A summary of California's collaboration, agreement, filing, supervision, prescribing, and specialty rules for NPs and the physicians who collaborate with them.
Collaborating Physician Required? Yes, with a pathway to reduced supervision
Physician Involvement: Standard
Agreement Name: Standardized procedures
On-Site Requirements: No physical presence required
Chart Review: No fixed count; standardized procedures must set an evaluation method
Controlled Substances: Allowed with a federal DEA registration; Schedule II and III require a patient-specific protocol approved by the physician
Reduced Supervision / Transition Requirements: 4,600 hours (3 years) to practice without standardized procedures (103NP); roughly 3 more years for full independence (104NP)
California NP Collaboration Requirements Summary
Most California nurse practitioners must practice under written standardized procedures developed with and approved by a collaborating physician, who must be available by phone when the NP sees patients but need not be physically present. California also offers a path out of that arrangement: after a transition to practice of 4,600 hours (three full-time-equivalent years) an NP can practice without standardized procedures in a setting where a physician also practices (a “103NP”), and with roughly three more years of experience an NP can gain Board approval to practice fully independently in any setting (a “104NP”).
Source: Cal. Bus. & Prof. Code § 2837.101–2837.104
Type of Collaborative Relationship
Most California NPs work under written standardized procedures that a collaborating physician helps develop and approve, with the physician reachable by phone when patients are seen rather than physically on-site. California law does not automatically make the collaborating physician legally responsible for the NP’s care. A physician may supervise no more than four NPs who are furnishing (prescribing) at one time; there is no limit on NPs who are not furnishing. Over time an NP can move to less oversight: after 4,600 hours an NP may practice without standardized procedures in a group setting where a physician also practices (103NP), and with additional experience an NP may be approved to practice fully independently (104NP).
Source: Cal. Bus. & Prof. Code § 2683.1
What is an NP’s scope of practice in California?
California NPs assess, diagnose, treat, and furnish or order drugs and devices, traditionally under written standardized procedures developed with a collaborating physician. After completing the state’s transition-to-practice requirements, an NP may practice without standardized procedures and, with further experience, fully independently.
Do NPs need a collaborating physician in California?
Yes, at first. Most NPs must practice under standardized procedures with a collaborating physician; after 4,600 hours an NP can practice without standardized procedures in a setting where a physician also practices, and an experienced NP may qualify to practice independently with no physician involvement.
Can NPs practice independently in California?
Yes, eventually. California has an independent-practice pathway: an NP who completes the transition to practice (4,600 hours) plus about three additional years of practice may receive Board approval to practice without standardized procedures in any setting (known as 104NP status).
How many NPs can a physician supervise in California?
Four at a time for NPs who are prescribing medications. There is no limit on the number of NPs a physician may supervise if those NPs are not prescribing.
Who can be a collaborating physician in California?
For standard practice, the collaborating physician is the one who helps develop and approve the NP’s standardized procedures. For an NP seeking 104NP (independent) status, the person providing the required attestation — either a physician or an NP practicing under Section 2837.104 — must be in the same specialty area as the applicant and have no familial or financial relationship with them.
Are there proximity or in-person requirements in California?
No physical presence is required. The physician does not have to be on-site but must be available by telephone at the time of patient contact and close enough geographically to supervise effectively; California sets no specific mileage limit.
Collaboration Agreement Requirements
California’s written agreement is called standardized procedures. Standardized procedures must be in writing, dated, and signed; specify which functions the NP may perform and under what circumstances; state any specific requirements, experience, training, or education needed; establish a method for initial and continuing evaluation of the NP; maintain a written record of who is authorized to perform the functions; specify the scope of supervision; state when the NP must communicate with the physician; note any limits on practice settings; specify patient-recordkeeping requirements; and provide for periodic review. The document is signed by the organized health care system personnel authorized to approve it. A backup physician is not required.
Source: Cal. Code Reg. § 1474(b)
What must be included in an NP collaborative agreement in California?
Standardized procedures must be in writing, dated, and signed; specify the functions the NP may perform and any requirements, training, or setting limits; set methods for evaluating the NP’s competence and for periodic review; state when the NP must consult the physician; and specify patient record-keeping requirements.
What is the collaborative agreement called in California?
It is called standardized procedures — California’s term for the written protocol that authorizes and defines the functions an NP may perform in collaboration with a physician.
Who has to sign the collaborative agreement in California?
The organized health care system personnel authorized to approve it. California requires standardized procedures to be dated and signed by that authorized approver.
