Prescribed alternatives

B.C.’s prescribed alternatives (PA) program oversees prescribing and provision of regulated, pharmaceutical-grade medications of known concentration to people at high risk of harm from the unregulated drug supply.

On this page:

• Witnessed dosing
• Pharmacy witness fees
• PharmaNet entry procedures
• Witness accountability logs

Witnessed dosing

In B.C., all prescribed alternatives (PAs) must be consumed under the direct supervision of a health professional. The requirement helps ensure these medications are used by their intended recipients as part of harm reduction strategies and help prevent diversion to illicit markets. It applies to benzodiazepines and stimulants when used for PA, as well as opioids. It does not apply to opioid agonist treatment (OAT).

On December 2, 2025, the Ministry of Health released the Access to Prescribed Alternatives in British Columbia: Policy Direction (PDF, 304KB), which includes PA witnessing requirements. To help clinicians understand the new policy direction, the BC Centre on Substance Use (BCCSU) released Updated Prescribed Alternatives Policy—Implications for Clinical Practice (PDF, 2.6MB).

The policy direction requires that all clients who have a PA prescription must transition to witnessed dosing by December 30, 2025. This builds on previous requirements for witnessed dosing for new PA clients, as described in the February 2025 PharmaCare Newsletter (PDF, 448KB). 

There are limited exemptions to witnessed dosing for clients in exceptional circumstances. These include:

• Clients from rural, remote and Indigenous communities who do not have routine access to a pharmacy
• Clients with employment obligations, who may be permitted unwitnessed doses during work hours when they have achieved clinical stability
• Clients titrating onto opioid agonist treatment (OAT)

Full details on exemptions to witnessed dosing can be found in the new policy direction. For case-based support, clinicians should consult BCCSU's 24/7 line at 778-945-7619.

Pharmacy witness fees

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

Pharmacies can expect to receive payments in Spring 2026, once a payment system is implemented. Pharmacies will receive retroactive payments for witnessed doses of PA recorded in PharmaNet from June 18, 2025, onwards.

Pharmacists and other regulated health professionals must witness according to Access to Prescribed Alternatives in British Columbia: Policy Direction (PDF, 304KB) and the BCCSU’s Clinical Bulletin: Updated Prescribed Alternatives Policy–Implications for Clinical Practice (PDF, 2.6MB).

To be eligible for a PA witness fee:

• “SA” must be written on the prescription by the prescriber. If “SA” is missing, pharmacist can confirm with prescriber and enter associated code in PharmaNet
• The drug must be on the PA drug list
• The drug must be ingested orally or applied topically (includes applying/removing fentanyl patch)

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.

For full details on which witnessed doses of PAs are eligible for the PA witness fee, refer to the PharmaCare Policy Manual, Section 8.16: Prescribed Alternatives Witnessing Fee. 

PharmaNet entry procedures

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. If “SA” is missing, pharmacists must confirm with the prescriber before dispensing.

Claims must be submitted on the day PA is dispensed and witnessed. Multiple daily doses for one patient should not be processed in PharmaNet at the same time. For example, if a patient is prescribed four doses of hydromorphone daily, those four doses should not be entered together, i.e., 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.

Intervention codes

All doses of PAs witnessed in a community pharmacy or delivered to a client must be notated with “VS” intervention code.

All non-witnessed doses of PAs dispensed in a community pharmacy must be notated with “SA” intervention code (for “safer alternative”).

When dispensing PAs to be witnessed in a clinic, pharmacies must use the new 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.

For full PharmaNet entry instructions, refer to the PharmaCare Policy Manual, Section 8.16: Prescribed Alternatives Witnessing Fee.