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BRN reports confusion, IT errors and next steps in implementing 103/104 transition-to-practice rules
Summary
BRN staff told the committee that changes from SB1451 and other updates caused the 104 application to be released with outdated fields; staff described planned Breeze system updates, interim manual workarounds, and clarified CCR 1482.4 requirements (three years or 4,600 hours as a 103) for 104 eligibility.
BRN staff apologized April 9 after meeting members' questions about the newly implemented 103 and 104 pathways. Executive Officer Lori Melby said the 104 licensing form was released in January but contained language aligned with prior law because technical updates tied to SB1451 were not fully incorporated into the Breeze licensing application.
"When SB1451 updated the process of becoming a 103 and ultimately becoming a 104 I did not catch that and update the application," Melby said, taking ownership and describing a plan to align the NP initial application, furnishing, schedule II, 103 and 104 forms in the licensing system. She warned the committee that the Breeze change request queues at Department of Consumer Affairs are prioritized across many boards and that full automation could take months; in the interim BRN staff will accept applications but said manual processing will be slower.
Committee members sought clarity on eligibility: BRN staff and members cited California Code of Regulations language (1482.4) that requires proof of practice as a 103 in good standing for three full-time equivalent years or 4,600 hours of direct patient care to meet certain eligibility tracks. Members also described that employers sometimes decline to recognize a nurse practitioner's 103 certification, meaning a certified 103 may still practice under standardized procedures and not be counted administratively as a 103 in a given workplace.
On numbers, staff and members noted there are thousands of nurse practitioners in transition: the committee discussed figures including roughly 3,000 to 3,800 103 certifications issued as of early 2026 and that the board is tracking growth as 104s begin to be issued. Melby said the BRN has developed a form for DNP program directors to certify that doctoral clinical hours exceed prior master's clinical requirements so certain hours can count toward the 4,600-hour eligibility threshold for 104 applicants.
What to expect: BRN staff will pursue the Breeze IT updates and continue manual case-by-case processing for applicants in the short term. The committee was asked to inform licensees that applications are available even while updates are pending, but that applicants should expect delays until the system aligns.
