I fully support a change in 18VAC110-20-490 section 5.  The current process takes 40  to 60 man-hours each month to complete all audits required and does not identify possible diversion effectively.

Using a reconciliation software program similar to RxAuditor, Pandora or others - a 24-hour audit of all transactions for controlled substances becomes obsolete.  These programs show statistical analysis over a month.  Using the process set by the regulation, identifying possible diversion was hit or miss.  Using RxAuditor, we can identify specific employees to audit based on peer-to-peer comparisions of use for their unit. This is a more effective use of the auditors time and addresses the diversion concerns.

Combine this with a facility using their ADC on "profile" mode, where a pharmacist must enter the order into the hospital's Clinical System before the drug is available to the nurse (order verification).  The use of Controlled Substance perpetual inventory management systems (i.e. CII-Safe, NarcStation, etc) where issues remain open until appropriately stocked into the receiving ADC (narrowing the focus of audits for issue/restock).  Overrides and Open Discrepancies may be reviewed easily and in a more timely manner. 

Thank you for your consideration.