California’s AB 890 is a landmark law that allows qualified nurse practitioners to practice with greater independence, especially those under NP 103 and NP 104 pathways. It removes the long-standing requirement for physician supervision once specific criteria are met, giving NPs expanded authority to serve patients more efficiently. This shift makes AB 890 essential for NPs navigating autonomy, compliance, and new professional responsibilities.
If you need clarity on how AB 890 affects your scope, documentation, or transition to independent practice, Cohen Healthcare Law Group offers trusted legal guidance backed by over 25 years of healthcare regulatory experience. Our team helps nurses understand compliance obligations and avoid legal pitfalls. Reach out to us today!
This post will break down AB 890 in simple terms, explain how NP 103 and NP 104 differ, and outline what NPs must do to stay compliant under the new framework.
What Is California AB 890 and Why Does It Matter?
California AB 890, signed into law by Governor Gavin Newsom in 2020, introduced a major shift in how nurse practitioners can provide health care services within the state’s healthcare system. The Assembly Bill did not expand the NP scope of practice. Instead, it set up two new types of nurse practitioners, NP 103 and NP 104, which let qualified NPs work on their own without needing a doctor to supervise them, as long as they complete certain training, clinical hours, and national certification requirements. Under this law, the Board of Registered Nursing works with national certifying body organizations and certifying agencies to ensure NPs meet statewide standards, including educational training, professional examination services, and national certifications accredited by a national certifying body accredited for various nursing specialties.
These pathways are especially important as California approaches full implementation, and additional regulatory clarity is expected by 2026. This is when more proposed regulations and statewide standards will shape how NPs work across medical group practices, medical foundations, professional medical corporations, nursing corporations, home health agencies, health facilities, clinics, state hospitals, and other healing arts provider-based settings. NP 103 licensees can practice within a lawfully organized group with one or more physicians, while NP 104 licensees may operate with even greater practice authority in specific areas, provided they meet conditions related to transition to practice, good standing, and the licensee’s employment environment.
With AB 890, NPs gain the ability to function with more full practice authority in defined clinical condition settings, but the law remains limited. It does not increase the NP scope, authorize new procedures, or place NPs on par with surgeons, nurse midwives, or other healthcare professionals outside their established registered nursing role. Instead, it removes administrative barriers, such as enhancing access for patients, supporting underserved communities served, and reducing dependency on supervising physicians, while maintaining existing limits on controlled substances, peer review, medical staff membership, and the types of health care services that NPs may provide.
Who Can Apply for NP 103 Certification in California?
Under California AB 890, nurse practitioners who wish to gain more practice authority within approved settings may apply for the NP 103 certification, which is issued by the Board of Registered Nursing (BRN). To qualify, an applicant must already hold recognized California NP certification in one of the BRN-approved nursing specialties and maintain national certification from a national certifying body accredited by the appropriate certifying agencies, such as the national commission or the American Board.
Applicants must also complete the AB 890 transition to practice requirement, which is 3 full-time equivalent years or 4,600 clinical practice hours within the past five years, performed in California, as a licensed NP, and involving direct health care services to patients. This experience must be verifiable through approved providers such as a medical group practice, home health agency, health facility, clinic, state hospital, medical partnership, professional medical corporation, medical foundation, or nursing corporation, provided the setting is a lawfully organized group with one or more physicians or other healing arts providers based in California.
It’s important to note that NP 103 certification is optional. NPs may continue practicing under standardized procedures with physician supervision if they prefer. However, those who meet AB 890 requirements gain the ability to practice independently within specific clinical condition areas, though this does not grant full practice authority or expand NP scope of practice beyond what is allowed under existing registered nursing laws and administrative law constraints.
What Are the NP 103 Transition to Practice Rules?
The AB 890 transition to practice (TTP) requirement serves as structured professional development designed to prepare NPs for practicing with reduced reliance on physicians and without standardized procedures in NP 103 settings. This TTP period includes mentored practice and supervised healthcare services that build competency in patient management, team-based care, communication, interprofessional collaboration with other healthcare professionals, professionalism, and even foundational business and operational skills relevant to working within California’s evolving healthcare system. Under the law, acceptable TTP activities can occur in the following settings: clinic, health facility, home health agency, medical group practice, state hospital, medical foundation, exempt entities, or any lawfully organized group employing qualifying healthcare providers.
