The 4,600-Hour Transition to Practice: What California Actually Counts

What Exactly Is the Transition to Practice Requirement?

It is the fourth eligibility requirement for 103 NP certification, and the one most people underestimate. BPC §2837.103(a)(1)(D) requires that an applicant "has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours" 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(1)(D): 'Has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours,' plus the deeming clause for an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours 'within the last five years, as indicated on the application'; (D)(i) attestation 'from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104'; (D)(ii) attestor need not specialize in the same category; (D)(iii) attestor 'shall only attest to the completion of the transition to practice'; (D)(iv) attestor immunity 'unless the attestation was produced fraudulently.'.

The content of that period is defined at BPC §2837.101(c): "additional clinical experience and mentorship provided to prepare a nurse practitioner to practice independently," including but not limited to "managing a panel of patients, working in a complex health care setting, interpersonal communication, interpersonal collaboration and team-based care, professionalism, and business management of a practice" 2Ref 2California State Legislature (2024).Business and Professions Code § 2837.101 — Definitions, including “transition to practice” (amended by Stats. 2024, Ch. 481 (SB 1451)).BPC §2837.101(c) defines 'transition to practice' as 'additional clinical experience and mentorship provided to prepare a nurse practitioner to practice independently,' including 'managing a panel of patients, working in a complex health care setting, interpersonal communication, interpersonal collaboration and team-based care, professionalism, and business management of a practice,' and directs the board to define minimum standards by regulation; (c)(1) clinical experience 'shall not be limited to experience in a single category'; (c)(2) experience before January 1, 2021 may count but experience before NP certification shall not.. The board is directed to define minimum standards by regulation, which it has done in Title 16 of the California Code of Regulations 2Ref 2California State Legislature (2024).Business and Professions Code § 2837.101 — Definitions, including “transition to practice” (amended by Stats. 2024, Ch. 481 (SB 1451)).BPC §2837.101(c) defines 'transition to practice' as 'additional clinical experience and mentorship provided to prepare a nurse practitioner to practice independently,' including 'managing a panel of patients, working in a complex health care setting, interpersonal communication, interpersonal collaboration and team-based care, professionalism, and business management of a practice,' and directs the board to define minimum standards by regulation; (c)(1) clinical experience 'shall not be limited to experience in a single category'; (c)(2) experience before January 1, 2021 may count but experience before NP certification shall not.3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: qualifying transition-to-practice experience must be 'Completed in California,' 'Completed within five years prior to the date the applicant applies for certification as a 103 NP,' 'Completed after certification by the Board of Registered Nursing as a NP' and 'Completed in direct patient care'; a DO may attest; a 103 NP or 104 NP may attest; 'The attestor cannot have a familiar or financial relationship with the applicant and will be attesting to the applicant's completion of the transition to practice requirement under penalty of perjury'; BreEZe emails each identified attestor, who may approve, disapprove or partially approve the claimed hours..

The same period is also the foundation for the 104. BPC §2837.104(b)(3) requires three further years of practice in good standing "not inclusive of the transition to practice" — see what a 104 NP is.

Which Hours Count, and Which Do Not?

The BRN states four criteria for qualifying transition-to-practice experience 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: qualifying transition-to-practice experience must be 'Completed in California,' 'Completed within five years prior to the date the applicant applies for certification as a 103 NP,' 'Completed after certification by the Board of Registered Nursing as a NP' and 'Completed in direct patient care'; a DO may attest; a 103 NP or 104 NP may attest; 'The attestor cannot have a familiar or financial relationship with the applicant and will be attesting to the applicant's completion of the transition to practice requirement under penalty of perjury'; BreEZe emails each identified attestor, who may approve, disapprove or partially approve the claimed hours.:

• Completed in California.
• Completed within five years prior to the date the applicant applies for certification as a 103 NP.
• Completed after certification by the Board of Registered Nursing as an NP.
• Completed in direct patient care.

