Scope of Practice & Standards

California CRNA
Scope of Practice,
answered.

Q&A about the legal basis of Nurse Anesthesia practice in California.

member questions

source documents

practice documents

Summaries are a starting point, not legal advice. Each answer is a plain-language synthesis for member convenience. The linked source documents — statutes, regulations, board opinions, and agency correspondence — are the authoritative reference. Verify against the source before relying on it. CANA does not provide legal advice.

Browse all 27 questions across 14 topics.

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Physician Supervision

California CRNAs are independent practitioners — physician supervision is not required.

Do CRNAs in California require Physician Supervision?

No. The Board of Registered Nursing has consistently held that CRNAs are licensed independent practitioners who do not require supervision by a physician, surgeon, or anesthesiologist, and California has opted out of the federal Medicare supervision requirement. AB 876 (eff. Jan. 1, 2026) further codified this principle in statute: the amended BPC §2833.6 is expressly declaratory of existing law and the holding of California Society of Anesthesiologists v. Brown (2012) 204 Cal.App.4th 390, which confirmed CRNAs do not require physician supervision to administer anesthesia. Additionally, AB 876’s new BPC §2826.6(c) provides that mere physical proximity of a physician or other provider does not create supervision over a CRNA.Source documents (6)

[A7.3] CRNAs may discharge outpatient surgery patients; are independent practitioners not requiring physician supervision — BRN, Sep 1988
[A7.9] BRN: physician supervision is not required for CRNA practice (to CA DHS) — BRN, Jul 2002
[A7.13] CRNAs are licensed independent practitioners and do not require supervision of a surgeon or anesthesiologist — BRN, Nov 2004
[A7.14] BRN to The Joint Commission: California CRNAs do not require supervision — BRN, Jan 2005
[B3] Reg. Package R-34-85 — eliminated physician/CRNA supervision requirement & regional-anesthesia restrictions — CA Code Title 22, Dec 1986
[C1.a] California's letter to CMS opting out of the Medicare supervision requirement — Gov. Schwarzenegger, 2009
[A4a] AB 876 (Ch. 169, Stats. 2025) — Nurse Anesthetists Act; amends BPC §§2826 & 2833.6; adds §§2826.5, 2826.6, 2826.7 — CA Legislature, signed Oct. 1, 2025, eff. Jan. 1, 2026

When and how did California opt out of the federal supervision requirement?

In 2009 the Governor sent CMS a letter opting California out of the Medicare physician-supervision requirement for CRNA anesthesia services. Lawsuits brought by the CSA and CMA to overturn it failed at the trial, appellate, and Supreme Court levels through 2012.

Source documents (7)

[C1.a] California's letter to CMS opting out of the Medicare supervision requirement — Gov. Schwarzenegger, 2009
[C1] CMS Spotlight: Opt-Out of Federal CRNA Supervision Requirement — CMS, Jun 2013
[C1.b] CSA-CMA Lawsuit — Superior Court original filing — Courts, Feb 2010
[C1.c] CSA-CMA Lawsuit — Summary judgment granted for Governor + CANA — Courts, Sep 2010
[C1.d] CSA-CMA Lawsuit — Appeal filed against the opt-out — Courts, Jan 2011
[C1.e] CSA-CMA Lawsuit — Appellate court final judgment for Governor + CANA — Courts, Mar 2012
[C1.f] CSA-CMA Lawsuit — CA Supreme Court review denied — Courts, Jun 2012

A facility says supervision is still required — what can I show them?

Point them to CANA's current opt-out FAQ for facilities and the BRN / state correspondence confirming that physician supervision is not required for CRNA practice in California. However, healthcare facilities remain free to organize anesthesia departments and deliver anesthesia services in the manner that best serves their patients and communities. Any limitations on CRNA practice that exceed legal and accreditation requirements are often found in the facility’s medical staff bylaws. See the next question below for additional information.

