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Staff report: AB 890 pathway open but few Nurse Practitioners have moved to 103/104 status
Summary
BRN staff reported that while AB 890 and subsequent SB 1451 enabled pathways for nurse practitioners to pursue independent practice, only about 2,700 of roughly 45,540 NPs have obtained 103 status so far; staff cited employer restrictions and an application-update backlog as barriers.
Executive Officer Laurie Melby gave an information‑only briefing on the state’s implementation of AB 890 and follow‑on changes under SB 1451 that affect nurse practitioner pathways to independent practice.
Melby summarized the regulatory history: AB 890 established a pathway to independent NP practice and the BRN developed implementing regulations and the 103/104 application processes. The Office of Professional Examination Services (OPES) reviewed national board certifications and determined national certification demonstrated competency, removing the need for an additional BRN exam. SB 1451 opened legacy/retired national certifications to the pathway but BRN staff said uptake has remained modest.
Melby offered counts: the state has about 45,540 nurse practitioners; roughly 2,700 have been granted 103 status (the step required to work toward 104 independent practice). Yearly approved 103 applications reported by staff were: 2021–22–23: 843; 2023–24: 1,030; 2024–25: 846. Melby described the statutory/practice requirements: an applicant must work in 103 status for three years or about 4,600 hours before qualifying to apply for 104 independent practice. She also said employers sometimes do not allow certified 103 NPs to work in 103 roles, limiting opportunities to gain the required experience.
Melby warned of public confusion about titles and certification and said BRN and stakeholder groups will publish FAQs. She stated, “Unless you are certified through the board of registered nursing as a 103, you are not a 103,” emphasizing the need for applicants to follow the formal application and certification steps.
Melby said BRN is updating the 104 application instructions to reflect SB 1451 and expects to complete those updates in the first half of the year. The item was information only; no regulatory changes were voted at the committee meeting.
Ending: Staff will continue outreach, update application instructions and publish FAQs to clarify the certification pathway and employer expectations.