To count toward NP 103, TTP experience must include the direct conduct of patient care and align with statewide standards for supervision, professional examination services, and educational training recognized by the California Board. All hours must be completed in California as a licensed NP (not RN) and verified by approved supervising individuals or entities in good standing. Verification is crucial because the BRN will assess whether the practitioner met the AB 890 TTP requirements before granting NP 103 status, which supports expanded but still limited practice authority, not the unrestricted surgeon’s practice or authority given to nurse midwives or other healing arts providers. These TTP rules ensure that NPs transitioning into NP 103 are fully prepared to operate safely within specific areas of practice, maintain compliance with state regulations, and continue serving the best interests of the communities served.
Where Can NP 103s Legally Practice in California?
Under AB 890, NP 103s may practice independently in defined, lawfully organized group settings, but only within organizations that meet California’s requirements for employing or contracting with nurse practitioners. NP 103s may practice in the following approved environments:
- Clinics: including licensed community clinics, specialty clinics, and other outpatient settings that qualify as lawfully organized medical group entities.
- Health Facilities: such as hospitals, skilled nursing facilities, and ambulatory care facilities (excluding correctional facilities and state hospitals, which are not approved NP 103 settings).
- Medical Group Practices / Medical Foundations: including nonprofit medical foundation organizations, medical group practice entities, professional medical corporations, or any lawfully organized group employing one or more physicians or other healing arts providers.
- Home Health Agencies: as long as the agency is properly licensed and structured in compliance with California’s employment rules.
- Licensed Hospice Facilities: provided the hospice meets California licensing standards and operates as an eligible healthcare employer under AB 890.
These settings must align with California’s regulatory requirements for employing healthcare providers, and they must operate under legally recognized structures, such as professional medical corporations, nursing corporations, medical partnerships, or medical foundations.
However, an important note:
Even though NP 103s are permitted to practice independently under California’s AB 890, individual employers may still require standardized procedures, internal protocols, or varying levels of supervision based on their compliance policies, hospital committees, risk management rules, or organizational governance.
Who Is Eligible for NP 104 Certification in CA?
To qualify for NP 104 status in California, a nurse practitioner must first be an NP 103 in excellent standing and must have completed 3 years or 4,600 clinical practice hours under NP 103 authority. The applicant must also hold a national certification in a BRN-recognized population focus, such as family practice, pediatrics, neonatal, women’s health, gerontology, or psychiatric/mental health, issued by a national certifying body accredited for that specialty.
If the NP has a Doctor of Nursing Practice (DNP) degree, the supervised clinical hours they completed during the program can be counted towards the total experience needed, as long as they meet the standards set by AB 890 for clinical practice hours and population focus. As with NP 103, NP 104 certification is optional, and applicants are encouraged to review the benefits, responsibilities, and regulatory expectations before applying, especially since NP 104s operate with significantly more practice authority.
How Does NP 104 Independent Practice Work?
NP 104s may practice independently without physician supervision or standardized procedures, but they must remain within the legally defined scope of practice established under California’s registered nursing laws. Independent practice does not eliminate the need for good clinical judgment, as NP 104s must still consult, collaborate, or refer to other healthcare providers (including physicians, specialists, or other healing arts providers) when a patient’s clinical condition is outside their training or population focus. NP 104s must also comply with all laws governing prescribing, controlled substances, peer review, medical staff membership, and organizational regulations across clinics, health facilities, medical group practice settings, and other approved environments.
For healthcare organizations adopting NP 104 roles, such as professional medical corporations, medical foundations, nursing corporations, home health agencies, or multidisciplinary group practices, best practices include updating workflows, clarifying referral pathways, revising policies previously tied to physician supervision, and ensuring hospital or clinic hospital committees understand how NP 104 integration affects credentialing and access to health care services. Practices should also verify that all NP 104 activities align with statewide BRN proposed regulations, ensure documentation supports good standing, and maintain compliance with administrative rules that govern licensee employment, quality oversight, and best interest standards for the communities served.
Do NPs Have to Get NP 103 or NP 104 Status?
Not all nurse practitioners in California are required to pursue NP 103 or NP 104 certification under AB 890. Many NPs may continue practicing safely and legally under traditional standardized procedures with physician supervision, especially in organizations where the workflow, staffing structure, or clinical model is already functioning well.
