Guide

SB 1451 and California NPs: What Changed, and What Older Guides Still Get Wrong

Summary

SB 1451 (Ashby, Chapter 481, Statutes of 2024) amended AB 890's nurse practitioner article effective January 1, 2025. It barred the board from requiring nurse practitioners to tell patients they have a right to see a physician and surgeon, and deleted AB 890's mandated Spanish phrase. It kept the duty to inform new patients that a nurse practitioner is not a physician and surgeon, kept the posted board notice, and left the California-only hours rule in place.

By Gale · Updated 2026-07-31. Every figure cited to a dated source. How we write.

What Is SB 1451 and When Did It Take Effect?

SB 1451 (Ashby) is Chapter 481, Statutes of 2024. It amended the Advanced Practice Registered Nurses article created by AB 890 — including BPC §§2837.101, 2837.103, 2837.104 and 2837.105 — effective January 1, 2025 23.

That matters for anyone reading older material. Most published explanations of the 103 and 104 pathways were written between 2021 and 2024, against the AB 890 text 4; several duties they describe were renumbered, narrowed or reversed a year later. Where an older guide and the current code conflict, the code governs — and both sections now close with the credit line "Amended by Stats. 2024, Ch. 481… (SB 1451) Effective January 1, 2025" 23. The certificates themselves are described at what a 103 NP is and what a 104 NP is.

Which Patient Disclosure Rules Did SB 1451 Actually Change?

This is the most frequently garbled point in the published guidance. Comparing AB 890 as chaptered in 2020 4 with the sections as they read today 23 gives three findings, not one:

DutyAB 890 (2020)Today, after SB 1451
Tell new patients an NP is not a physician and surgeonRequired — "shall verbally inform," plus the mandated Spanish phrase "enfermera especializada"Still required — "shall inform all new patients in a language understandable to the patient" (§2837.103(d), §2837.104(d)). The word "verbally" and the mandated phrase are gone
Tell patients they have a right to see a physician and surgeonNo such provision in the statuteBoard may not require it — a new subdivision (§2837.103(e), §2837.104(e))
Post a conspicuous notice that you are regulated by the BRNRequired (§2837.103(e), §2837.104(e))Still required, renumbered to §2837.103(f) and §2837.104(f), with a "not working under standardized procedures" qualifier

So the honest summary is: one disclosure was foreclosed, one piece of mandated wording was deleted, and two duties survived. The Legislative Counsel's Digest matches — the bill "would prohibit the board from requiring a nurse practitioner… to tell a patient that the patient has a right to see a physician and surgeon, and would delete a provision requiring the nurse practitioner to use a certain phrase to inform Spanish language speakers that the nurse practitioner is not a physician and surgeon" 1.

Note the verb in the second row: prohibit the board from requiring. AB 890 never imposed a right-to-see-a-physician duty in statute 4; SB 1451 closed the door on the board imposing one. So "SB 1451 removed the patient-disclosure obligation" — a line common in secondary commentary — is wrong in a way that could cost you a posted notice.

What Changed About the Transition to Practice?

Three loosenings, aimed at rules the Legislature considered stricter than AB 890 intended 15.

The deeming clause. BPC §2837.103(a)(1)(D) now provides that a nurse practitioner 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" 2.

The single-category restriction, deleted. Clinical experience "shall not be limited to experience in a single category" (BPC §2837.101(c)(1)) 1. The Senate's sunset-review paper describes SB 1451 as having "deleted the requirements for the TTP to be completed in a specified practice area and that the individual attesting… be in the same practice area as well" 5.

A pre-certification exclusion, made explicit. Experience obtained before a person is certified as a nurse practitioner does not count 12.

Current rules in full: the 4,600-hour transition to practice.

How Did the Attestation Rules Change?

They became narrower and safer for the attestor. The Digest states the bill "would require proof of completion of one transition to practice to be provided to the board as an attestation from either a licensed physician and surgeon or a nurse practitioner" 1.

In the enacted text, BPC §2837.103(a)(1)(D)(ii)–(iv) provides that the attestor need not specialize in the applicant's category; "shall only attest to the completion of the transition to practice" and is "not required to verify competence, clinical expertise, or any other standards"; and is shielded from civil, criminal, administrative, disciplinary, employment, credentialing, contractual and medical-staff liability for giving or refusing an attestation "unless the attestation was produced fraudulently" 2.