Source documents (5)

[C1.g] California Opt-Out FAQs — information sheet for facilities — CANA, Feb 2025
[C1.h] CMS Spotlight: Opt-Out of Federal CRNA Supervision Requirement (reference copy) — CMS
[A7.10] DHS defers to the BRN on CRNA scope of practice — CA DHS, Nov 2002
[A7.11] DHS to CSA: Department defers to the BRN on CRNA scope of practice — CA DHS, Nov 2002
[A7.14] BRN to The Joint Commission: California CRNAs do not require supervision — BRN, Jan 2005

How is CRNA practice impacted by facility bylaws, department rules, regulations, and policy?

CRNA practice is directly impacted by federal, state, and local laws and regulations, and accreditation standards. In addition, a facility may impose other limitations on CRNA practice that exceed legal and accreditation requirements. These limitations are often found in the organization’s medical staff bylaws. Medical staff bylaws serve as the roadmap for the governance structure of the organization’s clinical practice. CRNAs should review these documents to understand the organization’s expectation of practice and for any problematic language that may restrict CRNA practice.

Scope of Practice

What anesthesia services CRNAs may provide, and the laws that define them. Updated to reflect AB 876 (Ch. 169, Stats. 2025), which amended the Nurse Anesthetists Act effective January 1, 2026.

Can a CRNA administer general and regional anesthesia?

Yes. A 1984 California Attorney General opinion concluded it is within a CRNA's scope to administer general or regional anesthesia, and the BRN has repeatedly confirmed this.

Source documents (4)

[A5]AG Opinion 83-1007 — CRNAs may administer general or regional anesthesia — CA Attorney General, Apr 1984
[A7.4]CRNAs may administer anesthesia ordered by a physician, dentist or podiatrist; may perform pre/post anesthesia evaluation — BRN, Nov 1988
[A7.5]CRNA selects and administers the anesthetic agent and maintains patient stability — BRN, Jul 1990
[A1]Scope of Practice Guidelines for California CRNAs — CANA, 2012

What did AB 876 change, and when does it take effect?

AB 876 (Chapter 169, Statutes of 2025) was signed by the Governor on October 1, 2025, and takes effect January 1, 2026. It amends BPC §§2826 and 2833.6, and adds §§2826.5, 2826.6, and 2826.7 to the Nurse Anesthetists Act. Key changes: (1) For the first time, “anesthesia services” is defined in statute to include preoperative, intraoperative, and postoperative care and pain management; selection and administration of medications; and emergency, critical care, and resuscitation services. (2) CRNAs are expressly authorized to perform anesthesia services — settling any ambiguity in the prior statutory text. (3) A patient-specific order from a physician, dentist, or podiatrist is deemed full legal authorization for the CRNA to select, implement, abort, or modify the anesthesia modality without requiring a separate prescription or standardized procedure. (4) The CRNA’s selection and administration of medications — including controlled substances — under such an order does not constitute a “prescription” under state or federal law. (5) Mere physical proximity of a physician or other provider does not create supervision over the CRNA. (6) BPC §2833.6 is amended to be expressly declaratory of existing law, codifying the California Court of Appeal’s holding in California Society of Anesthesiologists v. Brown (2012) 204 Cal.App.4th 390 — which confirmed CRNAs do not require physician supervision to administer anesthesia in California. Importantly, AB 876 does not expand independent prescriptive authority, does not eliminate facility-level credentialing or bylaw requirements, and does not change the requirement that a qualified provider first issue an anesthesia order for a specific patient.

Source document

[A4a] AB 876 (Ch. 169, Stats. 2025) — Nurse Anesthetists Act: defined “anesthesia services,” expressly authorized CRNA anesthesia practice, codified order-as-authorization rule, confirmed medications not a prescription; amends BPC §§2826 & 2833.6; adds §§2826.5, 2826.6, 2826.7 — CA Legislature, signed Oct. 1, 2025, eff. Jan. 1, 2026

Which laws define the CRNA scope of practice in California?

