Collaborating Physicians in California: What NPs and PAs Need in 2026

The Pathway, in Plain Terms

California built a staircase rather than a switch.

Standard NP. Written Standardized Procedure Agreement with a supervising physician. This is where most NPs are, and where most stay for the first several years.

103 NP. After three years and 4,600 hours, you can practise without standardized procedures — but inside a group setting that includes at least one physician. The supervision relationship ends; the requirement to be in a practice with a physician does not. This is the step people most often misread as full independence.

104 NP. After three more years as a 103, full independent practice in defined settings: FQHCs, group practices with physicians, and entities providing services under contract with the state.

The practical consequence for hiring a collaborator: the staircase is long. Six years of qualifying practice separates a new California NP from 104 status. For the great majority of NPs practising in the state today, a supervising physician isn't a temporary inconvenience — it's the arrangement for the foreseeable future, and worth setting up properly.

What Changed for PAs

Until the end of 2025, a California physician could supervise four PAs. As of January 1, 2026, the limit is eight, across all practice settings.

Two things follow from that.

Supervision is no longer one-to-one. Multiple physicians may supervise the same PA, and a practice agreement can be signed by multiple physicians or by an agent for the physicians in a health system.

Chart countersignature is gone. PA medical records no longer require review by a supervising physician. That doesn't mean review is a bad idea — it means the state stopped mandating it, and what remains is whatever your practice agreement says.

The practice agreement itself must address the types of medical services the PA may perform, supervision policies and procedures, how competency is evaluated, and drug and device furnishing. It is not submitted to the Board — you keep it at the practice site.

The California Process, Step by Step

1. Draft the written Standardized Procedure Agreement — tailored to the specific practice setting, scope of practice, and drug formulary. Generic templates are where most problems start.
2. Both parties sign and date it.
3. Keep it on file at the practice site. Nothing is submitted to either board. That's convenient, and it's exactly why agreements go stale — nobody external ever asks to see them until something goes wrong.
4. Establish your review, quality assurance, and physician availability protocols. The state doesn't set a percentage, so this is a judgment call you document rather than a box you tick.
5. Register with CURES if you hold a DEA number, and consult it as required before prescribing controlled substances.
6. Review and update the agreement periodically — and whenever the scope of practice changes.
7. Retain documentation for at least seven years.

What a Collaborating Physician Costs in California

California runs expensive, and the reason is arithmetic.

Four prescribing NPs per physician is among the tighter caps in the country. Supply of willing supervising physicians is capped by that number, demand isn't, and the price does what prices do.

The eight-PA change relieves some of this on the PA side — a physician who was full at four PAs now has room for four more. That's new capacity that entered the market this year, and it hasn't fully shown up in pricing yet.

This is where a network is worth something concrete. We're placing multiple providers with physicians who have verified capacity, and negotiating across a pool rather than accepting whatever a single physician quotes a stranger in a constrained market.

At MD-Match, pricing is tailored to your practice rather than flat-rated. The match fee is $50, one time, and rematching is free, always.

Mistakes I Actually See in California Arrangements

Treating 103 as full independence.

It isn't. A 103 NP still has to practise in a group setting with at least one physician. NPs have restructured their practices on this misunderstanding and had to unwind it.

Assuming the PA limit is still four.

It changed in January. Practices are turning away PAs they now have room for, and PAs are paying constrained-market rates in a market that just loosened.

A standardized procedure that doesn't match the practice.

The agreement has to reflect your actual setting, scope, and formulary. A template borrowed from a different specialty is the most common defect I see, and it's the one that looks worst in hindsight.

Never updating it.

Because nothing is filed with a board, no renewal notice ever arrives. Agreements drift years behind the practice they describe.

Missing CURES.

People register for the DEA and stop. CURES is a separate mandatory registration, and consultation before prescribing is required in most circumstances.

Counting 103 and 104 NPs against the cap.

They don't count — they aren't being supervised. Physicians decline collaborations they actually have room for.

Every physician in the MD-Match network is background-checked, license-verified for California, and capacity-checked before matching. We draft the standardized procedure to your setting rather than handing you a template, and set review reminders — because an agreement nobody has to file is an agreement nobody remembers to update.

How MD-Match Works in California

1. Complete the free intake form — credential, specialty, practice setting, timeline. First step takes about two minutes.
2. Get a personalized quote. I review every California submission myself. If you're approaching 103 eligibility, say so — it changes what you should be signing now.
3. Pay the one-time $50 match fee and get matched with a California-licensed, specialty-aligned physician with genuine capacity.
4. We handle the compliance rails — standardized procedure or practice agreement drafting, formulary, review protocols, and update reminders. If a match stops working, rematching is free.