That changes how you ask. An attestor is not vouching for your competence and is protected either way — a smaller request than it used to look. The mechanics are in how to apply for 103 NP certification.

What Did SB 1451 Deliberately Not Change?

The California-only location rule — and this one nearly went the other way.

The Senate's 2026 sunset-review background paper records that "in an earlier version of SB 1451, language was included to better reflect the reality of competent and qualified NPs in other states becoming licensed in California by striking the limitation on the TTP being only completed in California. The language was subsequently amended so pursuant to current law, a TTP completed in another state or decades of experience do not count" 5.

So the words "in California" survive in BPC §2837.103(a)(1)(D) 2, and out-of-state independent practice still counts for nothing — see the out-of-state NP page.

That paper's Issue #7 now recommends the Committees "may wish to delete the requirement that the TTP be completed in California" 5. It remains a staff recommendation in a sunset-review background paper — not a bill, not law, no operative date, no assurance of enactment. Given near-identical language was already removed from SB 1451 once, track it rather than rely on it.

What Do Older Guides Still Get Wrong?

Seven corrections, in rough order of how often they appear.

1. "SB 1451 removed the patient-disclosure obligation." The most common and most consequential error. You must still inform all new patients that a nurse practitioner is not a physician and surgeon, and still post the BRN notice (BPC §2837.103(d), (f); §2837.104(d), (f)) 23. 2. "You must tell patients they have a right to see a physician." The board may not require that (BPC §2837.103(e); §2837.104(e)) 23. AB 890 never imposed it by statute 4. 3. "A specific Spanish-language phrase is mandated." AB 890 required "enfermera especializada"; SB 1451 deleted it 14. The duty to inform in an understandable language remains 23 — and where the statute now says "inform," the BRN's guidance still says verbally, so follow the board. 4. "Your hours must sit in one category, and your attestor must share your specialty." Both gone (BPC §2837.101(c)(1); §2837.103(a)(1)(D)(ii)–(iii)) 125. 5. "A 104 NP must consult a physician on acute decompensation." SB 1451 deleted that standalone consultation trigger; decompensation, already in AB 890's referral criteria, now sits reworded at §2837.104(c)(4)(B) 34. 6. "The board may charge a fee for the 104 certificate." AB 890 §2837.104(b)(2) authorized one; SB 1451 deleted that paragraph, and no 104 fee provision remains 34. 7. "California fixed the out-of-state experience problem." It did not — proposed in an earlier version of SB 1451 and amended out; deletion exists only as a sunset-review staff recommendation, with no bill and no operative date 5.

One more is stale rather than wrong: "104 status isn't available yet" — true when most of this commentary was written, not now (how to apply). What did not change: the not-a-physician notification, the posted notice, liability insurance, the referral duty, the six functions, the six settings, and the three-years-as-a-103 ladder 23.

Common questions

No. BPC §2837.103(e) states a nurse practitioner shall not be required to tell a patient the patient has a right to see a physician and surgeon, and §2837.104(e) carries the parallel provision. SB 1451 added those subdivisions effective January 1, 2025. The separate duty to say you are not a physician and surgeon is unaffected and still applies.

Yes. Both BPC §2837.103(d) and §2837.104(d) require informing all new patients, in a language understandable to the patient, that a nurse practitioner is not a physician and surgeon. What SB 1451 deleted was the separately mandated Spanish-language phrase, not the underlying duty to inform.

No. The requirement remains a minimum of three full-time-equivalent years of practice or 4,600 hours. SB 1451 added a deeming clause for NPs who have practiced in direct patient care at that level within the last five years, and removed the requirement that the hours sit within a single practice category.

Yes. BPC §2837.103(a)(1)(D)(i) allows the attestation to come from a licensed physician and surgeon, a certified nurse practitioner practicing under §2837.103, or one practicing under §2837.104. The BRN confirms that a Doctor of Osteopathy, a 103 NP or a 104 NP may attest.

No. An earlier version of the bill contained language striking the California-only limitation on the transition to practice, and that language was amended out before enactment. Under current law a transition to practice completed in another state does not count toward 103 or 104 certification.

