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Key Takeaways
- AB 583 authorizes nurse practitioners (NPs), effective July 1, 2026, to complete and attest to death and fetal death certificates, determine and record causes of death, amend vital records, and fulfill coroner notification duties, when the NPs were last in attendance on the decedent.
- AB 876 clarifies certified registered nurse anesthetist (CRNA) authority, effective January 1, 2026, by defining "anesthesia services," confirming that a patient-specific anesthesia order provides full authorization for anesthesia care, and specifying that a CRNA's selection and administration of medication under such orders does not constitute a prescription.
- Healthcare organizations should begin preparing now by reviewing bylaws, policies, and related documentation workflows to ensure alignment with these statutory changes taking effect in 2026.
AB 583 (Pellerin): NP Authority to Complete Death and Fetal Death Certificates
Existing Law
Under California Health and Safety Code §§ 102775–102805, every death occurring in the state must be registered with the local registrar in the district where the death was officially pronounced or the body was found.
The death certificate contains both demographic and medical information, including cause, manner, and time of death. Prior to AB 583, the medical and health section had to be completed and attested to by the physician and surgeon last in attendance or, in certain post-acute settings, by a qualified physician assistant (PA) acting within defined statutory parameters.
All certifiers are required to notify the coroner of deaths that occur under specific conditions (e.g., suspected homicide, suicide, accident, or unattended death). Failure to do so constitutes a criminal offense.
What the Bill Does
Effective July 1, 2026, AB 583 amends several provisions of the Health and Safety Code (HSC) to authorize nurse practitioners (NPs) to perform duties relating to death and fetal-death certificates and coroner notification.
Specifically, AB 583:
- Authorizes NPs who were the last practitioners in attendance on a decedent to complete and attest to the medical and health section of the death certificate, including the time of death. (HSC § 102795)
- Extends to NPs the procedural deadlines for completion and filing of certificates, including the existing 15-hour post-death timeframe for submission to the local registrar or coroner. (HSC § 102800)
- Permits NPs who were last in attendance to provide cause-of-death information, including the primary and contributing medical conditions and the time they last saw the patient alive. (HSC § 102825)
- Includes NPs among the individuals who must immediately notify the coroner when they have knowledge of a death in certain circumstances (e.g. suspected suicide). Failure to notify remains a misdemeanor. (HSC § 102850)
- Authorizes NPs to prepare and deposit or deliver fetal-death certificates in the same manner as attending physicians. (HSC § 102975)
- Includes NPs among those who may file a declaration under penalty of perjury to amend a record of death, fetal death, or live birth when new or corrected information becomes available. (HSC § 103300)
Scope and Limitations
Facilities and NPs should note the following boundaries of this new authority:
- Applicable to the Practitioner Last in Attendance. An NP may complete and attest to a death certificate only if the NP was the last practitioner in attendance on the decedent before death. If another qualified provider attended the patient more recently, that provider remains responsible for certification.
- No Setting Restriction. The amended statutes do not limit NP authority to specific facility types such as skilled nursing or intermediate care facilities. The determining factor is who was last in attendance, not where the patient died.
- Consistent Legal Standards. NPs now are subject to the same timing, accuracy, and coroner-notification requirements–and the same potential penalties for failure to report–as physicians and physician assistants.
Why It Matters
- Reduces administrative delays. Allows the practitioner directly involved in the patient's final care to complete and file the death certificate promptly, minimizing delays in record processing.
- Supports families and next of kin. Enables faster issuance of death certificates, facilitating funeral arrangements, life-insurance claims, and estate administration.
- Modernizes California law. Reflects the realities of contemporary care delivery in which nurse practitioners often manage patients' ongoing and end-of-life care.
Implementation and Compliance Considerations
Effective Date: July 1, 2026
Recommended Next Steps for Facilities and NPs:
- Update death-certification procedures and electronic record access to allow nurse practitioner attestations, and coordinate with local or state registration authorities to ensure external systems can accept NP certifications by the operative date.
