Peer Responses
Student 1 – Brianna Antelman
Hello Brianna,
Great post! Your post provides a well-structured and detailed overview of California’s certification and licensure process for PMHNPs. I appreciate how you unpacked the implications of AB 890 and the pathways it creates through the 103 and 104 NP designations. It’s commendable that California is progressing toward full practice authority, though the mandated 4,600 supervised hours before autonomy remains a significant barrier—especially for underserved communities: Peer Responses.
As someone preparing for practice in Arizona, a full-practice authority state, the contrast is striking. Arizona permits NPs to evaluate, diagnose, and prescribe independently without physician oversight immediately upon licensure (Arizona State Board of Nursing, 2024). This streamlined pathway may contribute to faster integration into clinical settings and address provider shortages more efficiently than California’s tiered model.
One question that arises from your post is how institutions in California are adapting their bylaws and payer policies to align with AB 890. Are there statewide efforts to enforce alignment, or is advocacy needed at the organizational level? Also, the administrative burden you outlined is noteworthy—perhaps technology and centralized applications could reduce redundancy.
Reference
Arizona State Board of Nursing. (2024). SCOPE OF PRACTICE: Nurse Practitioners.
https://azbn.gov/sites/default/files/SOP-APRN-FAQs.pdf
Student 2 – Emmanuel M
Hello Emmanuel,
Thank you for sharing your insightful post. You presented a well-structured summary of Colorado’s requirements for APRN certification and licensure. I appreciate your thorough explanation of the state’s transition from supervised to full practice authority, especially the 1,000-hour supervised practice requirement.
One unique aspect that stood out is Colorado’s “Articulated Plan for Safe Prescribing.” This quality assurance element highlights the state’s proactive approach to ensuring patient safety even after independent practice begins—a model other states could consider adopting to balance autonomy and accountability.
In comparison, Arizona is a full practice state and does not require physician collaboration or supervised hours before granting independent practice authority (Arizona Board of Nursing, 2024). This allows NPs in Arizona to enter autonomous roles immediately after licensure and national certification, possibly accelerating access to care in rural and underserved areas. However, this also raises a question: Could Colorado’s supervised practice model reduce clinical errors or enhance patient outcomes during the transition to independent practice?
I wonder how the 1,000 supervised hours impact new NPs’ employment opportunities and whether healthcare systems in Colorado are well-prepared to support that requirement.
Reference
Arizona State Board of Nursing. (2024). SCOPE OF PRACTICE: Nurse Practitioners.
https://azbn.gov/sites/default/files/SOP-APRN-FAQs.pdf
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Question 
By Day 6 of Week 1
Respond to at least two of your colleagues on 2 different days in one or more of the ways listed below.
- Share an insight from having viewed your colleagues’ posts.
- Suggest additional actions or perspectives.
- Share insights after comparing state processes, roles, and limitations.
- Suggest a way to advocate for the profession.
- Share resources with those who are in your state.
Student 1 – Brianna Antelman
This Discussion post will focus on the process to become a Nurse Practitioner post-completion of the Master’s program. I reside in California, which requires applicants to hold an active, unrestricted registered nurse (RN) license, complete an accredited Psychiatric Mental Health Nurse Practitioner (PMHNP) graduate program, and pass the American Nurses Credentialing Center (ANCC) PMHNP examination before applying for state recognition.
All materials are uploaded through the Board of Registered Nursing’s (BRN) BreEZe portal, including official transcripts that verify at least 500 supervised clinical hours and 45 contact hours in advanced pharmacology (BRN, 2024). Fees for the nurse practitioner certificate and psychiatric–mental health specialty listing currently total $450, and fingerprint clearance must be on file. Average processing time ranges from eight to twelve weeks.
California has always limited nurse practitioners to functions outlined in “standardized procedures” jointly developed with a supervising physician, effectively restricting NPs to a collaborative practice model. Assembly Bill 890, enacted in 2020 and implemented in 2023, introduced two pathways toward greater autonomy. A “103 NP” may practice without physician supervision in clinics, medical groups, or hospitals after national certification and 4,600 hours of direct patient care. A “104 NP” may establish an independent practice anywhere in the state once the exact hour requirement is met, provided a written practice agreement specifies consultation, referral, and quality-review processes (Cal. Bus. & Prof.. Code §§ 2837.101-.105).
The statute removes the standardized-procedure mandate for qualified NPs; however, new graduates must still complete the transition-to-practice hours before being eligible for independent billing or practice (Spetz et al., 2022). Even for independently practicing “104 NPs,” California mandates a practice agreement that delineates the population focus, services offered, mechanisms for physician consultation, chart review protocols, and a plan for annual review (BRN, 2024b).
These agreements serve as the legal foundation of autonomous NP practice, ensuring accountability while addressing quality assurance and patient safety concerns (Morgan & Hawkins, 2023). After receiving a BRN furnishing number, the PMHNP may apply for federal Drug Enforcement Administration (DEA) registration using Form 224. Furnishing a number and a DEA registration together authorizes the prescribing of controlled substances in Schedules II–V.
