Guide

What Is a 103 NP in California? The Certificate, Read Plainly

Summary

A 103 NP is a California nurse practitioner certified under Business and Professions Code §2837.103 to perform six enumerated functions without standardized procedures — but only inside six settings where at least one physician and surgeon also practices with the NP. Eligibility requires national board certification, board-consistent education with clinical hours, and a transition to practice of three full-time-equivalent years or 4,600 hours completed in California.

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

What Does the 103 Certificate Actually Authorize?

It authorizes six clinical functions — advanced assessment, ordering and interpreting diagnostics, establishing primary and differential diagnoses, prescribing and furnishing therapeutic measures, certifying disability, and delegating to medical assistants — without standardized procedures, meaning without the written physician-agreed protocols that otherwise define California nurse practitioner practice (BPC §2837.103(c)) 1. Each is walked through in the six functions of a 103 NP.

The honest framing: this is not full practice authority. The BRN's 2026 sunset report describes the 103 as "marking an initial step toward independent practice" 5, and its FAQ notes the categories "do not significantly extend or alter the current NPs scope of practice" 3. What you shed is the standardized-procedure apparatus. What you do not gain is the freedom to practice anywhere.

Who Is Eligible for a 103 NP Certificate?

BPC §2837.103(a)(1) sets four requirements 1:

  • (A) Passed a national nurse practitioner board certification examination, plus any supplemental examination developed under §2837.105(a)(4).
  • (B) Holds certification from a national certifying body accredited by the National Commission for Certifying Agencies or the American Board of Nursing Specialties and recognized by the board.
  • (C) Documented educational training consistent with board standards under §2836 as those relate to clinical practice hours. The statute is explicit: "Online educational programs that do not include mandatory clinical hours shall not meet this requirement."
  • (D) Completed a transition to practice in California of a minimum of three full-time-equivalent years of practice or 4,600 hours.

Two BRN operational notes the statute does not carry. Legacy or retired national certifications do not qualify, and you file one 103 application per national certification for which you have completed a transition to practice 4. Before starting, the board asks you to verify that your national certification is currently recognized as a population focus under 16 CCR 1481(a) 4. The hours rule has its own page: the 4,600-hour transition to practice.

Where Can a 103 NP Practice Without Standardized Procedures?

In exactly six kinds of place, and only where "one or more physicians and surgeons practice with the nurse practitioner without standardized procedures" (BPC §2837.103(a)(2)) 1: a clinic as defined in Health and Safety Code §1200; a health facility under H&S Code §1250, excluding a correctional treatment center and a state hospital; a facility under H&S Code Chapter 2.5 (commencing with §1440); a medical group practice — including a professional medical corporation under BPC §2406, another physician-controlled corporation, a medical partnership, a licensure-exempt medical foundation, or another lawfully organized physician group; a home health agency under H&S Code §1727; and a licensed hospice facility under H&S Code Chapter 8.5.

The physician condition is structural, not nominal. If the physician leaves your clinic, the basis for practicing there without standardized procedures leaves with them. Health care settings operated by the Department of Corrections and Rehabilitation are exempt from the section entirely (BPC §2837.103(i)) 1.

The list also excludes a nursing corporation, which is why an NP who owns their own entity cannot rely on the 103 for that work 3. That gap is the reason the 104 certificate exists.

What Rights Does a 103 NP Get Inside a Facility?

In health care agencies with governing bodies as defined in Division 5 of Title 22 of the California Code of Regulations, a 103 NP must adhere to all applicable bylaws, is eligible to serve on medical staff and hospital committees, and is eligible to attend meetings of their assigned department (BPC §2837.103(a)(3)) 1.

Voting is the narrower right. A 103 NP "shall not vote at department, division, or other meetings" unless the vote concerns the determination of nurse practitioner privileges with the organization, peer review of nurse practitioner clinical practice, whether a licensee's employment is in the best interest of the communities served by a hospital under BPC §2401, or the vote is otherwise allowed by the applicable bylaws 1. Broader department voting is a 104 attribute (BPC §2837.104(a)(3)) 2.

Separately, the entity you work for "shall not interfere with, control, or otherwise direct the professional judgment" of a 103 NP in a manner prohibited by BPC §2400 or any other law (BPC §2837.103(b)) 1.

What Obligations Come With the Certificate?

Four, and they are ongoing rather than one-time. Inform all new patients, in a language understandable to the patient, that a nurse practitioner is not a physician and surgeon (BPC §2837.103(d)) 1 — the BRN reads this as a verbal notification 3. Post a conspicuous public notice naming the Board of Registered Nursing with its telephone number and website, in at least 48-point Arial per the board (BPC §2837.103(f)) 13. Refer any patient whose situation or condition is beyond the scope of your education and training to a physician and surgeon or other licensed provider (BPC §2837.103(g)) 1. And carry professional liability insurance appropriate for the practice setting (BPC §2837.103(h)) 1.

