California · Contract for Care

California Contract for Care — State Requirements and Office Additions

A clinic’s agreement can contain legal duties, recommended safeguards and additional office conditions. California’s general Medical Board guidance strongly recommends pain agreements in specified long-term treatment circumstances. That recommendation must not be described as a blanket statute forcing every California pain patient to sign an agreement.

Agreements: a strong recommendation

The Medical Board’s July 2023 prescribing guidelines, page 9 recommend agreements when opioid therapy is expected to last more than three months or when beginning a chronic-pain opioid trial. Suggested topics include refill and replacement policies, periodic testing, one prescriber, pharmacy coordination and responsibilities on both sides. The one-pharmacy recommendation assumes the pharmacy can dispense the prescribed supply. The guidance does not prescribe every office’s exact deadlines, fees, disclosure authorizations or consequences.

The Board’s explanation of the revised guidelines emphasizes individualized clinical decisions and access to appropriate pain care. General guidance can inform professional standards without turning every example into mandatory contract language.

CURES: a legal prescriber duty

The Board’s current CURES guidance explains that covered practitioners must consult the database before first prescribing a Schedule II–V controlled substance, using the required recent-report window, and at least every six months during continuing treatment, unless an exception applies. The report window is the previous 24 hours or previous business day. Exceptions include specified facility, emergency, surgical, hospice and access-failure circumstances; supply and documentation limits differ. See Health and Safety Code §11165.4 and the Board’s exception list. Checking CURES is not the same as obtaining a patient’s blanket privacy waiver.

Risk discussions: a legal requirement with exceptions

Since January 1, 2025, SB 607 requires specified opioid-risk discussions before the first prescription in a course of treatment. Topics include addiction, overdose and dangerous combinations. The Board identifies exceptions for specified settings and circumstances, including some emergency, terminal-care and substance-use treatment. This is a duty to discuss risks; it does not establish a requirement to complete one particular clinic’s online course.

Naloxone: offer, education and exceptions

California’s naloxone requirements include an offer of an antagonist prescription in specified risk circumstances. The Board’s FAQ identifies 90 or more MME per day, concurrent benzodiazepines and increased opioid-overdose risk, and distinguishes an offer from a requirement that the patient accept it. Read it with the AB 714 clarification: the duties relate to prescribing opioids or benzodiazepines, include defined exceptions, and education need not be repeated if declined or received within the prior 24 months. A packet saying naloxone is available on request does not alone demonstrate whether the practice makes the required offers.

Dosage and treatment changes

The Board’s guidelines, page 10 call for documenting higher-dose decisions and explicitly caution against treating the 90-MME recommendation as a rigid prescribing ceiling. CDC’s 2022 guideline likewise supports individualized care, warns against abrupt discontinuation except for urgent safety circumstances, and advises against dismissing patients solely on a toxicology result. Guidance does not remove applicable laws or guarantee a prescription. Patients should discuss medication changes with their clinician.

Medical cannabis: an individual evaluation matters

The Board’s summary of AB 1954 explains that a physician and surgeon may not automatically deny treatment or medication to a qualified patient solely because of a THC-positive screen or reported medical-cannabis use without the required case-by-case evaluation and medical-significance determination. Recommended medical cannabis is not treated as an illicit substance in that evaluation. This is not a guarantee of any particular medication; the patient’s qualification and clinical circumstances matter.

Workers’ compensation and other distinct settings

California workers’ compensation uses a separate framework: 8 CCR §9792.24.4 incorporates the December 12, 2023 ACOEM opioid guideline into MTUS, effective March 27, 2024. DWC’s current MTUS index identifies the operative materials. Do not use an older 2017 document, or the general Medical Board agreement recommendation alone, as a complete workers’ compensation analysis. Federal, tribal, facility, payer and profession-specific requirements also need separate review.

Our comparison labels

• Legal requirement: an applicable law actually imposes the duty.
• Recommendation: guidance supports an approach but does not prescribe every exact term.
• Office condition: no identical requirement was located in the general authorities reviewed.
• Mixed or unresolved: the underlying safeguard has support, but the office chooses details or current application needs confirmation.

This is a scoped comparison, not an exhaustive opinion on every law that might affect a practice. Privacy, discrimination, abandonment and contract enforceability require their own factual and legal analysis.

Evidence limits: A public document does not confirm current signed use. “Office condition” identifies wording or implementation not established as an exact requirement by the authorities reviewed. It does not decide legality, enforceability or clinical necessity. Clinician profession, payer, treatment setting and other laws may change the analysis. Checked October 13, 2026.

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