Healthcare practices can also operate with a mix of NP types. For example, some NPs work under standardized procedures, some are designated as NP 103, and others achieve NP 104, so long as each NP’s role aligns with their scope of practice, training, and the organization’s compliance standards. The decision to apply for NP 103 or NP 104 should be based on a clear evaluation of the benefits, regulatory requirements, documentation workload, and long-term career goals for each NP.
How Should Practices Prepare for AB 890 Compliance?
Healthcare organizations should begin by reviewing and revising staffing models to accommodate NP roles under NP 103 and NP 104, ensuring that responsibilities align with AB 890’s definitions of practice authority, settings, and supervision requirements. Compliance teams must update internal policies, employment agreements, collaborative expectations, prescribing procedures for controlled substances, and liability insurance language to reflect the independent practice allowances created by AB 890.
Practices should also establish internal systems to track NP certifications, Transition to Practice (TTP) hours, national certification status, and documentation of scope compliance, especially if multiple NP categories are in use. Keeping these processes current helps maintain alignment with emerging statewide standards, proposed regulations, and the operational demands of California’s evolving healthcare system.
What Steps Should NPs Take Before 2026?
As California moves toward full implementation of AB 890 regulations by 2026, nurse practitioners should begin by reviewing their eligibility for NP 103 or NP 104 based on national certification, population focus, and accumulated clinical practice hours. NPs should actively track and document all Transition to Practice (TTP) hours, ensuring they reflect direct patient care in California and can be verified by qualifying employers or supervising providers.
It is also essential to confirm that your national certification aligns with your population focus, since the Board of Registered Nursing will require matching credentials for NP 103 and NP 104 categories. Finally, because AB 890 compliance involves nuanced regulatory standards, employment considerations, and evolving statewide rules, many NPs benefit from legal consultation to ensure they meet all requirements and fully understand how the 2026 changes may impact their practice authority and career options.
How Can You Stay Compliant Under AB 890?
Staying compliant under AB 890 begins with ensuring you meet the specific requirements for NP 103 or NP 104. This includes maintaining the correct national certification, aligning your population focus, and documenting all qualifying clinical practice hours or Transition to Practice (TTP) experience. It is also essential to verify that your employment setting meets California’s legal standards for NP practice under the bill. Keeping accurate records of certifications, TTP hours, employment history, and scope-related documentation helps protect your license and ensures you remain aligned with the expectations of the Board of Registered Nursing.
As AB 890 continues to evolve toward 2026, many practices will update their internal procedures, liability policies, and collaboration guidelines. So, NPs should regularly review their agreements and organizational policies to ensure they match the new practice authority structure.
When uncertainties arise regarding scope, documentation, or regulatory interpretation, expert legal advice can make compliance much clearer. Cohen Healthcare Law Group offers guidance to help NPs navigate AB 890 obligations and avoid compliance pitfalls. Visit our office today or contact us online.
FAQs
Nurse practitioners navigating AB 890 often have questions about the differences between NP 103 and NP 104, how Transition to Practice (TTP) works, and what independent practice requires. These FAQs provide clear answers to help NPs understand certification pathways, documentation expectations, and practical considerations as California moves toward full implementation in 2026.
What Is the Difference Between NP 103 and NP 104 Certifications?
NP 103 allows NPs to practice independently only within approved group settings that meet AB 890’s organizational requirements. NP 104 offers a higher level of autonomy, permitting independent practice across broader settings as long as the NP remains within their scope and population focus.
How Long Does It Take to Complete Transition to Practice Hours?
The TTP requirement takes 3 years or 4,600 hours of qualifying NP practice completed within the past 5 years. These hours must reflect direct patient care and meet BRN documentation and verification standards.
Can TTP Hours Outside California Count Toward Certification?
No, TTP hours must be completed in California under a valid NP license to count toward NP 103 or NP 104 certification. Out-of-state experience does not meet the BRN’s AB 890 requirements.
Do NPS Need Additional Liability Insurance for Independent Practice?
Many organizations recommend or require enhanced liability coverage for NPs practicing independently under NP 103 or NP 104. Coverage needs may vary by employer, setting, and risk level, so reviewing policies with legal or insurance experts is advisable.
Can NP 104s Collaborate With Physicians Remotely?
Yes, NP 104s can collaborate or consult with physicians and other providers remotely as long as the communication supports safe patient care and aligns with the NP’s scope and population focus. AB 890 does not require on-site physician presence for NP 104 collaboration.
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