The statute reinforces the third: clinical experience "may include experience obtained before January 1, 2021, but clinical experience obtained before a person is certified by the board as a nurse practitioner shall not be included" (BPC §2837.101(c)(2)) 2Ref 2California State Legislature (2024).Business and Professions Code § 2837.101 — Definitions, including “transition to practice” (amended by Stats. 2024, Ch. 481 (SB 1451)).BPC §2837.101(c) defines 'transition to practice' as 'additional clinical experience and mentorship provided to prepare a nurse practitioner to practice independently,' including 'managing a panel of patients, working in a complex health care setting, interpersonal communication, interpersonal collaboration and team-based care, professionalism, and business management of a practice,' and directs the board to define minimum standards by regulation; (c)(1) clinical experience 'shall not be limited to experience in a single category'; (c)(2) experience before January 1, 2021 may count but experience before NP certification shall not.. So your pre-certification RN years, however long, do not count.

One constraint was loosened in 2025. Clinical experience "shall not be limited to experience in a single category that a nurse practitioner may practice in pursuant to Section 2836" (BPC §2837.101(c)(1)) 2Ref 2California State Legislature (2024).Business and Professions Code § 2837.101 — Definitions, including “transition to practice” (amended by Stats. 2024, Ch. 481 (SB 1451)).BPC §2837.101(c) defines 'transition to practice' as 'additional clinical experience and mentorship provided to prepare a nurse practitioner to practice independently,' including 'managing a panel of patients, working in a complex health care setting, interpersonal communication, interpersonal collaboration and team-based care, professionalism, and business management of a practice,' and directs the board to define minimum standards by regulation; (c)(1) clinical experience 'shall not be limited to experience in a single category'; (c)(2) experience before January 1, 2021 may count but experience before NP certification shall not. — SB 1451 removed the requirement that the hours sit within one practice area 5Ref 5Senator Angelique Ashby (California State Legislature) (2024).Senate Bill 1451 — Healing arts (Chapter 481, Statutes of 2024), chaptered bill text and Legislative Counsel's Digest.SB 1451 (Ashby, Chapter 481, Statutes of 2024) Legislative Counsel's Digest: the bill 'would specify that, for purposes of transition to practice, clinical experience shall not be limited to experience in a single category in which a nurse practitioner may practice' and 'would prohibit experience obtained before a person is certified as a nurse practitioner from being considered clinical experience'; it would deem an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours within the last five years to have satisfied the requirement, and require proof of completion 'as an attestation from either a licensed physician and surgeon or a nurse practitioner.'. And BPC §2837.103(a)(1)(D) now says an NP practicing in direct patient care for at least three full-time-equivalent years or 4,600 hours within the last five years, as indicated on the application, "may be deemed to have satisfied this requirement" 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(1)(D): 'Has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours,' plus the deeming clause for an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours 'within the last five years, as indicated on the application'; (D)(i) attestation 'from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104'; (D)(ii) attestor need not specialize in the same category; (D)(iii) attestor 'shall only attest to the completion of the transition to practice'; (D)(iv) attestor immunity 'unless the attestation was produced fraudulently.'.

Who Attests, and What Are They Actually Attesting To?

Proof is an attestation, not a logbook. BPC §2837.103(a)(1)(D)(i) requires proof of completion of one transition to practice, on a form prescribed by the board, "as an attestation from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104" 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(1)(D): 'Has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours,' plus the deeming clause for an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours 'within the last five years, as indicated on the application'; (D)(i) attestation 'from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104'; (D)(ii) attestor need not specialize in the same category; (D)(iii) attestor 'shall only attest to the completion of the transition to practice'; (D)(iv) attestor immunity 'unless the attestation was produced fraudulently.'. The BRN confirms a Doctor of Osteopathy may also attest 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: qualifying transition-to-practice experience must be 'Completed in California,' 'Completed within five years prior to the date the applicant applies for certification as a 103 NP,' 'Completed after certification by the Board of Registered Nursing as a NP' and 'Completed in direct patient care'; a DO may attest; a 103 NP or 104 NP may attest; 'The attestor cannot have a familiar or financial relationship with the applicant and will be attesting to the applicant's completion of the transition to practice requirement under penalty of perjury'; BreEZe emails each identified attestor, who may approve, disapprove or partially approve the claimed hours..

