Evidence status: CURRENT BINDING STATEWIDE RULE. Vermont’s Department of Health requires a signed Controlled Substance Treatment Agreement before prescribing opioids for chronic pain.
Current rule
The Rule Governing the Prescribing of Opioids for Pain is effective April 1, 2024. It applies to Schedule II, III, and IV opioids prescribed for pain.
Chronic-pain agreement requirement
For chronic pain, defined by the rule as pain lasting longer than 90 consecutive days, the prescriber must receive and place in the medical record a signed Controlled Substance Treatment Agreement from the patient or legal representative.
Required agreement subjects
The agreement must include:
- Functional goals for treatment.
- Dispensing-pharmacy choice.
- Safe storage of medication.
- Safe disposal of medication.
The rule also allows the prescriber to add other requirements, including directly observed urine drug testing and pill counts, when used to reasonably and timely identify misuse.
Signed informed consent is separate
Vermont also requires signed informed consent before prescribing an opioid. The consent addresses risks including misuse, addiction, tolerance, respiratory depression, accidental exposure, neonatal withdrawal, and overdose risk when opioids are combined with alcohol or other psychoactive medications.
Exemptions
The chronic-pain section does not apply to chronic pain associated with cancer or cancer treatment and does not apply to patients in nursing homes. Hospice and hospice-eligible patients are governed by separate provisions.
Primary sources
- Vermont Department of Health — Rule Governing the Prescribing of Opioids for Pain
- Vermont Department of Health — Opioid Prescribing and MOUD
Reviewed: October 4, 2026.
Evidence boundary: Vermont mandates the signed agreement and its core subjects. Additional prescriber-created testing, pill-count, refill, conduct, or dismissal provisions must be classified separately unless another authority independently requires them.