I fully support a change in 18VAC110-20-490 section 5.  My facility has 72 unique ADC locations and requires a full time pharmacy employee to perform the 24 hour audits. These audits are not an effective method of identifying potential diversion as the audit is a 24 hour snap shot within a months worth of activity.

I currently utilize a program that does statistical analysis on controlled substance activity over a 30 day period.  This statistical report identifies specific employees for each unique location and compares activity peer-to-peer.  This is an efficient and effective process and reviews a broader time frame to identify potential diversion.

In addition, orders are reviewed by a pharmacist and entered into the electronic MAR prior to the end user having access to the medication.  The use of a Controlled Substance perpetual inventory management system provides additional safe guards for potential diversion review.

I appreciate your consideration of this petition.