8.16 Prescribed Alternatives Witnessing Fee
Last updated on August 10, 2026General policy description
PharmaCare pays pharmacies a fee for witnessing eligible doses of prescribed alternatives (PAs). The fee per dose depends on the type of medication. Pharmacies can claim up to $33 in PA Witnessing Fees per patient per day.
Pharmacists and other regulated health professionals must witness according to instructions described in the provincial policy Access to Prescribed Alternatives in British Columbia (PDF, 304KB) and the BC Centre on Substance Use (BCCSU) Clinical Bulletin: Updated Prescribed Alternatives Policy–Implications for Clinical Practice (PDF, 2.6MB).
Policy details
Eligibility
To be eligible for the PA witness fee, witnessing must be in person in a pharmacy or during direct delivery to a client. PharmaCare does not pay a fee for virtual witnessing of PA, i.e., over videoconferencing.
For pharmacies to be eligible for the PA witness fee:
- In a community pharmacy: PA witnessing must be in person by a pharmacist
- As part of an outreach model of care with direct delivery to the client: PA witnessing must be in person by a B.C. regulated health professional (e.g., pharmacist, nurse)
- "SA" (for safer alternative) must be written by the prescriber on the prescription, or the pharmacist may confirm with the prescriber that the prescription is intended as PA and then enter the relevant intervention code in PharmaNet (refer to Procedures for codes)
- The drug must be a PA drug from the table below
- The drug must be ingested orally or applied topically. This includes pharmacist-led removal and application of a fentanyl patch, or exchange of a used fentanyl patch for new fentanyl patches provided by a pharmacist
PharmaCare will pay a maximum number of witness fees per client per day, as detailed on the PA drug list below, up to a total maximum of $33 per client per day.
PA witness fees are subject to audit and recovery. Refer to the PharmaCare Policy Manual, Section 10.1: Audit Policies
| PA drugs eligible for a witness fee – includes all dosages | ||||
|---|---|---|---|---|
| Drug class | Chemical type | Formulation type | Witness fee amount | Daily maximum number of fees |
| Opioid | Fentanyl | Patch | $10 | 1 |
| Fentanyl | Tablet (e.g., Fentora) | $7 | 3 | |
| Hydromorphone | Capsule 12h ER | $4 | 2 | |
| Hydromorphone | Tablet | $4 | 3 | |
| Hydromorphone | Syrup | $4 | 3 | |
| Morphine | Capsule 12h ER (e.g., M-Eslon) |
$4 | 2 | |
| Morphine | Tablet ER (e.g., MS Contin) | $4 | 2 | |
| Morphine | Syrup | $4 | 3 | |
| Morphine | IR capsule (e.g., M-Ediat) | $4 | 3 | |
| Morphine | Tablet | $4 | 3 | |
| Oxycodone | Tablet 12h ER (e.g., Oxyneo) | $4 | 2 | |
| Oxycodone | Tablet | $4 | 3 | |
| Benzodiazepine | Alprazolam, clobazam, clonazepam, diazepam, lorazepam, oxazepam | Tablet | $4 | 3 |
| Chlordiazepoxide | Capsule | $4 | 1 | |
| Lorazepam | Sublingual tablet | $4 | 3 | |
| Stimulant | Dextroamphetamine | Capsule ER (e.g., Dexedrine Spansule) | $4 | 2 |
| Dextroamphetamine | Tablet | $4 | 3 | |
| Dextroamphetamine | Capsule ER 24h (e.g., Adderall XR) | $4 | 1 | |
| Lisdexamfetamine | Capsule | $4 | 1 | |
| Methylphenidate | CSBP 40-60 (e.g, Biphentin) | $4 | 2 | |
| Methylphenidate | Tablet ER 24h (e.g., Concerta) | $4 | 1 | |
| Methylphenidate | Tablet | $4 | 3 | |
| Methylphenidate | Tablet ER (e.g., Ritalin SR) | $4 | 2 | |
Procedures
Submitting claims
Claims must be submitted on the day the PA was dispensed and witnessed. Claims submitted on a different date than the actual dispense will not be paid and/or will be subject to recovery.
Multiple daily doses for one patient should not be processed to PharmaNet at the same time. For example, if a patient is prescribed four doses of hydromorphone daily, each dose must be processed separately once the patient arrives for the dose.
Claim reversals will not be paid.
PAs witnessed in a community pharmacy or delivered to a client
Claims for all witnessed PA doses in a community pharmacy or delivered to a client must be notated with the PharmaNet intervention code “VS – Other outcome or intervention”.
If dispensing more than once in a day, enter both:
- VS – Other outcome or intervention, AND
- UF – Patient gave adequate explanation, Rx filled as written
The VS code must be entered for each instance of witnessed consumption of PA. For example, if hydromorphone 8 mg is witnessed three times daily at the pharmacy, there should be three claims submitted using the appropriate intervention codes.
