I am in support of modifications to 18 VAC 110-20.  The software upgrades that are available to monitor expiration dates as well as statistically analyze individual users if far superior to antiquated manual methods of audit and much more dependable in providing the evidence required to control narcotic misuse and diversion.  The shift in man-hours and staffing to more valuable clinical functions would further support the true role of pharmacist and pharmacy technicians in the healthcare environment.

Thank you for considering modifications to this regulation.