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BRN committee outlines slow uptake of 103→104 nurse practitioner pathway and employer barriers
Summary
BRN Executive Officer Lori Melby briefed the committee on implementation of AB 890 and SB 1451, saying California has about 45,540 nurse practitioners but only roughly 2,700 have secured 103 supervised‑practice status; staff cited employer barriers that prevent some certified 103s from getting required experience toward 104 independent practice.
The California Board of Registered Nursing’s Nurse Practice Committee received an information‑only briefing on the state’s nurse practitioner pathway under AB 890 and recent changes from SB 1451, with staff warning that relatively few practitioners have moved through the supervised‑practice steps needed for independent practice.
Executive Officer Lori Melby told the committee that “we have 45,540 nurse practitioners in our state” but only about 2,700 have been certified by the BRN as 103 nurse practitioners — the supervised‑practice designation required before applying for 104 independent practice. Melby framed that gap as central to workforce planning: without employers enabling 103 practice experience, clinicians cannot complete the three‑year (or 4,600‑hour) supervised requirement to qualify for the 104 independent‑practice application.
Melby also described how SB 1451 reopened eligibility for ‘‘legacy’’ national certifications that were excluded under earlier Office of Professional Examination Services reviews, but said that even after those certifications were accepted the BRN has not seen a meaningful uptick in 103 applications. She gave annual approval counts from the transcript: about 843 approvals in 2022–23, 1,030 in 2023–24 and 846 in 2024–25, and said fiscal‑year 2025–26 totals were not yet available.
The briefing underscored two operational issues staff are addressing: clarifying the 103/104 application instructions (Melby said the 104 application needs updating to reflect SB 1451 changes) and improving public messaging so clinicians and employers understand that “unless you are certified through the Board of Registered Nursing as a 103, you are not a 103,” according to Melby. She also said staff would publish FAQs and coordinate messaging with the Board’s communications team to reduce confusion.
The item was informational; no rulemaking or board vote on policy occurred. Committee members thanked staff for the overview and asked clarifying questions about employer practices and certification status.
