I am in full support to change 18VAC110-20-490 section 5.  The current process takes valuable pharmacist time each month that could be used to promote "Best Practice".

The manual audits required are not the most effective or efficient way to identify possible diversion. It has been reasearched and shown that 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. This has moved diversion monitoring to a new level.

Thank you for your consideration.