Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
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7/11/11  8:35 am
Commenter: Brian Caruth, Virginia Hospital Center

Supporting Change to Automated Dispensing Cabinet Regulations
I support a change in 18VAC110-20-490 section 5. My hospital currently performs all required 24 hour audits on ADC’s AND uses a statistical analysis program to evaluate controlled substance activity. Compared to the 24 hour audits, the statistical analysis software produces more data and detailed actionable information to identify potential diversion. In addition to identifying potential diversion, the statistical analysis software also provides a level of reassurance that employees ARE properly accessing and accounting for controlled substances.
It appears that other institution currently employ both 24 hour audits of ADC’s and statistical analysis programs. The comprehensive data sets produced by the statistical analysis programs provide more value when compared to 24 hour audits of ADC’s.  Better alignment of Pharmacy auditing responsibilities with Board requirements would likely result with the proposed regulatory changes to 18VAC110-20-490 section 5.
CommentID: 17701