How often must the agreement be reviewed or renewed in California?
There is no fixed schedule. Standardized procedures must include a method for periodic review, and the state advises updating them often enough to ensure patients receive appropriate care as patient needs, treatments, and technology change.
Is a backup (covering) physician required in California?
No. California sets no requirement for a backup physician.
Board Filing Requirements
California does not require standardized procedures or the collaborating physician to be filed with or approved by the Medical Board or the Board of Registered Nursing. There is no routine board filing to begin standard collaborative practice and no recurring filing or termination-notice requirement for the agreement itself. Separately, an NP who wants to move beyond standardized procedures must file with the Board: an attestation is required to practice as a 103NP, and a full application is required for 104NP (independent) status.
Source: Cal. Bus. & Prof. Code § 2725(d)
Do you have to file the collaborative agreement with the board in California?
No. Standardized procedures do not have to be filed with, or approved by, the Medical Board of California or the Board of Registered Nursing. Moving to reduced-supervision or independent status is separate and does require a board attestation or application.
Can an NP start practicing as soon as they file in California?
There is nothing to file for standard collaborative practice, so no board filing gates the start of practice under standardized procedures. Transitioning to 103NP or 104NP status, by contrast, requires Board processing of an attestation or application first.
What are the termination and notice requirements in California?
None. California sets no board termination-notice requirement for ending a collaborative relationship.
Collaboration Compliance
California sets no fixed chart-review count or required meeting cadence; instead, standardized procedures must build in a method to evaluate the NP’s competence on an ongoing basis. The state evaluates the NP at 3, 6, and 12 months and annually thereafter, but the specifics are set within each practice’s standardized procedures rather than by a statewide number. Physician countersignature of NP charts is not required under the Nursing Practice Act, though other rules (such as reimbursement or malpractice-carrier requirements) may call for it.
Source: Cal. Code Reg. § 1474(b)(5)
How many charts must a collaborating physician review in California?
There is no fixed number. California does not set a chart-review count; standardized procedures must instead establish a method for evaluating the NP’s competence, which may include chart review.
How often must an NP and collaborating physician meet in California?
California sets no required meeting cadence. Standardized procedures must include an evaluation method.
How long must collaboration records be kept in California?
California sets no specific retention period. Standardized procedures must specify patient-recordkeeping requirements, but no statewide minimum retention period for collaboration records is stated.
Prescribing Rules
California NPs may furnish or order drugs, including controlled substances, once authorized, and must register with the federal DEA to do so. Schedule II and Schedule III controlled substances must be furnished or ordered under a patient-specific protocol approved by the treating or supervising physician, which specifies the categories of patients who may receive that class of drug and any other limits. NPs prescribe within their standardized procedures until they transition to independent practice.
Source: Cal. Bus. & Prof. Code § 2683.1(f), § 2683.2
Can an NP prescribe controlled substances in California?
Yes. California NPs who are authorized to prescribe controlled substances may do so with a federal DEA registration; Schedule II and III require a patient-specific protocol approved by the supervising physician.
Can an NP prescribe Schedule II drugs in California?
Yes, under a patient-specific protocol. Schedule II controlled substances must be prescribed in accordance with a patient-specific protocol approved by the treating or supervising physician, alongside a federal DEA registration.
What schedule drugs can an NP prescribe in California?
California NPs may prescribe drugs and, once authorized, controlled substances. Schedules II and Schedule III drugs require a patient-specific protocol approved by the physician.
Does an NP need a DEA license in California?
Yes. An NP authorized to furnish or order controlled substances must register with the U.S. Drug Enforcement Administration.
Can an NP prescribe independently in California?
Not under standard practice. NPs prescribe within their standardized procedures, and Schedule II and III require a physician-approved patient-specific protocol; an NP who has attained independent status may prescribe without physician sign-off.
Specialty & Telehealth Requirements
California sets no telehealth-specific collaboration requirement and no specialty-specific practice requirement. Notably, once an NP practices independently, the NP is solely responsible for the care they provide.
Source: Cal. Bus. & Prof. Code § 2837.104(c)(3)
Are there telehealth or telemedicine requirements for NPs in California?
No. California sets no telehealth-specific collaboration requirements.
Are there specialty-specific requirements for NPs in California?
Not for practice generally. The main specialty rule is that the physician (or NP) who provides the attestation for an NP’s independent (104NP) certification must be in the same specialty area as the applicant.
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