Evidence status: CURRENT PDMP LAW AND STATE CHRONIC-PAIN GUIDANCE. Pennsylvania’s Prescription Drug Monitoring Program and opioid-prescribing guidance operate alongside Act 112 but are legally distinct from the treatment agreement itself.

When prescribers must query the PDMP

Pennsylvania requires prescribers to query the PA PDMP:

  • The first time a patient is prescribed a controlled substance by that prescriber.
  • Each time a patient is prescribed an opioid drug product or benzodiazepine.
  • When the prescriber has reason to believe the patient may be abusing or diverting drugs.

PDMP use continues even when an agreement exists

The Department’s current Q&A expressly states that a prescriber must still query the PDMP every time an opioid or benzodiazepine is prescribed even when the patient has signed a controlled-substance agreement and is seen regularly.

Chronic-pain prescribing guidance

Pennsylvania’s evidence-based chronic-pain prescribing tools recommend establishing measurable treatment goals, using opioids only when expected benefits outweigh risks, obtaining a signed patient-provider agreement, reassessing treatment early, reviewing the PDMP, and using monitoring practices such as urine testing and pill counts according to risk.

Guidance is not identical to Act 112

The prescribing guidelines include clinical recommendations that may go beyond Act 112’s statutory minimum. Recommendations on reassessment intervals, dose strategy, pill counts, naloxone, and risk-based testing should therefore be classified as guidance unless another binding law or rule independently requires them.

Primary sources

Reviewed: October 4, 2026.

Evidence boundary: PDMP obligations and clinical guidelines are separate evidence layers. They should not be silently converted into additional mandatory agreement clauses.