The attestor's exposure is deliberately narrow. They are "not required to verify competence, clinical expertise, or any other standards related to the practice of the applicant and shall only attest to the completion of the transition to practice," and they need not specialize in the same category as the applicant 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(1)(D): 'Has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours,' plus the deeming clause for an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours 'within the last five years, as indicated on the application'; (D)(i) attestation 'from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104'; (D)(ii) attestor need not specialize in the same category; (D)(iii) attestor 'shall only attest to the completion of the transition to practice'; (D)(iv) attestor immunity 'unless the attestation was produced fraudulently.'. They are also shielded from civil, criminal, administrative, disciplinary, employment, credentialing, contractual and medical-staff liability for providing — or refusing to provide — an attestation, "unless the attestation was produced fraudulently" 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(1)(D): 'Has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours,' plus the deeming clause for an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours 'within the last five years, as indicated on the application'; (D)(i) attestation 'from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104'; (D)(ii) attestor need not specialize in the same category; (D)(iii) attestor 'shall only attest to the completion of the transition to practice'; (D)(iv) attestor immunity 'unless the attestation was produced fraudulently.'.

Two board-level details the statute does not carry: the attestor cannot have a familial or financial relationship with the applicant — the board's page writes "familiar" — and attests under penalty of perjury 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: qualifying transition-to-practice experience must be 'Completed in California,' 'Completed within five years prior to the date the applicant applies for certification as a 103 NP,' 'Completed after certification by the Board of Registered Nursing as a NP' and 'Completed in direct patient care'; a DO may attest; a 103 NP or 104 NP may attest; 'The attestor cannot have a familiar or financial relationship with the applicant and will be attesting to the applicant's completion of the transition to practice requirement under penalty of perjury'; BreEZe emails each identified attestor, who may approve, disapprove or partially approve the claimed hours.. Mechanically, BreEZe emails each attestor you identify by license number; they open a portal and approve, disapprove, or partially approve the hours you claimed 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: qualifying transition-to-practice experience must be 'Completed in California,' 'Completed within five years prior to the date the applicant applies for certification as a 103 NP,' 'Completed after certification by the Board of Registered Nursing as a NP' and 'Completed in direct patient care'; a DO may attest; a 103 NP or 104 NP may attest; 'The attestor cannot have a familiar or financial relationship with the applicant and will be attesting to the applicant's completion of the transition to practice requirement under penalty of perjury'; BreEZe emails each identified attestor, who may approve, disapprove or partially approve the claimed hours.. The filing sequence is in how to apply for 103 NP certification.

Why Doesn't Experience From Another State Count?

Because the statute places the requirement geographically. The words "in California" sit inside BPC §2837.103(a)(1)(D) itself 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(1)(D): 'Has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours,' plus the deeming clause for an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours 'within the last five years, as indicated on the application'; (D)(i) attestation 'from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104'; (D)(ii) attestor need not specialize in the same category; (D)(iii) attestor 'shall only attest to the completion of the transition to practice'; (D)(iv) attestor immunity 'unless the attestation was produced fraudulently.', and the BRN's criteria repeat it 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: qualifying transition-to-practice experience must be 'Completed in California,' 'Completed within five years prior to the date the applicant applies for certification as a 103 NP,' 'Completed after certification by the Board of Registered Nursing as a NP' and 'Completed in direct patient care'; a DO may attest; a 103 NP or 104 NP may attest; 'The attestor cannot have a familiar or financial relationship with the applicant and will be attesting to the applicant's completion of the transition to practice requirement under penalty of perjury'; BreEZe emails each identified attestor, who may approve, disapprove or partially approve the claimed hours..

