PMHNP Practice Requirements in California: Scope, Prescribing & Collaboration

Practice Authority

What is California NP practice authority?

California historically required NPs to practice under standardized procedures developed with a physician. Assembly Bill 890 (AB 890) created a phased path toward greater independence through two new categories commonly referred to as the “103” NP and the “104” NP. Later legislation has continued to adjust the details, so the current rules are best confirmed directly with the California Board of Registered Nursing.

In broad terms: a 103 NP may practice without standardized procedures but generally within a defined organization or group setting where a physician also practices, after completing a substantial transition-to-practice experience. A 104 NP, after further qualifying experience, may practice more independently outside those group settings, within the population focus of their national certification. Because PMHNPs are certified in psychiatric-mental health, your authorized scope tracks that population focus, and the specific hour thresholds and conditions should be verified rather than assumed.

Collaboration & Agreements

Is a physician agreement required in California?

It depends on your category. An NP practicing under the traditional model works under standardized procedures developed in collaboration with a physician or organization. A 103 NP may practice without those standardized procedures but is generally tied to a setting where a physician also practices. A 104 NP may practice more independently. Because AB 890 is being implemented in phases and the criteria have been refined by follow-on legislation, the practical answer for your situation, including any transition-to-practice, documentation, or patient-disclosure requirements, should be confirmed with the California Board of Registered Nursing.

Prescribing

Prescriptive authority and controlled substances

California NPs may furnish or order drugs and devices consistent with their category and scope, and controlled-substance prescribing additionally requires federal DEA registration. The exact conditions differ between the standardized-procedure model and the 103 and 104 categories, and for PMHNPs the handling of controlled substances common in psychiatric care is a detail to verify, not to infer. Furnishing numbers, transition-to-practice hour totals, and category-specific conditions all change as implementation proceeds.

For that reason we do not publish specific hour counts or furnishing rules here; confirm them with the California Board of Registered Nursing and the DEA. If a claim about your prescribing authority cannot be confirmed there, treat it as unverified.

Billing & Credentialing

What this means for your billing and credentialing

Your AB 890 category is not just a clinical label; it changes how you present to payers. Whether you are practicing under standardized procedures, as a 103 NP tied to a group setting, or as a 104 NP, your credentialing file, CAQH profile, and enrollment applications should reflect the correct category, your DEA registration, and any required physician or organizational relationship. Because California is mid-transition, keeping this current matters: an outdated category on file can delay effective dates or trigger denials.

Advance a Practice helps California PMHNPs align operations to their pathway: PMHNP credentialing and payer enrollment, practical guidance on how to start a PMHNP practice, and a comparative look at PMHNP scope of practice by state. See our full PMHNP services for the complete picture.

FAQ

California PMHNP: frequently asked questions