obtained 103 or 104 certification must practice under standardized procedures developed with a supervising physician. Certified 103 NPs may practice without standardized procedures in group settings with at least one physician present. Certified 104 NPs may practice fully independently outside group settings without any physician supervision or formal collaboration agreement.
What is a 103 NP in California?
A 103 NP is a nurse practitioner certified by the California BRN under BPC § 2837.103 who has completed at least 4,600 hours or three full-time equivalent years of clinical practice in California. A 103 NP may practice without standardized procedures only in a group setting with at least one physician and surgeon. No individual physician collaboration agreement is required.
When did 104 NPs become available in California?
The 104 NP category became available for applications beginning January 1, 2026. Eligibility requires having practiced as a certified 103 NP in good standing for at least three years. Some NPs with prior qualifying experience credited under SB 1451 achieved 104 status ahead of the general 2026 timeline.
Does a California physician need to co-develop and approve standardized procedures?
Yes, for traditional NPs. Under BPC § 2836.1, standardized procedures must be developed and approved by the supervising physician and surgeon, the NP, and the facility administrator or designee. This joint development requirement applies to NPs who have not obtained 103 or 104 certification.
What does California’s corporate practice of medicine doctrine mean for NP clinics?
California strictly prohibits unlicensed entities from employing physicians or controlling medical decision-making. NP-operated clinics must be structured appropriately to comply with this doctrine, regardless of the NP’s AB 890 certification tier. Physicians considering service agreements with California NP clinics should have the clinic’s corporate structure reviewed by California healthcare counsel before signing.
Do certified 104 NPs have any physician obligations at all?
Yes. Under BPC § 2837.104(c), a 104 NP is required to consult and collaborate with other health care practitioners as clinically appropriate, including consulting with physicians when emergent conditions arise beyond the 104 NP’s training. This is a professional practice obligation, not a formal collaboration agreement requirement.
