I fully support a change in 18VAC110-20-490 section 5. My facility has 43 unique ADC locations. The manual audits are not an effective method of identifying potential diversion as the audit is a 24 hour snap shot within a 30 day period of activity.

We current utilize a program that completes statistical analysis on controlled substance activity over a 30 day period. This statistical report identifies specific exmployees for each unique location and compares peer-to-peer activity. This is an efficient, effective and more thorough process and reviews a broader time frame to identify potential diversions.

Enhanced further is the use of an ADC in "profile" mode, where a pharmacist must enter the medication order into the hospital's clinical informatics system before the drug is available to the nurse in the ADC. The use of controlled substance perpetual inventory management systems such as CII Safe or NarcStation where issues remain open until appropriately stocked into the receivng ADC also support a more improved process over a manual review. Technology is available to meet the intent of the regulation.

I believe the combination of profile dispensing ADCs, automated controlled substance inventory systems and controlled substance statistical analysis software provide a much greater diversion tracking system than the current regulations of a manual review over a limited period of time.

Thank your for considering modifications to this regulation.