Guide

Do Your Employed NP Years Count Toward Transition-to-Practice Hours?

Summary

Employed nurse practitioner hours generally do count toward a state's transition-to-practice or full-practice-authority threshold. In New York, Florida and California the rules define qualifying hours by the capacity you practiced in, the supervision behind them, where they were worked and when, not by whether a W-2 or a 1099 paid you. What varies by state is the hour count itself, the lookback window, and who has to sign for the hours.

By Gale Editorial · Updated 2026-09-01. Every figure cited to a dated source. How we write.

Do employed nurse practitioner hours count toward full practice authority?

In the three states whose rules are set out below, yes. Their thresholds turn on the capacity you practiced in, the supervision behind the work, the state it happened in and the dates it fell between. Not one of them turns on whether a W-2 or a 1099 paid you. The threshold itself is the state question, and in some states there is none to reach.

The counts are nowhere near each other. New York ends the written practice agreement requirement above 3,600 hours of qualifying practice 1. Florida registers an advanced practice registered nurse (APRN) for autonomous practice at a minimum of 3,000 clinical practice hours inside a five-year window 2. California sets 4,600 hours, or three full-time-equivalent years of clinical practice experience and mentorship 3.

But a threshold only exists where the state has written an end to supervision.

The American Association of Nurse Practitioners sorts states into full, reduced and restricted practice, and its definitions carry the consequence: a reduced-practice state requires a career-long regulated collaborative agreement with another health provider, and a restricted-practice state requires career-long supervision, delegation or team management 4. Career-long means there is no count to finish, so find out which category your state sits in before totalling anything toward full practice authority.

Three states, three different tests

The tests differ in more than their hour counts. Each state picks its own lookback window, its own rule about hours worked elsewhere, and its own signer: New York has the nurse practitioner attest and keep the form on site, Florida asks one question on a registration application, and California collects signatures from the practices the applicant worked for.

New YorkFloridaCalifornia
Thresholdmore than 3,600 qualifying NP hours 1at least 3,000 clinical practice hours 24,600 hours or three full-time-equivalent years 3
Lookbacknone stated on the Department's page 1the 5 years preceding the request 2five years before applying 3
Out-of-state hoursqualify if practiced as an NP under another state's laws 1any state, jurisdiction or territory of the United States 2must be completed in California 3
Who signsthe NP, on Form NP-CR, kept at the practice location 5the applicant, one attestation question 6each provider named, under penalty of perjury 3

One line there is an absence rather than a rule: New York's page states no time bound on the 3,600 hours.

New York: the hours are defined by capacity

New York defines qualifying hours by the capacity the work was done in, and employed practice sits squarely inside it. The experience counts if it was practice as a licensed or certified nurse practitioner in accordance with the laws of New York or another state, or as a nurse practitioner employed by the United States veterans administration, the armed forces or the U.S. Public Health Service 1. Nothing in that list distinguishes W-2 employment from contracting.

Below the threshold, a New York nurse practitioner works under written practice protocols and a written practice agreement with a collaborating physician, unless or until completing more than 3,600 hours of qualifying experience 1. The page states 3,600 as a number to exceed rather than to reach.

Above it, the instrument is Form NP-CR. The nurse practitioner attests to collaborative relationships, keeps the form at the practice location and provides it to the New York State Education Department on request rather than filing it in advance 5. Documentation of employment relationships with a physician practice or a hospital is listed there as acceptable evidence 5, and employed years produce exactly that.

Crossing 3,600 hours does not end physician collaboration in New York. Collaborative relationships replace the written agreement 5.

Florida: supervised hours, a five-year window, two graduate courses

Florida counts employed hours, and counts hours worked in other states, but attaches conditions an independent stretch of a career may not meet. Autonomous practice registration requires at least 3,000 clinical practice hours completed in any state, jurisdiction or territory of the United States within the five years immediately preceding the request, while practicing as an APRN under the supervision of an allopathic or osteopathic physician 2.

That physician had to hold an active, unencumbered license during the supervision 2. The filter is supervision and licensure rather than employment: a supervised employed year clears it on its face, while a stretch practiced without physician supervision does not match what the statute describes. The hours may include clinical instructional hours provided by the applicant 2.