Before issuing a Schedule II prescription, the practitioner must complete a one-time, BRN-approved three-hour course on Schedule II controlled substances (Cal. Bus. & Prof. Code § 2836.1). DEA registration must be renewed every three years, and current fees are posted on the DEA Diversion Control Division website (DEA, 2025).
California’s Controlled Substance Utilization Review and Evaluation System (CURES 2.0) is the state’s prescription-monitoring program. Nurse practitioners with furnishing numbers are required to register within thirty days of receiving their credentials. The database must be consulted when initiating a Schedule II–IV medication and at least every four months for ongoing therapy (California Department of Justice, 2024). CURES aims to curb diversion and enhance patient safety, aligning with national trends toward data-driven controlled-substance stewardship (Klieber & Rogers, 2024).
The mandatory 4,600-hour supervised practice period delays autonomous practice for new graduates, disproportionately affecting rural and underserved communities that urgently need mental health providers. Institutional bylaws in many hospitals and reimbursement policies among commercial insurers still require physician cosignature, creating operational hurdles even for fully qualified “104 NPs” (Spetz et al., 2022). The administrative burden of sequential applications, such as RN license, NP certificate, specialty listing, furnishing number, CURES registration, DEA license, and 103/104 recognition, extends onboarding timelines and increases costs.
References
Board of Registered Nursing. (2024a). Advanced practice and public health nurse certification. https://www.rn.ca.gov
Board of Registered Nursing. (2024b). Assembly Bill 890 implementation FAQs. https://www.rn.ca.gov
California Business and Professions Code §§ 2836.1, 2837.101–2837.105 (West 2023).
California Department of Justice. (2024). CURES 2.0: Frequently asked questions. https://oag.ca.gov
Drug Enforcement Administration. (2025). Registration applications & forms. https://www.deadiversion.usdoj.gov
Klieber, R., & Rogers, M. A. (2024). Payer acceptance of nurse practitioner-led primary care in California after AB 890. The Journal for Nurse Practitioners, 20(6), 421–428. https://doi.org/10.1016/j.nurpra.2024.03.015
Morgan, P., & Hawkins, M. C. (2023). Quality assurance mechanisms in autonomous nurse practitioner practice agreements: A national perspective. Journal of Advanced Nursing, 79(5), 1723–1732. https://doi.org/10.1111/jan.15311
Spetz, J., Parente, V., & Chu, L. H. (2022). Early impacts of California’s full-practice-authority legislation on nurse practitioners. Nursing Outlook, 70(4), 568–576. https://doi.org/10.1016/j.outlook.2022.02.008
Peer Responses
Student 2 – Emmanuel M
A comprehensive overview of the requirements and processes for Nurse Practitioners (NPs) in Colorado:
Physician Collaboration or Supervision Requirements
In Colorado, Nurse Practitioners must complete 1000 hours of supervised practice to gain full practice authority. After fulfilling these requirements, NPs can practice independently without a written collaborative agreement.
Certification and Licensing as an APRN in Colorado (Requirements)
To become a licensed APRN in Colorado, you must:
Hold an active Colorado RN license.
Complete a graduate-level APRN program accredited by the U.S. Department of Education or the Council for Higher Education Accreditation.
Obtain national certification in your APRN role and population focus from a recognized certifying body.
Apply for Advanced Practice Registry through the Colorado Board of Nursing.
The application process for certification
The application process involves:
Completing the online application for the Advanced Practice Registry via the Colorado Division of Professions and Occupations website.
Advanced Practice Registry: $132
Prescriptive Authority (RXN/C-RXN): $264
Submitting official transcripts from your graduate program.
Providing verification of national certification sent directly from the certifying body.
Scope of Practice for Nurse Practitioners
In Colorado, Nurse Practitioners have full practice authority, allowing them to:
Evaluate patients.
Diagnose conditions.
Order and interpret diagnostic tests.
Initiate and manage treatments.
Prescribe medications, including controlled substances.
State Practice Agreement
After completing the required supervised hours, NPs must develop an “Articulated Plan for Safe Prescribing,” which includes:
A quality assurance plan.
Mechanisms for consultation, collaboration, and referral to other healthcare providers
Obtaining a DEA License
To prescribe controlled substances, NPs must:
Obtain prescriptive authority from the Colorado Board of Nursing.
Apply for a DEA registration by completing DEA Form 224 online at the DEA Diversion Control Division website.
Provide necessary documentation, including state license information and payment.
Prescription Monitoring Program (PMP)
Colorado operates a Prescription Drug Monitoring Program (PDMP), a secure online database that tracks controlled substance prescriptions. Nurse Practitioners with DEA registration are required to register with the PDMP and utilize it to monitor patient prescription histories, aiding in the prevention of prescription drug misuse.
Controlled-Substance Prescriptive Authority
In Colorado, Nurse Practitioners with prescriptive authority can prescribe medications in Schedules II through V, provided they have obtained DEA registration and comply with state and federal regulations regarding controlled substances.
State websites associated with the requirements and procedures for becoming an advanced practice nurse in Colorado.
https://dpo.colorado.gov/NursingLinks to an external site.
https://dpo.colorado.gov/PDMPLinks to an external site.
https://www.deadiversion.usdoj.gov/drugreg/registration.htmlLinks to an external site.