Prescribed alternatives

Last updated on December 2, 2025

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

B.C. has mandated that all PAs must be consumed under the direct supervision of a health professional. The policy supports efforts to ensure these medications are used by their intended recipients as part of harm reduction strategies, and to prevent diversion to illicit markets. This applies to benzodiazepines and stimulants when used for PA, as well as opioids. The policy change 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, which outlines updated witness requirements for clients taking prescribed alternatives (PA).

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 or educational obligations, who may be permitted unwitnessed doses during work or school 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. Clinicians should consult BCCSU's 24/7 line for case-based support at 778-945-7619.

Pharmacy witness fees

The Ministry is working on a new payment system to pay pharmacies a fee for witnessing doses of PAs. Pharmacies can expect to receive payments in spring 2026, once the new payment system is ready to be implemented. Pharmacies will receive retroactive payments for witnessed doses of PA recorded in PharmaNet from June 18, 2025, onwards.

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. 

To be eligible for a PA witness fee, the dose must be:

  • An eligible PA drug from the table below
  • Witnessed oral ingestion or topical application on June 18, 2025, or later
  • Witnessed by a pharmacist in a community pharmacy according to provincial policy instructions and BCCSU protocols

PharmaCare will pay a maximum number of daily witness fees per client per day, as detailed on the drug list below. Witnessed doses must be notated with the PharmaNet intervention code "VS – Other outcome or intervention".

Claims must be submitted on the day the PA was dispensed and witnessed. 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. 

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 12 ER (e.g., M-Elson) $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
Methyphenidate CSBP 40-60 (e.g, Biphentin) $4 2
Methyphenidate Tablet ER 24h (e.g., Concerta) $4 1
Methyphenidate Tablet $4 3
Methyphenidate Tablet ER (e.g., Ritalin SR) $4 2

PharmaNet entry procedures

If there are no instructions about witnessing on the prescription, pharmacists must confirm with the prescriber before dispensing.

"SA" notation

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 not written in the original prescription, but there is reason to believe it is a PA prescription based on dispense history or other sources of information, the pharmacist should confirm with the prescriber that it is intended as PA. If so, the pharmacist should denote it as a PA prescription by inputting the associated intervention codes (below).

Witness logs

As of December 4, pharmacies witnessing PA must record each witnessed interaction in a witness accountability log. The log must include:

  • The date and time the drug was dispensed and witnessed
  • The prescription's transaction number
  • The quantity of the drug ingested and witnessed
  • The quantity provided as unwitnessed doses ("carries"), if any
  • The total quantity dispensed
  • The signature or initials of the dispensing pharmacist, and the signature of the client

Any fees associated with the dispense, including the witness fee, will be recovered if the log is not filled out correctly.

Recording PAs – witnessed

To support tracking of pharmacy services provided and Ministry recordkeeping, when entering witnessed consumption of PAs in PharmaNet, pharmacists should enter:
  • 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.

Recording PAs – non-witnessed (aka "carries" or take-home doses)

When a prescriber has clearly indicated a dose is not to be witnessed, enter:

  • SA – Prescribed safer alternative

If dispensing non-witnessed PAs more than once in a day, enter both:

  • SA – Prescribed safer alternative, AND
  • UF – Patient gave adequate explanation, Rx filled as written

Recording PAs – both witnessed and non-witnessed

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).

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
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 
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
 

Clinicians should consult the BCCSU’s 24/7 Line (778-945-7619) for case-based support.