Hours alone do not qualify anyone. The same section requires 3 graduate-level semester hours, or the equivalent, in differential diagnosis and 3 graduate-level semester hours, or the equivalent, in pharmacology, completed within the past 5 years 2. Coursework finished eight years ago sits outside that window even when the hours sit inside it.

On the form itself the requirement is one attestation question, with the applicant referred to the statute for the complete requirements rather than asked to submit a log 6.

California: someone else signs for your hours

California is where the employed-versus-self-employed distinction bites, because the applicant does not certify the hours. The 4,600-hour transition to practice, which the Board of Registered Nursing also expresses as three full-time-equivalent years of clinical practice experience and mentorship, is verified by attestation from the providers the applicant names, under penalty of perjury, that the applicant completed all or a specified portion of those hours 3.

The Board applies four conditions: the hours must be completed in California, within five years before applying, after Board certification as a nurse practitioner, and in direct patient care 3. Hours from a first job in another state fail the first condition no matter how well documented.

The attesting provider also attests to having no familial or financial interest in the applicant 3. The Board's page does not name the case of hours worked in a practice the applicant owns, so treat that as open, and check who could sign for a self-employed stretch before counting it.

The arithmetic assumes a career spread across employers: hours from more than one provider are entered separately, and the total across all providers entered must be equal to or greater than 4,600 hours 7.

Three years in good standing as a 103 NP is also required before a 104 NP certification, and as of the Board's page read on 2026-09-01 the Board states it cannot certify 104 NPs until 2026 3. The 103 packet is named for independent practice in a group setting 7, so practice ownership before full licensure is a separate question from whether the hours count.

How to check your own state, and what to keep

Start at the board's own page for the credential rather than a summary site, and read it along the four axes named at the top: capacity, supervision, geography and window. Then find the instrument the state uses to collect the claim. New York keeps a form on site 5, Florida asks one question on an application 6, California collects signatures from former practices 3.

The instrument a state uses to collect an hours claim describes the evidence it expects.

Keep the log while the hours are being worked. For each position: the employer's name and address, the dates worked, the hours, the setting, the supervising or collaborating physician and whether their license was clear then, and the effective date of your own certification, since California counts only hours worked after it 3.

Ask each employer for a written hours summary before leaving. California's attestation depends on a former practice signing under penalty of perjury 3, and none of the pages cited here addresses one that will not.

The same four axes settle the neighbouring question of whether supervised hours under direct client payment count toward a threshold.

What these documents do not answer

Four things, and a solo nurse practitioner hits each of them early. None of the three states' documents draws a line between W-2 employment, 1099 contracting, locums or part-time schedules: they define qualifying hours by capacity, supervision, geography and date, and say nothing about how the practitioner was paid. That silence is why the answer at the top of this page is yes, and why it is not a guarantee for any individual log.

The other three gaps:

  • California states the requirement as 4,600 hours or three full-time-equivalent years and defines neither a full-time-equivalent year nor an hours-per-year divisor 3, so a part-time career cannot be converted from the page alone.
  • Neither California's direct patient care condition 3 nor Florida's clinical practice hours definition 2 addresses telehealth or asynchronous work.
  • New York's page states no lookback window on the 3,600 hours 1, and an absence of a stated window is not a statement that none exists.

Send those questions to the board in writing before filing anything, and keep the reply with the hour log.

Common questions

In the states described here, yes. Their rules define qualifying hours by the capacity the work was done in, the supervision behind it, the state it happened in and the dates it fell between. None of the three documents distinguishes W-2 employment from contracting or locums work. The distinction that does the filtering is supervision and setting, so read those clauses rather than looking for a rule about employment status.

That depends entirely on the state you are applying in. New York counts practice as a licensed or certified nurse practitioner under the laws of New York or another state. Florida counts hours completed in any state, jurisdiction or territory of the United States within the preceding five years. California requires the hours to have been completed in California.

The signer varies more than the hour count does. In New York the nurse practitioner attests on Form NP-CR and keeps it at the practice location, producing it to the Education Department on request. In Florida the applicant answers a yes-or-no attestation question on the registration form. In California each provider named on the application attests under penalty of perjury, and also attests to having no familial or financial interest in the applicant.

