8.16 Prescribed Alternatives Witnessing Fee

General policy description

PharmaCare will pay pharmacies a fee for each eligible dose of witnessed PA medications up to a daily maximum. Fee amounts are based on the type of medication.

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
• Procedures
• Documentation
• Dispensing exclusively unwitnessed PAs
• Resources

Eligibility

Prescribers are requested to write “SA” on all PA prescriptions (for “safer alternative”). They must not use "SA" for opioid, stimulant or benzodiazepine drugs when they are prescribed for non-PA indications.

To be eligible for a PA witness fee:

• "SA" must be written on the prescription by the prescriber*
• The drug must be a PA drug from the table below
• The drug must be ingested orally or applied topically**

*If "SA" is not written in the original prescription, and the pharmacist has confirmed with the prescriber that it is intended as PA, the pharmacist should denote it as a PA prescription by inputting the associated intervention codes.

**A fentanyl patch exchange regimen where a patient exchanges their used fentanyl patches for new fentanyl patches constitutes witnessed dosing.

PAs witnessed in a community pharmacy must be witnessed by a pharmacist.

PAs witnessed as part of a delivery or outreach model of care (i.e., delivered directly to the client) must be witnessed by a regulated health professional (e.g., pharmacist, nurse).

PAs witnessed in a clinic by a regulated health professional are not eligible for the PharmaCare witness fee.

PharmaCare will pay up to a maximum number of witness fees per client per day, as detailed on the PA drug list below.

PA witness fees are subject to audit and recovery. Refer to the PharmaCare Policy Manual, Section 10.1: Audit Policies for details.

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
	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. 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, those four doses should not be processed all together before the patient arrives.

Claim reversals will not be paid. Claims submitted on a different date than the actual dispense will not be paid and/or will be subject to recovery. 

PAs witnessed in a clinic

When dispensing PAs to be witnessed in a 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 that takes place in a clinic.

Note: Clinics will update a patient record on PharmaNet when they witness doses; refer to TMUs in PharmaNet for IIMOAT (PDF, 166KB) for further information.

PAs witnessed in a community pharmacy or delivered to a client

Claims for all witnessed doses of PAs witnessed 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.

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 (if dose was witnessed in a community pharmacy) or witnessing regulated health professional (if dose was delivered on behalf of the pharmacist as part of a delivery or outreach model of care)

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 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.

Resources

•  Access to Prescribed Alternatives in British Columbia (PDF, 304KB)
• Clinical Bulletin: Updated Prescribed Alternatives Policy–Implications for Clinical Practice (PDF, 2.6MB)