The Nursing Practice Act and the Nurse Anesthetists Act in the Business & Professions Code set the statutory basis, supplemented by CANA’s Scope of Practice Guidelines and legal memoranda. As of October 1, 2025, AB 876 (Chapter 169, Statutes of 2025) significantly strengthened this framework by amending BPC §2826 and §2833.6 and adding §§2826.5, 2826.6, and 2826.7 to the Nurse Anesthetists Act. The new sections: (1) define “anesthesia services” for the first time in statute; (2) expressly authorize CRNAs to perform anesthesia services; (3) clarify that a patient-specific order from a physician, dentist, or podiatrist is full authorization for the CRNA to select, initiate, modify, or abort the anesthesia modality; and (4) codify that a CRNA’s selection and administration of medications — including controlled substances — for anesthesia or pain management under such an order does not constitute a “prescription.” The amended BPC §2833.6 is explicitly declaratory of existing law, incorporating the California Court of Appeal ruling in California Society of Anesthesiologists v. Brown (2012) 204 Cal.App.4th 390. These provisions take effect January 1, 2026.

Source documents (5)

[A4a] AB 876 (Ch. 169, Stats. 2025) — Nurse Anesthetists Act amendments: defined “anesthesia services,” expressly authorized CRNA practice, codified order-as-authorization rule, clarified no-prescription status for medications; amends BPC §§2826, 2833.6; adds §§2826.5, 2826.6, 2826.7 — CA Legislature, signed Oct. 1, 2025, eff. Jan. 1, 2026
[A3] Nursing Practice Act, §2725–2727.5 — CA B&P Code
[A4] Nurse Anesthetist Act, §2825–2833.6 — CA B&P Code
[A1] Scope of Practice Guidelines for California CRNAs — CANA, 2012
[A2] CRNA Scope of Practice Memorandum — Mayer Brown, Sep 2014

Who can order anesthesia, and what is the CRNA responsible for?

A physician, dentist, or podiatrist may order anesthesia. Under AB 876 (eff. Jan. 1, 2026), that patient-specific order is deemed full authorization for the CRNA to select, initiate, modify, or abort the modality of anesthesia during the course of care, and to select and administer all necessary medications — including controlled substances — for anesthesia and perioperative pain management without a separate prescription. The CRNA is responsible for selecting and administering the anesthetic agent and managing the patient’s stability throughout the entire perioperative period. A CRNA performing anesthesia services does not assume the scope of practice of a registered nurse and is not required to follow standardized procedures.

Source documents (4)

[A7.4] CRNAs may administer anesthesia ordered by a physician, dentist or podiatrist; may perform pre/post anesthesia evaluation — BRN, Nov 1988
[A7.5] CRNA selects and administers the anesthetic agent and maintains patient stability — BRN, Jul 1990
[H2] Scope of Nurse Anesthesia Practice — AANA, 2013
[A4a] AB 876 (Ch. 169, Stats. 2025) — order by physician/dentist/podiatrist is full CRNA authorization to select, modify, or abort anesthesia modality; medications not a prescription (BPC §§2826.5, 2826.6, 2826.7) — CA Legislature, signed Oct. 1, 2025, eff. Jan. 1, 2026

Who is liable for a CRNA's anesthesia care?

Pre / Post Evaluation & Discharge

Pre-anesthesia and post-anesthesia evaluations, PACU release, and discharge authority.

Can a CRNA perform the pre-anesthesia and post-anesthesia evaluation?

Yes. The BRN confirmed this in the 1980s, and a 1993 Title 22 amendment removed the requirement that only a physician perform the pre-anesthesia evaluation.

Source documents (4)

[A7.2]CRNAs may perform pre/post anesthesia evaluation, release patients from PACU, implement emergency procedures — BRN, Apr 1986
[A7.4]CRNAs may administer anesthesia ordered by a physician, dentist or podiatrist; may perform pre/post anesthesia evaluation — BRN, Nov 1988
[B4]Reg. Package R-41-91 — permits CRNAs to perform pre-anesthesia evaluation & PACU/outpatient discharge — CA Code Title 22, Apr 1993
[H6]Post-Anesthesia Care Standards for the CRNA — CANA / AANA, 2013

Can a CRNA discharge a patient from the PACU or outpatient surgery?

Yes. CRNAs may authorize release of a patient from the PACU and discharge patients from outpatient or ambulatory surgery centers.