Do not confuse that first duty with a different one that the board may no longer impose. BPC §2837.103(e) now provides that a nurse practitioner "shall not be required to tell a patient the patient has a right to see a physician and surgeon" 1. Those are two separate disclosures: telling patients you are not a physician is still required; telling them they may see one instead cannot be required of you. What SB 1451 also deleted was the mandated Spanish standardized phrase that AB 890 had written into subdivision (d) — not the duty to inform in an understandable language 1. Explainers written before 2025 routinely blur these — see what SB 1451 changed.

If your national board certification expires, the BRN says you must immediately return to practicing under standardized procedures until it is regained 3. An employer may also require standardized procedures regardless of your certificate 3.

How Common Is the 103 Certificate Today?

Uncommon. The BRN's 2026 sunset report records 843 certifications issued in FY 2022/23, 1,030 in FY 2023/24 and 849 in FY 2024/25 — 2,722 across the three reported years, against applications received of 2,896, 1,837 and 1,935 respectively, with 366 pending at the close of FY 2024/25 5. The category itself is young: the report's own footnote records that the "NP 103 License [was] not created until January 2023" 5. How that compares with California's whole nurse practitioner population is set out on the 103 vs. 104 page.

That scarcity has practical consequences. Employers, credentialing committees and malpractice carriers are still forming their reference points for what a 103 NP is, which is one reason the application step rewards care — see how to apply for 103 NP certification.

Common questions

No. A 103 NP practices without standardized procedures only inside six statutory settings in which at least one physician and surgeon also practices. The BRN's own sunset report calls it an initial step toward independent practice. Practice outside those settings requires the separate 104 certificate under BPC §2837.104.

Only if it included mandatory clinical hours. BPC §2837.103(a)(1)(C) requires documented educational training consistent with board standards as those relate to clinical practice hours, and states directly that online educational programs which do not include mandatory clinical hours shall not meet the requirement.

The certificate remains, but the basis for using it in that location may not. BPC §2837.103(a)(2) conditions practice without standardized procedures on being in a listed setting where one or more physicians and surgeons practice with the nurse practitioner. If no physician practices there, that setting condition is no longer met.

Yes, and the BRN expects it where you hold multiple national certifications. Its 103 application instructions state that you complete a 103 application for each national certification for which you have completed a transition to practice. Legacy or retired national certifications will not qualify for the certificate.

No. The BRN states it chose not to create additional initials or make any title changes associated with certification as a 103 NP or 104 NP. Verification is instead visible through the Department of Consumer Affairs License Search, which displays the 103 or 104 authority alongside registered nurse license status.

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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(a)(1)(A)–(D) sets the four eligibility requirements, including that 'Online educational programs that do not include mandatory clinical hours shall not meet this requirement' and a transition to practice 'in California of a minimum of three full-time equivalent years of practice or 4600 hours'; §2837.103(a)(2) enumerates the six settings; §2837.103(a)(3)(A)–(C) governs bylaws adherence, committee eligibility and the limited voting right; §2837.103(b) bars entity interference with professional judgment in a manner prohibited by BPC §2400; §2837.103(c) lists the six functions; §2837.103(d)–(i) carry the new-patient notification, the removed right-to-see-a-physician duty, the posted notice, the referral duty, liability insurance, and the CDCR exemption.
  2. 2.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) places the §2837.103(c) functions outside the six settings for a certified 104 NP; §2837.104(a)(3) provides that a 104 NP member 'may vote at meetings of the department to which nurse practitioners are assigned,' subject to applicable conflict-of-interest policies of the bylaws.
  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). link ✓BRN AB 890 FAQ: the categories 'do not significantly extend or alter the current NPs scope of practice'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; consumer notification requires a posted notice 'in at least 48-point Arial font' and to 'Verbally inform all new patients in a language understandable to the patient that a nurse practitioner is not a physician and surgeon'; on expiry of national board certification 'the NP must immediately begin practicing under standardized procedures'; 'an employer can still require a 103 NP to practice under standardized procedures'; the Board 'chose not to create additional initials'; 103/104 authority displays through DCA License Search.
  4. 4.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. link ✓BRN 103 NP step-by-step instructions: 'Legacy or Retired National Certifications will not qualify for a (103NP) Nurse Practitioner Practicing Without Standardized Procedures in a Group Setting'; 'You will need to complete the “103NP” application for each national certification that you have completed a transition to practice for'; 'Before proceeding with the application, please verify that your national certification is currently recognized as a population focus (CCR 1481(a)).'
  5. 5.California Board of Registered Nursing (2026). Board of Registered Nursing Sunset Review Report 2026 (Table 7a, Licensing Data by Type: Nurse Practitioner 103). California Board of Registered Nursing (rn.ca.gov). link ✓BRN Sunset Review Report 2026, Table 7a (Licensing Data by Type: Nurse Practitioner 103): applications received/issued of 2,896/843 (FY 2022/23), 1,837/1,030 (FY 2023/24) and 1,935/849 (FY 2024/25), 366 pending at close of FY 2024/25, footnote 'NP 103 License not created until January 2023'; the report describes the 103 category as 'marking an initial step toward independent practice.'

https://www.gale.care/for-providers/what-is-a-103-np-california · 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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