Evidence status: CURRENT PRESCRIBER-SCOPE AND ENFORCEMENT RECORD. Pennsylvania’s Act 112 framework applies broadly to Pennsylvania prescribers rather than to physicians alone, and violations are enforced through the prescriber’s professional licensing system.
Who is covered
Act 112 uses the definition of “prescriber” from Pennsylvania’s ABC-MAP prescription-monitoring law. The Department of Health’s current FAQ summarizes the rule broadly: any Pennsylvania prescriber and patient beginning a new opioid treatment for chronic pain must meet the Act 112 requirements.
Professional enforcement
35 Pa.C.S. §52B04 states that a prescriber’s violation of the chapter is subject to sanctions under the prescriber’s professional practice act and by the appropriate licensing board.
Different boards, one statutory floor
Physicians, osteopathic physicians, advanced-practice clinicians and other authorized prescribers may be regulated by different professional boards, but Act 112’s treatment-agreement requirement is a statewide statutory floor when its conditions are met.
State Board of Medicine
For physicians regulated by the State Board of Medicine, the current Board Chair is Donald M. Yealy, MD. The Board maintains separate controlled-substance standards and may impose discipline within its jurisdiction, but the Board did not create Act 112 and cannot repeal the statutory agreement mandate.
Do not confuse other “written agreements”
Pennsylvania professional licensing law also uses the phrase “written agreement” for physician-assistant supervision and other professional arrangements. Those documents are legally separate from the chronic-pain opioid treatment agreement created by Act 112.
Primary sources
- 35 Pa.C.S. Chapter 52B
- Act 112 Questions and Answers
- Pennsylvania State Board of Medicine — Current Members
Reviewed: October 4, 2026.
Evidence boundary: The statutory requirement is statewide; enforcement occurs through the professional licensing structure applicable to the individual prescriber.