Source documents (3)

[A7.2]CRNAs may perform pre/post anesthesia evaluation, release patients from PACU, implement emergency procedures — BRN, Apr 1986
[A7.3]CRNAs may discharge outpatient surgery patients; are independent practitioners not requiring physician supervision — BRN, Sep 1988
[B4]Reg. Package R-41-91 — permits CRNAs to perform pre-anesthesia evaluation & PACU/outpatient discharge — CA Code Title 22, Apr 1993

Pain Management

Acute and chronic pain services inside and outside the operating room.

Can CRNAs provide pain management services?

Yes. The BRN confirmed that providing pain management services and emergency procedures — both inside and outside the OR suite — is within the CRNA scope of practice, and CMS recognizes CRNA chronic pain management. AB 876 (eff. Jan. 1, 2026) codifies this in statute: pain management throughout the entire perioperative period is expressly included in the statutory definition of “anesthesia services” (BPC §2826), and the selection and administration of medications for pain management pursuant to a physician’s, dentist’s, or podiatrist’s order does not constitute a prescription.

Source documents (3)

[A7.6]Pain management services and emergency procedures inside and outside the OR are within CRNA scope — BRN, Jan 1992
[C7]CMS Update on CRNA chronic pain management — CMS, Nov 2012
[A4a]AB 876 (Ch. 169, Stats. 2025) — pain management expressly included in statutory definition of “anesthesia services”; pain management medications under order not a prescription (BPC §2826) — CA Legislature, signed Oct. 1, 2025, eff. Jan. 1, 2026

Licensed Independent Practitioner & Credentialing

LIP status and how CRNAs are credentialed by hospitals and The Joint Commission.

Are California CRNAs licensed independent practitioners (LIPs)?

Yes. The BRN, the California Department of Health Services, and The Joint Commission all recognize California CRNAs as licensed independent practitioners eligible to be credentialed without supervision.

Source documents (6)

[A7.13]CRNAs are licensed independent practitioners and do not require supervision of a surgeon or anesthesiologist — BRN, Nov 2004
[A7.15]DHS to BRN: CRNAs are licensed independent practitioners under state law — CA DHS, Feb 2005
[D3]CA CRNAs are eligible to be credentialed as licensed independent practitioners — The Joint Commission, Nov 2004
[D2]JC survey procedure for determining LIP status for CRNAs (to AANA) — The Joint Commission, Nov 2003
[D4]Definition of licensed independent practitioner and the process to determine LIP status — The Joint Commission, Apr 1989
[D1]Anesthesia Standards for Hospitals — The Joint Commission, 2010

Medicare, CMS & Billing

Conditions of participation, payment policies, and anesthesia claim modifiers.

How are CRNA services billed to Medicare?

Can anesthesiologist assistants (AAs) bill the QZ modifier?

Which Medicare conditions apply to anesthesia services?

Hospital Conditions of Participation §482.52 and Ambulatory Surgical Center Conditions for Coverage §416.42 / §416.52 govern anesthesia, surgical service, and patient discharge.

Source documents (2)

[C2] Medicare Conditions of Participation for Hospitals — §482.52 Anesthesia Services — CMS
[C3] Medicare Conditions for Coverage for ASCs — §416.42 Surgical service & §416.52 Admission/discharge — CMS

What CMS guidance covers teaching rules and OB sedation?

Practice Settings

Trauma centers, obstetrics, office-based and ambulatory surgery settings.

Can CRNAs provide anesthesia in trauma centers?

What standards apply to office-based anesthesia?

What governs California outpatient / ambulatory surgery centers?

Health & Safety Code §1248–1248.85 governs outpatient surgery centers, alongside Title 22 anesthesia and surgical-service regulations and the Medicare ASC conditions for coverage.

Source documents (4)

[E1] §1248–1248.85 (outpatient surgery centers) — CA Health & Safety Code
[B1] §70231–70239, Anesthesia Services — CA Code Title 22
[B2] §70223 Surgical Services (see (d) for anesthesia requirements) — CA Code Title 22
[C3] Medicare Conditions for Coverage for ASCs — §416.42 Surgical service & §416.52 Admission/discharge — CMS

Dental Anesthesia

Providing anesthesia for surgery performed by a dentist.