The Legislature's own 2026 sunset-review background paper describes the consequence bluntly: under current law "a TTP completed in another state or decades of experience do not count," and "there are many NPs who are authorized to practice independently outside of California who have met TTP guidelines in other states but are not permitted to count that experience towards certification as a 103 or 104 NP in California" 4Ref 4California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate BP&ED 2026 BRN sunset-review background paper, Issue #7 (Transition to Practice): 'Notably, the law limits these individuals to having to complete the TTP in California'; 'pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation 'The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs'; an earlier version of SB 1451 would have struck the California limitation and 'the language was subsequently amended'; comparative data attributed to The Nurse Practitioner — 27 states allow independent practice, 11 grant full practice authority with a TTP, California is one of 10 restricted-practice states with a TTP, 16 states grant full practice authority without a TTP, four of the 21 TTP states require more hours than California, Arkansas highest at 6,240 hours, and California, West Virginia and Virginia require three years or 4,600 hours (Virginia three years or 5,400 hours)..

If that is your situation, the planning math is on the out-of-state NP page. It is not a filing problem; it is a calendar problem.

Is the California-Only Rule About to Change?

It has been formally questioned — and that is all, so far. Issue #7 of the Senate Business, Professions and Economic Development Committee's 2026 background paper for the BRN sunset review asks whether NPs licensed outside California who have practiced independently longer than three years should still have to complete the transition to practice here. Its staff recommendation reads: "The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs" 4Ref 4California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate BP&ED 2026 BRN sunset-review background paper, Issue #7 (Transition to Practice): 'Notably, the law limits these individuals to having to complete the TTP in California'; 'pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation 'The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs'; an earlier version of SB 1451 would have struck the California limitation and 'the language was subsequently amended'; comparative data attributed to The Nurse Practitioner — 27 states allow independent practice, 11 grant full practice authority with a TTP, California is one of 10 restricted-practice states with a TTP, 16 states grant full practice authority without a TTP, four of the 21 TTP states require more hours than California, Arkansas highest at 6,240 hours, and California, West Virginia and Virginia require three years or 4,600 hours (Virginia three years or 5,400 hours)..

Read that with care. It is a staff recommendation inside a background paper prepared for an oversight hearing — not a bill, not a chaptered statute, and not in effect. There is no operative date, no bill number attached to the change, and no assurance it will be enacted at all. Until a bill passes and is signed, BPC §2837.103(a)(1)(D) still says "in California" 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(1)(D): 'Has completed a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours,' plus the deeming clause for an NP practicing in direct patient care for three full-time equivalent years or 4,600 hours 'within the last five years, as indicated on the application'; (D)(i) attestation 'from either a licensed physician and surgeon, a certified nurse practitioner practicing pursuant to this section, or a certified nurse practitioner practicing pursuant to Section 2837.104'; (D)(ii) attestor need not specialize in the same category; (D)(iii) attestor 'shall only attest to the completion of the transition to practice'; (D)(iv) attestor immunity 'unless the attestation was produced fraudulently.'.

There is precedent for it not landing. The same background paper records that an earlier version of SB 1451 contained language striking the California-only limitation, and that "the language was subsequently amended so pursuant to current law, a TTP completed in another state or decades of experience do not count" 4Ref 4California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate BP&ED 2026 BRN sunset-review background paper, Issue #7 (Transition to Practice): 'Notably, the law limits these individuals to having to complete the TTP in California'; 'pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation 'The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs'; an earlier version of SB 1451 would have struck the California limitation and 'the language was subsequently amended'; comparative data attributed to The Nurse Practitioner — 27 states allow independent practice, 11 grant full practice authority with a TTP, California is one of 10 restricted-practice states with a TTP, 16 states grant full practice authority without a TTP, four of the 21 TTP states require more hours than California, Arkansas highest at 6,240 hours, and California, West Virginia and Virginia require three years or 4,600 hours (Virginia three years or 5,400 hours).. A prior attempt at this exact change was removed before enactment. Plan against current law; treat any change as upside.