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References

  1. 1.Senator Angelique Ashby (California State Legislature) (2024). Senate Bill 1451 — Healing arts (Chapter 481, Statutes of 2024), chaptered bill text and Legislative Counsel's Digest. California Legislative Information (leginfo.legislature.ca.gov). link ✓SB 1451 (Ashby, Chapter 481, Statutes of 2024), Legislative Counsel's Digest: the bill 'would deem a nurse practitioner who has been practicing as a nurse practitioner in direct patient care for 3 full-time equivalent years or 4,600 hours within the last 5 years, as indicated on the application, to have satisfied this requirement'; 'would require proof of completion of one transition to practice to be provided to the board as an attestation from either a licensed physician and surgeon or a nurse practitioner'; 'would prohibit the board from requiring a nurse practitioner practicing under those provisions to tell a patient that the patient has a right to see a physician and surgeon, and would delete a provision requiring the nurse practitioner to use a certain phrase to inform Spanish language speakers that the nurse practitioner is not a physician and surgeon'; and would specify that clinical experience 'shall not be limited to experience in a single category' and prohibit pre-certification experience from counting.
  2. 2.California 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). California Legislative Information (leginfo.legislature.ca.gov). link ✓BPC §2837.103 as amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025: (a)(1)(D) retains 'a transition to practice in California of a minimum of three full-time equivalent years of practice or 4600 hours' and adds the five-year deeming clause; (a)(1)(D)(i)–(iv) the attestation source, the no-same-category rule, 'shall only attest to the completion of the transition to practice,' and attestor immunity 'unless the attestation was produced fraudulently'; (d) the new-patient not-a-physician notification; (e) 'A nurse practitioner shall not be required to tell a patient the patient has a right to see a physician and surgeon'; (f) the posted BRN notice; (g) the referral duty; (h) professional liability insurance.
  3. 3.California State Legislature (2024). Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025). California Legislative Information (leginfo.legislature.ca.gov). link ✓BPC §2837.104 as amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025: (b)(3) three years in good standing 'not inclusive of the transition to practice'; (d) the new-patient not-a-physician notification; (e) a 104 NP 'shall not be required by the board to tell a patient that the patient has a right to see a physician and surgeon'; (f) the posted BRN notice; (g) professional liability insurance.
  4. 4.Assembly Member Jim Wood (California State Legislature) (2020). Assembly Bill 890 — Nurse practitioners: scope of practice: practice without standardized procedures (Chapter 265, Statutes of 2020), chaptered bill text. California Legislative Information (leginfo.legislature.ca.gov). link ✓AB 890 (Wood, Chapter 265, Statutes of 2020), chaptered text — the pre-SB 1451 baseline. Original BPC §2837.103(d): 'A nurse practitioner shall verbally inform all new patients in a language understandable to the patient that a nurse practitioner is not a physician and surgeon. For purposes of Spanish language speakers, the nurse practitioner shall use the standardized phrase “enfermera especializada.”' Original §2837.103(e) carried the conspicuous Board of Registered Nursing posting duty (renumbered to (f) by SB 1451, not repealed); original (f) the referral duty, (g) liability insurance, (h) the CDCR exemption. Original §2837.104(d) and (e) were identically structured. AB 890 contained NO provision requiring a nurse practitioner to tell a patient they have a right to see a physician and surgeon. Original §2837.104(b)(2): 'The board may charge a fee in an amount sufficient to cover the reasonable regulatory cost of issuing the certificate' — a paragraph absent from the section as it reads today. Original §2837.104(c)(2) listed five physician-consultation circumstances including '(B) Acute decompensation of patient situation,' and the referral plan sat at (c)(3) with criteria that ALREADY covered decompensation — '(C) Any patient with acute decomposition or rare condition' — so SB 1451 deleted the standalone trigger rather than moving it; there was no provision corresponding to the current (c)(3) on physician-patient relationship and sole responsibility.
  5. 5.California 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). California State Senate (sbp.senate.ca.gov). link ✓Senate BP&ED 2026 BRN sunset-review background paper, Issue #7: 'In recognition that some of the BRN's TTP regulations did not align with the original intent of AB 890 and were more stringent than the original legislation, SB 1451 (Ashby, Chapter 481, Statutes of 2024) deleted the requirements for the TTP to be completed in a specified practice area and that the individual attesting to the NPs completion of the TTP be in the same practice area as well'; 'In an earlier version of SB 1451, language was included… by striking the limitation on the TTP being only completed in California. The language was subsequently amended so pursuant to current law, a TTP completed in another state or decades of experience do not count'; staff recommendation that 'The Committees may wish to delete the requirement that the TTP be completed in California.'

https://www.gale.care/for-providers/sb-1451-what-changed-for-california-nps · 5 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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