Guide

The Six Functions a 103 NP May Perform Without Standardized Procedures

Summary

Business and Professions Code §2837.103(c) lists exactly six functions a certified 103 NP may perform without standardized procedures, in accordance with their education and training: conduct an advanced assessment; order, perform and interpret diagnostic procedures; establish primary and differential diagnoses; prescribe, order, administer, dispense, procure and furnish therapeutic measures; certify disability after a physical examination; and delegate tasks to a medical assistant.

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

Which Six Functions Does §2837.103(c) Actually List?

Six, and the framing sentence matters as much as the list. BPC §2837.103(c) reads: "In addition to any other practices authorized by law, a nurse practitioner who meets the requirements of paragraph (1) of subdivision (a) may perform the following functions without standardized procedures in accordance with their education and training" 1.

Three consequences follow. The list is additive — it does not displace anything a nurse practitioner could already do under standardized procedures. It is conditioned on individual education and training, so it is a ceiling, not a floor. And it attaches to the person who meets §2837.103(a)(1), which means the eligibility work described in what a 103 NP is has to be complete first.

The same six functions are what a 104 NP performs outside the six settings (BPC §2837.104(a)(1)) 4. There is no seventh function for the 104.

What Counts as an Advanced Assessment, and Which Diagnostics Can You Order?

Function 1 — conduct an advanced assessment. The statute states it and does not define it further, leaving the boundary to your education, training and national certification 1.

Function 2 — order, perform, and interpret diagnostic procedures, with two carve-outs written into the paragraph itself 1. For radiologic procedures, the text is narrower than the headline: "a nurse practitioner can order diagnostic procedures and utilize the findings or results in treating the patient" — order and use, rather than perform and interpret. For laboratory work, an NP "may perform or interpret clinical laboratory procedures that they are permitted to perform under Section 1206 and under the federal Clinical Laboratory Improvement Act (CLIA)."

So function 2 is really three different permissions depending on the modality, and the radiology and laboratory sentences are the ones worth quoting accurately in any policy document you write for your own practice.

Can a 103 NP Establish a Diagnosis on Their Own?

Function 3 — establish primary and differential diagnoses 1. Under this certificate that act no longer runs through a standardized procedure co-signed with a supervising physician; it runs on your own certification, education and training.

The counterweight sits two subdivisions later. BPC §2837.103(g) requires that a nurse practitioner "shall refer a patient to a physician and surgeon or other licensed health care provider if a situation or condition of a patient is beyond the scope of the education and training of the nurse practitioner" 1. Diagnostic autonomy and a referral duty are issued together, in the same section, and the referral duty has no setting condition attached to it.

For 104 NPs that referral duty is elaborated into a written plan with five specific criteria — see what replaces standardized procedures.

What Therapeutic Measures Can a 103 NP Prescribe or Furnish?

Function 4 is the largest of the six: "prescribe, order, administer, dispense, procure, and furnish therapeutic measures," broken into three subparagraphs 1.

  • (A) Diagnose, prescribe, and institute therapy or referrals of patients to health care agencies, health care providers, and community resources.
  • (B) Prescribe, administer, dispense, and furnish pharmacological agents, "including over-the-counter, legend, and controlled substances."
  • (C) Plan and initiate a therapeutic regimen including nonpharmacological interventions — durable medical equipment, medical devices, nutrition, blood and blood products, and diagnostic and supportive services including home health care, hospice, and physical and occupational therapy.

One caveat is easy to miss and expensive to discover late: the certificate does not carry furnishing authority by itself. The BRN states that the 103 NP certification "does not automatically provide furnishing authority," and an NP without a furnishing number who wants to furnish without standardized procedures must apply for one separately 2. Schedule II furnishing additionally requires the pharmacology content covering risks of addiction in a nurse practitioner program plus registration with the federal Drug Enforcement Administration 3.

How Do Disability Certification and Medical-Assistant Delegation Work?

Function 5 — certify disability, but only "after performing a physical examination," and specifically under Section 2708 of the Unemployment Insurance Code 1. The physical-examination precondition is written into the paragraph; a records-only certification is not what the statute authorizes.

Function 6 — delegate tasks to a medical assistant, "pursuant to Sections 1206.5, 2069, 2070, and 2071, and Article 2 (commencing with Section 1366) of Chapter 3 of Division 13 of Title 16 of the California Code of Regulations" 1. This is a delegation function, not an expansion of what a medical assistant may lawfully do — the referenced statutes and regulations still govern the task list, and they are the documents to read before you write an MA scope policy.

Both functions are frequently omitted from summary charts, which tend to stop after prescribing. They are in the statute on equal footing with the other four.

What Do These Six Functions Not Include?