No. It ends the written practice agreement requirement. Above the threshold, collaborative relationships replace that written agreement, and the nurse practitioner attests to them on Form NP-CR, keeps the form at the practice location and keeps its information current. Below the threshold the written agreement still governs, and if the collaborating physician dies, a practitioner at or under 3,600 qualifying hours has to enter a new agreement with another collaborating physician.

The Board's page does not address that case directly, so treat it as open and ask the Board. What the page does say is that hours are verified by attestation from the providers the applicant names, and that the attesting provider attests to having no familial or financial interest in the applicant. Check who could sign for a self-employed stretch under that clause before counting those hours toward the total.

For each position: employer name and address, dates worked, hours, setting, the supervising or collaborating physician and whether their license was clear during the period, and the effective date of your own Board certification as a nurse practitioner. Request a written hours summary from each employer before leaving. California's attestation depends on a former practice signing later, and none of these documents covers an employer who declines.

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References

  1. 1.New York State Education Department, Office of the Professions (2026). Practice Information for Nurse Practitioners. NYSED Office of the Professions (op.nysed.gov). linkNew York's 3,600-hour threshold above which a nurse practitioner practices without a written practice agreement, the definition of qualifying experience by practising capacity (New York or another state's laws, or VA / armed forces / USPHS employment), the absence of any stated lookback window on that page, and the collaborating-physician-death rule for practitioners at or under 3,600 hours.
  2. 2.Florida Legislature (2024). 464.0123 Autonomous practice by an advanced practice registered nurse. The 2024 Florida Statutes, The Florida Senate. linkFlorida's statutory registration criteria for autonomous APRN practice: the 3,000 clinical practice hours, the five-year lookback, the any-state condition, the physician-supervision and unencumbered-license conditions, the inclusion of clinical instructional hours provided by the applicant, and the two graduate-level coursework requirements.
  3. 3.California Board of Registered Nursing (2026). Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions). California Board of Registered Nursing (rn.ca.gov). linkCalifornia's 4,600-hour or three-full-time-equivalent-year transition-to-practice requirement, its four qualifying conditions, the attestation mechanism and the attesting provider's no-familial-or-financial-interest declaration, the three-years-as-a-103-NP prerequisite for 104 NP status, and the Board's stated inability to certify 104 NPs until 2026 as of 2026-09-01.
  4. 4.American Association of Nurse Practitioners (2026). State Practice Environment. American Association of Nurse Practitioners. linkThe full, reduced and restricted practice classification and its definitions, used here only to establish that reduced-practice states require a career-long regulated collaborative agreement and restricted-practice states require career-long supervision, so no hour threshold exists to accumulate toward.
  5. 5.New York State Education Department, Office of the Professions (2017). Nurse Practitioner Form NP-CR, Collaborative Relationships Attestation Form. New York State Education Department, Office of the Professions. linkWhat a New York nurse practitioner attests to after exceeding 3,600 hours, that Form NP-CR is kept at the practice location and produced to the Education Department on request rather than filed, that its information must be kept current, that collaborative relationships replace the written practice agreement without ending physician collaboration, and that documentation of employment relationships is acceptable evidence of those relationships.
  6. 6.Florida Board of Nursing, Florida Department of Health (2020). Autonomous Advanced Practice Registered Nurse Registration (DH-MQA 5050). Florida Board of Nursing. linkThat on Florida's autonomous APRN registration form the 3,000-hour requirement appears as a single yes-or-no attestation question about supervised clinical practice hours in the past five years, with the applicant referred to the statute for the complete requirements rather than asked to file an hour log.
  7. 7.California Board of Registered Nursing (2026). Step by Step Guide for Applying for NP – Independent Practice Group Setting (103 NP). California Board of Registered Nursing (rn.ca.gov), applicant instruction packet. linkThe mechanics of the 103 NP application: that hours from multiple providers are entered and summed, that the overall total across all providers entered must be equal to or greater than 4,600 hours, and the packet's own name for the pathway.

https://www.gale.care/for-providers/pq-transition-hours-do-employed-years-count · 7 sources. Competitor details are cited to dated public sources and maintained as they change; figures are estimates, not commitments. Synthetic demonstration.

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