How Does California's Requirement Compare With Other States?

California is in the stricter half, but not at the extreme. Drawing on data the Senate background paper attributes to The Nurse Practitioner, 27 states allow NPs to practice independent of physician supervision; 11 grant full practice authority but require a transition to practice; and 16 grant full practice authority with no transition-to-practice requirement at all 4Ref 4California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate BP&ED 2026 BRN sunset-review background paper, Issue #7 (Transition to Practice): 'Notably, the law limits these individuals to having to complete the TTP in California'; 'pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation 'The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs'; an earlier version of SB 1451 would have struck the California limitation and 'the language was subsequently amended'; comparative data attributed to The Nurse Practitioner — 27 states allow independent practice, 11 grant full practice authority with a TTP, California is one of 10 restricted-practice states with a TTP, 16 states grant full practice authority without a TTP, four of the 21 TTP states require more hours than California, Arkansas highest at 6,240 hours, and California, West Virginia and Virginia require three years or 4,600 hours (Virginia three years or 5,400 hours)..

California sits among 10 states described as granting restricted practice for independently practicing NPs with a transition-to-practice requirement 4Ref 4California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate BP&ED 2026 BRN sunset-review background paper, Issue #7 (Transition to Practice): 'Notably, the law limits these individuals to having to complete the TTP in California'; 'pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation 'The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs'; an earlier version of SB 1451 would have struck the California limitation and 'the language was subsequently amended'; comparative data attributed to The Nurse Practitioner — 27 states allow independent practice, 11 grant full practice authority with a TTP, California is one of 10 restricted-practice states with a TTP, 16 states grant full practice authority without a TTP, four of the 21 TTP states require more hours than California, Arkansas highest at 6,240 hours, and California, West Virginia and Virginia require three years or 4,600 hours (Virginia three years or 5,400 hours).. Of the 21 states that require one, four require more hours than California; Arkansas is the highest at 6,240 hours of post-licensure practice. California, West Virginia and Virginia each require three years or 4,600 hours, with Virginia's alternative set at 5,400 hours 4Ref 4California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate BP&ED 2026 BRN sunset-review background paper, Issue #7 (Transition to Practice): 'Notably, the law limits these individuals to having to complete the TTP in California'; 'pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation 'The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs'; an earlier version of SB 1451 would have struck the California limitation and 'the language was subsequently amended'; comparative data attributed to The Nurse Practitioner — 27 states allow independent practice, 11 grant full practice authority with a TTP, California is one of 10 restricted-practice states with a TTP, 16 states grant full practice authority without a TTP, four of the 21 TTP states require more hours than California, Arkansas highest at 6,240 hours, and California, West Virginia and Virginia require three years or 4,600 hours (Virginia three years or 5,400 hours)..

What makes California distinctive is less the size of the requirement than its location clause — the requirement that the hours be earned inside the state, which is precisely what the sunset review has flagged for possible deletion 4Ref 4California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate BP&ED 2026 BRN sunset-review background paper, Issue #7 (Transition to Practice): 'Notably, the law limits these individuals to having to complete the TTP in California'; 'pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation 'The Committees may wish to delete the requirement that the TTP be completed in California in order to facilitate additional practice opportunities for qualified NPs'; an earlier version of SB 1451 would have struck the California limitation and 'the language was subsequently amended'; comparative data attributed to The Nurse Practitioner — 27 states allow independent practice, 11 grant full practice authority with a TTP, California is one of 10 restricted-practice states with a TTP, 16 states grant full practice authority without a TTP, four of the 21 TTP states require more hours than California, Arkansas highest at 6,240 hours, and California, West Virginia and Virginia require three years or 4,600 hours (Virginia three years or 5,400 hours)..