I am in full support to change 18VAC110-20-490 section 5.  The current process takes valuable pharmacist man-hours each month that could be used to promote patient care.

The manual audits required are not the most effective or efficient way to identify possible diversion. Using a reconciliation software program (i.e. RxAuditor, Pandora) quickly provides an audit of all transactions for controlled substances. These programs show statistical analysis for each user and medication. Using such a system, pharmacies can identify specific employees to audit based on peer-to-peer comparisons.

Thank you for your consideration.