As a longterm Pharmacist who has worked in a variety of settings I have had the opportunity to explore the potential requirements of the monthly audits as currently outlined.

In the face of diverse checks and balances in place  provided by automated dispensing cabinets daily as well as services such as RX Auditor, I find the additional auditing currently in the regs duplicative and labor-intense. In addition reports such as Compare within PYXIS  as well as daily all station reports for controlled substances, we have capability to already do this process on a prospective basis in our daily functions.

I am happy to expand upon this should additional information be required.

I therefore respectively request consideration to consider this audit requirement a limitation rather than enhancement of monitoring in the face of current automation as we know it in pharmacy practice

Thank you for your consideration.