They do not include a change of venue. The six functions are exercisable without standardized procedures only inside the six settings at BPC §2837.103(a)(2), each requiring that one or more physicians and surgeons practice with the nurse practitioner there 1. Moving them outside those settings is exactly what the 104 certificate does 4, and the fork is laid out at 103 vs. 104.

They also do not override your employer. The BRN states plainly that "an employer can still require a 103 NP to practice under standardized procedures," and that the ability to work under standardized procedures remains whether or not a licensee is a 103 or 104 NP 2. Nor do they survive a lapse in national certification: if it expires, the BRN says the NP must immediately begin practicing under standardized procedures until it is regained 2.

And they sit alongside a protection running the other way. The entity you work for "shall not interfere with, control, or otherwise direct the professional judgment" of a nurse practitioner functioning under this section in a manner prohibited by BPC §2400 or any other law (BPC §2837.103(b)) 1.

Common questions

The statute is narrower than for other diagnostics. BPC §2837.103(c)(2)(B) states that for radiologic procedures a nurse practitioner can order diagnostic procedures and utilize the findings or results in treating the patient. Performing and interpreting is expressed for diagnostic procedures generally, with laboratory work separately bounded by BPC §1206 and CLIA.

Only with the separate furnishing credential. BPC §2837.103(c)(4)(B) includes controlled substances among the pharmacological agents within the function, but the BRN states 103 certification does not automatically provide furnishing authority. Schedule II furnishing additionally requires the required pharmacology content and registration with the federal Drug Enforcement Administration.

Yes, within the statutory condition. BPC §2837.103(c)(5) authorizes a nurse practitioner to certify disability pursuant to Section 2708 of the Unemployment Insurance Code, but only after performing a physical examination. The physical-examination precondition is written into the paragraph itself and is not optional.

No. Function six authorizes a 103 NP to delegate tasks to a medical assistant pursuant to BPC sections 1206.5, 2069, 2070 and 2071 and Article 2 of the medical assistant regulations in Title 16. Those provisions continue to define which tasks may be delegated; the function changes who may delegate, not what.

Yes, identically. BPC §2837.104(a)(1) authorizes a certified 104 NP to perform the functions specified in BPC §2837.103(c) outside the six listed settings. There is no separate or wider function list for 104 NPs; the difference between the certificates is where the functions may be exercised.

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References

  1. 1.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(c): 'In addition to any other practices authorized by law, a nurse practitioner who meets the requirements of paragraph (1) of subdivision (a) may perform the following functions without standardized procedures in accordance with their education and training' — (1) conduct an advanced assessment; (2)(A) order, perform, and interpret diagnostic procedures, (2)(B) 'For radiologic procedures, a nurse practitioner can order diagnostic procedures and utilize the findings or results in treating the patient' and may perform or interpret clinical laboratory procedures permitted under Section 1206 and CLIA; (3) establish primary and differential diagnoses; (4)(A)–(C) prescribe, order, administer, dispense, procure and furnish therapeutic measures including over-the-counter, legend and controlled substances and nonpharmacological interventions; (5) 'After performing a physical examination, certify disability pursuant to Section 2708 of the Unemployment Insurance Code'; (6) delegate tasks to a medical assistant pursuant to Sections 1206.5, 2069, 2070 and 2071 and 16 CCR Article 2 (commencing with Section 1366). Also §2837.103(a)(2) settings, §2837.103(b) non-interference with professional judgment per BPC §2400, and §2837.103(g) the referral duty.
  2. 2.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). link ✓BRN AB 890 FAQ: 'the 103 NP certification does not automatically provide furnishing authority' and an NP without a furnishing licence who wishes to furnish without standardized procedures must apply for one; 'an employer can still require a 103 NP to practice under standardized procedures'; 'the ability to work under standardized procedures remains whether or not the licensee is a 103 or 104 NP'; if national board certification expires 'the NP must immediately begin practicing under standardized procedures.'
  3. 3.California Board of Registered Nursing (2026). Nurse Practitioner — practice information, furnishing numbers and Schedule II requirements. California Board of Registered Nursing (rn.ca.gov). link ✓BRN Nurse Practitioner practice page: the BRN issues a furnishing number allowing an NP to order or furnish drugs and devices; 'In order to furnish Schedule II controlled substances, NPs must complete the required pharmacological content, including risks of addiction associated with their use in a nurse practitioner program and shall register with the United States Drug Enforcement Administration (DEA).'
  4. 4.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(a)(1): a certified 104 NP 'may perform the functions specified in subdivision (c) of Section 2837.103 pursuant to that subdivision outside of the settings or organizations specified under subparagraphs (A) to (F), inclusive, of paragraph (2) of subdivision (a) of Section 2837.103.'

https://www.gale.care/for-providers/six-things-103-nps-can-do-without-standardized-procedures · 4 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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