Pharmacies are encouraged to indicate the frequency of witnessed ingestion in the SIG field.
When dispensing a PA prescription that includes both witnessed and non-witnessed doses, enter both:
- VS – Other outcome or intervention, AND
- SA – Prescribed safer alternative
Record frequency of witnessed and non-witnessed doses in brackets at the end of the SIG field (e.g., witness 3 times/day). The field limit is 80 characters only; long entries are cut short. Please use numerals ("3" instead of "three).
For instructions on how to record exclusively unwitnessed doses of PAs, refer to Dispensing exclusively unwitnessed PAs.
Dispensing PAs to be witnessed in a health clinic
When dispensing PAs to be witnessed in a community health clinic, pharmacies must use the PharmaNet intervention code “AW – PA Sent for witnessing by other health care professional”. PharmaCare does not pay pharmacies for witnessing in a clinic.
Clinics will update a patient record on PharmaNet when they witness doses. Refer to TMUs in PharmaNet for IIMOAT (PDF, 166KB) for further information.
| Prescribed alternative scenario | Intervention code to use | |
|---|---|---|
| Witnessed | First interaction of the day: VS Subsequent interactions same day: VS and UF |
|
| Witnessed with carries | First interaction of the day: VS and SA Subsequent interactions same day: VS and UF |
|
| Not witnessed | First dispense of the day: SA Subsequent dispenses same day: SA and UF |
|
| Witnessed in a clinic | Witnessed in a clinic: AW | |
| Example 1 | ||||
|---|---|---|---|---|
| RX: Hydromorphone 8 mg tablets – 1-3 tablets q1h as needed up to 14 tablets provided daily (SA witness) | ||||
| Dispense # in day | SIG/Directions | Quantity to PNet | Intervention codes | |
| First | Take 1-3 tabs/hr as directed, max 14 tabs/day (Witness) | 3 | VS | |
| Second | Take 1-3 tabs/hr as directed, max 14 tabs/day (Witness) | 3 | VS and UF | |
| Third | Take 1-3 tabs/hr as directed, max 14 tabs/day (Witness) | 3 | VS and UF | |
| Example 2 | ||||
|---|---|---|---|---|
| RX: Hydromorphone 8 mg tablets – 1-3 tablets q1h as needed up to 14 tablets provided daily. (SA witness first dose with remainder as carry) | ||||
| Dispense # in day | SIG/Directions | Quantity to PNet | Intervention codes | |
| First | Take 1-3 tabs/hr as directed, max 14 tabs/day (Witness 1 time daily) | 14 | VS and SA | |
| Example 3 | ||||
|---|---|---|---|---|
| RX: Hydromorphone 8 mg tablets – 1-3 tablets q1h as needed up to 14 tablets provided daily.(SA witness twice daily with remainder as carry) | ||||
| Dispense # in day | SIG/Directions | Quantity to PNet | Intervention codes | |
| First | Take 1-3 tabs/hr as directed, max 14 tabs/day(Witness 2 times daily) | 7 | VS and SA | |
| Second | Take 1-3 tabs/hr as directed, max 14 tabs/day(Witness 2 times daily) | 7 | VS and UF | |
Documentation
Witness accountability logs
As of December 4, 2025, each witnessed dose of PA must be recorded in a witness accountability log to claim the PharmaCare witness fee. The log must include:
- Date and time the drug was dispensed and witnessed
- Prescription or transaction number
- Quantity of the drug witnessed
- Quantity provided as unwitnessed doses (“carries”), if any
- Total quantity dispensed
- Signature of the client
- Signature or initials of the witnessing pharmacist (i.e., in pharmacy) or witnessing regulated health professional (delivery)
Any fees associated with the dispense, including the witness fee, will be recovered if the log is not filled out correctly.
The PA witness log is for PharmaCare auditing purposes and is not required for circumstances when PharmaCare does not pay any witness fees. This includes situations when:
- PAs are dispensed to a clinic for witnessing by a regulated health professional
- PA drugs are not eligible for the witness fee (i.e., drugs not listed on the PA drug list)
- Dispensing PAs where the prescriber has indicated that all doses are to be unwitnessed
Pharmacies can use existing methadone witness logs as a template with two modifications: add a column for marking the time when the PA dose was witnessed; and if deliveries are witnessed by a health professional other than a pharmacist, change “Pharmacists Initials” column to “Pharmacist or Health Professional Initials”.
Dispensing exclusively unwitnessed PAs
When a dispensing a PA prescription where the prescriber has clearly indicated that all doses are not to be witnessed, enter the PharmaNet intervention code “SA”.
If dispensing multiple non-witnessed doses of PA in a day, enter both the “SA” intervention code as well as the “UF – Patient gave adequate explanation, Rx filled as written” code.