- Establish clear procedures for determining which practitioner qualifies as "last in attendance."
- Train clinical and administrative personnel on documentation and coroner-notification obligations under HSC § 102850.
- Review internal policies for consistency with HSC §§ 102795–103225 and related regulations governing reportable deaths and record amendments.
AB 876 (Flora): CRNA Scope Clarification
Existing Law
Under California's Nursing Practice Act (Business and Professions Code (BPC) § 2700 et seq.), certified registered nurse anesthetists (CRNAs) may provide anesthesia services on the order of a physician, dentist, or podiatrist.
Facilities using CRNAs must obtain administrative and medical staff approval, and CRNAs who are not employees remain subject to the facility's bylaws, credentialing, and peer-review requirements. (BPC §§ 2827-2828.)
Prior to AB 876, the law did not define "anesthesia services" or expressly describe the scope of a CRNA's authority once a qualified provider issued an anesthesia order.
What the Bill Does
Effective January 1, 2026, AB 876 adds several new sections to the Business and Professions Code to define "anesthesia services" and clarify the authority of CRNAs when providing anesthesia pursuant to an order from a physician, dentist, or podiatrist.
Specifically, AB 876:
- Establishes a statutory definition of "anesthesia services," encompassing preoperative, intraoperative, and postoperative care and pain management for patients receiving anesthesia under a qualified provider's order; the selection and administration of medications pursuant to that order; and the provision of emergency, critical-care, and resuscitation services. (BPC § 2826)
- Explicitly authorizes CRNAs to perform anesthesia services. (BPC § 2826.5)
- Clarifies that a patient-specific order from a physician, dentist, or podiatrist for anesthesia services authorizes the CRNA to select, initiate, and implement the anesthesia modality and to modify or discontinue it as clinically indicated. (BPC § 2826.6)
- Specifies that the selection and administration of medications, including controlled substances, by a CRNA for anesthesia or pain-management purposes under such an order does not constitute a prescription under state or federal law. (BPC § 2826.7)
- Clarifies the Legislature's intent that these provisions codify and clarify existing practice rather than expand CRNA authority. (BPC § 2833.6)
Scope and Limitations
Facilities and CRNAs should note the following boundaries of this clarified authority:
- Authorized by a Patient-Specific Order. A CRNA may perform anesthesia services only when acting pursuant to an individual order from a physician, dentist, or podiatrist for a specific patient. The order serves as the legal authorization for the CRNA to select, initiate, and manage the anesthesia modality.
- No Expansion of Independent Practice. The bill codifies existing practice expectations but does not create independent prescriptive or supervisory authority, nor does it modify facility-level approval or committee requirements under the Nursing Practice Act or institutional bylaws, policies, or other governing documents.
- Consistent Legal Standards. CRNAs remain subject to all existing professional and regulatory standards under the Nursing Practice Act, including requirements for supervision, credentialing, and documentation.
Why It Matters
- Provides legal clarity. Establishes explicit statutory definitions and confirms that a qualified provider's order fully authorizes CRNA anesthesia practice.
- Reduces administrative ambiguity. Removes uncertainty regarding whether CRNAs must operate under separate standardized procedures to administer anesthesia or select related medications.
- Aligns law with practice. Reflects the established continuum of anesthesia care already recognized by the Board of Registered Nursing and national professional standards.
Implementation and Compliance Considerations
Effective Date: January 1, 2026[1]
Recommended Next Steps for Facilities and CRNAs:
- Update anesthesia bylaws, privileging criteria, and documentation to incorporate the statutory definition of anesthesia services and recognize the authorizing effect of patient-specific orders.
- Maintain required supervision, committee review, and peer-evaluation processes.
- Provide targeted training for anesthesia and perioperative staff on the clarified statutory framework and its relationship with existing facility policies.
Footnote
1. See Cal. Const. art. IV, § 8(c)(1); see also Cal. Gov. Code § 9600(a).
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