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Witnessing doses of opioid agonist therapy (OAT)

December 8, 2021

Pharmacists or healthcare professionals acting within their scope of practice delegated by the pharmacist must witness, confirm, and document ingestion of witnessed-dose OAT medications.

For individuals prescribed opioid agonist therapy (OAT), daily witnessed administration by a pharmacist may be required as part of treatment.

ACP’s pharmacy practice consultants have noticed that some pharmacists are not witnessing OAT ingestion as described in ACP’s OAT guidelines. In some cases, pharmacists are instead using delivery drivers to deliver the OAT medication and witness an individual ingesting it. The driver then takes photos or a video of the patient ingesting the medication to be viewed by the pharmacist. In other cases, the OAT medications are delivered to a regulated health professional whose scope of practice does not include administering drugs (e.g., social worker), or an unregulated healthcare provider.

As indicated in sections 5.1, 6.4.2, 8.8.2, and 9.1.3 of the OAT guidelines, a pharmacist must assess the patient each time they dispense OAT. Section 8.8.3 indicates that the pharmacist must witness and confirm the ingestion, and document the event, the assessment, and the monitoring plan in the patient record.

Section 10.3 of the OAT guidelines indicates that, when appropriate, a pharmacist may delegate another health professional who has the scope of practice, competence, and training to witness OAT medication ingestion if off-site administration is needed. Should off-site administration be deemed necessary, pharmacists must use a reliable, secure, and confidential method of transportation and follow up to ensure that the dose has been delivered untampered.

If the patient receiving OAT is isolating due to COVID-19, virtual care is temporarily authorized by the ACP COVID-19 Guidance for Pharmacists and Pharmacy Technicians. For witnessed ingestion of OAT medications with these patients, refer to the Temporary guidance for opioid agonist therapy and ensure the following: 

  • For patients who are self-isolating, alternative measures to support witnessed dosing should be considered, including approved virtual communication methods or home delivery if the requirements of physical distancing are maintained.
  • Regardless of the method used, the dose must be witnessed by a pharmacist or other authorized health care professional working in collaboration with the pharmacist. It is not appropriate for a dose to be witnessed by a pharmacy technician, pharmacy assistant, or unregulated delivery staff.

All pharmacy teams providing any type of virtual care should review ACP’s Providing virtual care to patients guidelines.

All pharmacists who provide OAT to individuals should review both the Standards of Practice for Pharmacists and Pharmacy Technicians and the OAT Guidelines. Meeting the standards and guidelines—including conducting assessments with each treatment—helps ensure that individuals receiving OAT receive safe and appropriate care.


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