Can a CRNA administer anesthesia for dental surgery?

Yes. California dental anesthesia law and regulations, together with BRN confirmation, allow a CRNA to administer anesthesia ordered by a dentist.

Source documents (3)

[F1] §1646–1646.9 (dental anesthesia law) — CA B&P Code
[F2] §1043 (dental anesthesia regulations) — CA Code of Regs
[A7.4] CRNAs may administer anesthesia ordered by a physician, dentist or podiatrA 4st; may perform pre/post anesthesia evaluation — BRN, Nov 1988

Podiatry

Providing anesthesia for surgery performed by a podiatrist.

Can a CRNA administer anesthesia for podiatric surgery?

Yes. The Department of Consumer Affairs, the BRN, and the Board of Podiatric Medicine all confirm a CRNA may provide the full range of anesthesia services ordered by a podiatrist, in inpatient or outpatient settings.

Source documents (4)

[G1] CRNAs may provide full range of services for surgery performed by a podiatrist — Dept. of Consumer Affairs, Sep 1988
[G2] CRNAs may administer all types of anesthesia as ordered by a podiatrist — BRN, Jan 2003
[G3] Restrictions on podiatrists administering anesthesia do not limit the type a podiatrist may order — Board of Podiatric Medicine, Feb 2003
[A7.12] CRNAs may administer all types of anesthesia for surgery performed by podiatrists — BRN, Jan 2003

DEA Registration

Whether a CRNA needs a separate DEA registration.

Does a CRNA need their own DEA registration?

No, the DEA has exempted CRNAs from registering with the DEA (at least since the early 1980's) in accordance with the Code of Federal Regulations Title 21, Part 1301.22 for engaging in usual and customary clinical anesthesia practice that does not involve writing prescriptions for patients to fill at a pharmacy once said patients are discharged from the hospital or ambulatory point of service.

California has not authorized CRNAs to have prescriptive authority to date. However, according to the Code of Federal Regulations, the definition of “Prescription” does “not include an order for medication which is dispensed for immediate administration to the ultimate user.” Since 1997, the U.S. Drug Enforcement Administration (DEA) has exempted CRNAs from registering with the DEA when engaging in usual and customary clinical anesthesia practice.

Source documents (3)

[I1] §1301.22 Exemption of agents and employees; affiliated practitioners — 21 CFR, 2023
[I2] DEA neither requires nor encourages registration for Mid-Level Practitioners acting as agents of registrants — DEA / Federal Register, Jul 1992
[I3] DEA: AANA Legal Briefs — AANA (Blumenreich), Oct 1993

Laboratory Orders

Ordering laboratory tests as part of nursing practice.

Can a CRNA order laboratory tests?

Employment & AB5

Worker classification and independent-contractor rules.

How do AB5 and AB2257 affect CRNAs working as independent contractors?

Education & Practice Standards

Accreditation, scope, and national practice standards.

What education and practice standards apply to CRNAs?

CRNA education follows the Council on Accreditation standards, and practice follows the AANA scope and standards for nurse anesthesia practice, core clinical privileges, office-based and post-anesthesia care standards.

Source documents (6)

[H1] Education Standards of the Council on Accreditation of Nurse Anesthesia Educational Programs — COA
[H2] Scope of Nurse Anesthesia Practice — AANA, 2013
[H3] Standards for Nurse Anesthesia Practice — AANA, 2013
[H4] Guidelines for Core Clinical Privileges for CRNAs — AANA
[H5] Standards for Office-Based Anesthesia Practice — CANA / AANA, 2015
[H6] Post-Anesthesia Care Standards for the CRNA — CANA / AANA, 2013

Workforce Studies

Independent workforce research commissioned by non-CRNA groups.

What independent anesthesia workforce studies exist?

A series of RAND studies — commissioned by the ASA and the U.S. Department of Veterans Affairs — analyze anesthesia labor markets and workforce capabilities.

Source documents (4)