Evidence status: CURRENT IMPLEMENTATION AND CONTINUITY-OF-CARE RECORD. Pennsylvania’s Act 112 framework distinguishes new treatment courses from pre-existing treatment plans and allows a prescriber to end an agreement when it is no longer necessary.

Existing plans were not retroactively rewritten

Department of Health guidance states that Act 112 does not require a new treatment agreement for an opioid treatment plan that was already established before November 27, 2019.

Agreement termination

Under 28 Pa. Code §26.4, a prescriber may terminate a treatment agreement when the prescriber reasonably believes, based on professional standards, that the agreement is no longer necessary.

Documentation and notice

When an agreement is terminated, the prescriber must document the reason in the patient’s medical record and inform the patient.

Continuity of care

When necessary, the temporary regulation directs the prescriber to work with the patient, to the fullest extent possible, to ensure continuity of care consistent with Pennsylvania’s professional conduct rules.

State guidance on discontinuation risk

Pennsylvania’s Patient Advocacy Program warns that rapid tapering or sudden discontinuation in physically dependent patients can cause withdrawal, worsened pain, serious psychological distress, and increased overdose risk if patients turn to illicit sources. The Department directs providers toward safer tapering, communication, and referral resources.

Why this matters to Contract for Care

Agreement termination and opioid-therapy discontinuation are related but not identical. Pennsylvania’s framework does not turn every agreement problem into a single automatic result; documentation, communication, professional judgment, and continuity remain part of the record.

Primary sources

• 28 Pa. Code §26.4
• Act 112 Considerations for Prescribers
• Patient Advocacy Program — Treatment Agreement Considerations

Reviewed: October 4, 2026.