Who Can Prescribe Medication in California: Physicians, NPs, PAs

In California, the providers who can legally prescribe medication are physicians (MDs and DOs), nurse practitioners, physician assistants, certified nurse-midwives, dentists, podiatrists, optometrists, pharmacists, and naturopathic doctors. Only physicians have essentially unlimited prescriptive authority. Every other licensed prescriber works inside a narrower scope set by state law, and some can only furnish specific drugs under a protocol or a written agreement with a supervising physician.

Physicians and Surgeons

MDs licensed by the Medical Board of California and DOs licensed by the Osteopathic Medical Board of California hold the broadest prescriptive authority in the state. They can prescribe any medication, including every schedule of controlled substances, for any condition within the scope of medical practice.¹ The requirement is that the physician perform an appropriate examination and document a medical reason for the drug in the patient’s record.

Physicians, like every other California prescriber of controlled substances, must check the state prescription drug monitoring database (CURES) before writing a Schedule II through V prescription.²

Nurse Practitioners

Nurse practitioners (NPs) can prescribe in California, but how independently depends on which category they fall into. Assembly Bill 890, signed in 2020, created two newer NP designations that step away from the older “standardized procedures” model that tied an NP’s prescribing to a supervising physician.³

A “103 NP” must have completed at least 4,600 hours of clinical practice in California within the past five years and must work in a group setting that includes at least one physician. After three years in good standing as a 103 NP, a practitioner can apply for the “104 NP” designation, which permits fully independent practice and prescribing outside a group setting. The Board of Registered Nursing began certifying 103 NPs when the law took effect; 104 NP certifications are expected to begin in 2026.³

NPs who do not qualify under either AB 890 category can still prescribe, but only under standardized procedures developed with a physician.

Physician Assistants

Physician assistants (PAs) cannot practice or prescribe independently in California. Every PA works under a written practice agreement developed with a supervising physician. That agreement defines which medical services the PA may perform and which drugs the PA may prescribe, including Schedule II through V controlled substances if the supervising physician authorizes it.⁴

The supervising physician doesn’t have to be physically present while the PA sees patients, but must be reachable by phone or other electronic means during those encounters.⁴ A PA prescribing outside the terms of that agreement is prescribing unlawfully.

Certified Nurse-Midwives

Certified nurse-midwives (CNMs) hold a furnishing number from the Board of Registered Nursing that lets them order or furnish drugs and devices consistent with the midwifery scope: pregnancy, childbirth, postpartum care, newborn care, and family planning. They prescribe under standardized procedures developed with a physician.⁵

CNMs can furnish Schedule II controlled substances only after completing specific pharmacology coursework covering addiction risks and neonatal abstinence syndrome, and only if they hold a DEA registration. Their authority doesn’t extend outside the midwifery scope into general medicine.⁵

Dentists, Podiatrists, and Optometrists

These three provider types can prescribe, but only for conditions inside their licensed area. A dentist can’t legally write a prescription for back pain, and a podiatrist can’t prescribe allergy medication.

Dentists (DDS or DMD) can prescribe drugs, including controlled substances, for conditions involving the teeth, jaws, and surrounding oral structures.
Podiatrists (DPM) are licensed to diagnose and treat conditions of the foot, ankle, tendons that insert into the foot, and (nonsurgically) the muscles and tendons of the leg that control foot function. Prescriptions must relate to that region.⁶
Optometrists (OD) can prescribe topical and oral therapeutic medications for eye conditions, including nonmalignant diseases of the front of the eye. They cannot prescribe controlled substances or antiglaucoma agents, and certain other drugs are excluded by statute.⁷

All three must check CURES before prescribing controlled substances.

Pharmacists

Pharmacists don’t prescribe in the traditional sense. They do have a furnishing authority that lets them provide specific medications directly to patients without a physician’s prescription. The categories currently covered are:

Hormonal contraceptives, including emergency contraception, after a screening
Prescription-strength nicotine replacement products for smoking cessation
Travel medications recommended by the CDC
Antibiotics for uncomplicated urinary tract infections under a standardized protocol
Injectable epinephrine for emergency allergic reactions

Pharmacists must complete category-specific training and must notify the patient’s primary care provider of anything they furnish.⁸ They cannot furnish controlled substances under these protocols.

Naturopathic Doctors

Naturopathic doctors (NDs) have the most restricted prescriptive authority of any California prescriber. They can independently prescribe non-controlled prescription drugs, including natural and synthetic hormones.

For controlled substances, NDs can furnish Schedule III through V only under standardized procedures developed with a supervising physician, and Schedule III furnishing additionally requires a patient-specific protocol approved by that physician for each prescription. A single physician cannot supervise more than four NDs at a time.⁹ NDs are prohibited from prescribing Schedule I or Schedule II substances at all.

DEA Registration for Controlled Substances

State licensing isn’t enough to prescribe controlled substances. Any provider who writes controlled substance prescriptions in California must also hold a valid federal DEA registration, obtained through DEA Form 224 (initial) or 224a (renewal). Without it, a provider can prescribe non-controlled drugs within their scope but cannot legally write a prescription for anything on Schedules II through V.

Telehealth Prescribing

Federal law generally requires an in-person examination before a provider prescribes a controlled substance, under the Ryan Haight Act. Pandemic-era flexibilities have been extended and currently remain in effect through December 31, 2026. During the extension, any DEA-registered practitioner can prescribe Schedule II through V controlled substances via telehealth without a prior in-person visit, provided the prescription serves a legitimate medical purpose and the consultation uses a real-time audio-visual system.¹⁰

These rules apply to every provider type covered above, not just physicians. An NP prescribing via telehealth still needs the same DEA registration and state-level authority that would apply in person. When the current extension expires at the end of 2026, an in-person visit requirement for controlled substance prescriptions may return.

What Happens If a Provider Prescribes Outside Their Authority

Prescribing outside a valid license carries serious consequences at both the state and federal level. A California licensing board can suspend or revoke a provider’s license for prescribing beyond scope. The DEA can revoke a practitioner’s registration, which ends the ability to handle controlled substances anywhere in the country.

The stakes rise further when controlled substances are involved. Under federal law, knowingly dispensing a controlled substance outside the usual course of professional practice is a criminal offense. Penalties vary by schedule: Schedule I or II violations can carry up to twenty years in prison, while Schedule V violations carry up to one year.¹¹ Providers convicted of fraud or certain drug offenses also face mandatory exclusion from Medicare, Medicaid, and other federal healthcare programs, meaning no federal program will pay for anything they prescribe, order, or furnish.¹²

1
Medical Board of California. Consumer – Prescribing
2
Medical Board of California. Mandatory Use – CURES
3
California Board of Registered Nursing. Assembly Bill 890
4
Medical Board of California. Supervising Physician Assistants – FAQs
5
California Board of Registered Nursing. Nurse-Midwife
6
Justia Law. California Business and Professions Code Article 22 – Podiatric Medicine
7
California Legislative Information. California Business and Professions Code 3041
8
California Legislative Information. California Business and Professions Code 4052
9
Justia Law. California Business and Professions Code Article 4 – Sections 3640-3645
10
Federal Register. Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications
11
Office of the Law Revision Counsel. 21 U.S. Code 841 – Prohibited Acts A
12
Office of Inspector General, HHS. Exclusions