SecProbe.io

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Mail Stop 6010

       August 26, 2005

Mr. Michael Branca
Vice President and Chief Financial Officer
MTS Medication Technologies, Inc.
2003 Gandy Boulevard North, Suite 800
St. Petersburg, Florida 33702

	RE:	MTS Medication Technologies, Inc.
		Form 10-K for the period ending March 31, 2005
		Form 8-K dated July 27, 2005
		Filed July 27, 2005
		File No. 1-31578

Dear Mr. Branca:

	We have reviewed your response dated August 22, 2005 and have
the following comments.  We have limited our review to matters
related to the issues raised in our comments and we will make no
further review of your documents. In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

General
1. We note that your response letter dated August 22, 2005 did not
include a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

Please include this statement in your next response.

Form 10-Q filed August 10, 2005

Item 4 Controls and Procedures, page 18

2. We note your statement that the chief executive officer and
chief
financial officer have concluded that the company`s disclosure
controls and procedures are effective "subject to the limitations
noted below."  Given the limitations noted, it remains unclear
whether your chief executive officer and chief financial officer
have
concluded that your disclosure controls and procedures are
effective.
Please revise your disclosure to state, in clear and unqualified
language, the conclusions reached by your chief executive officer
and
your chief financial officer on the effectiveness of your
disclosure
controls and procedures.  For example, if true, you can state that
your disclosure controls and procedures are effective including
consideration of the limitations, so long as you provide
appropriate
disclosure explaining how the disclosure controls and procedures
were
determined to be effective in light of the limitations.  Or, if
true,
you can state that given the limitations, your disclosure controls
and procedures are not effective.  You should not, however, state
the
conclusion in your current disclosure, which appears to state that
your disclosure controls and procedures are effective except to
the
extent they are not effective.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested  information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Dennis Hult, Staff Accountant, at (202) 551-
3618 or me at (202) 551-3554 regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Martin F. James, Senior Assistant Chief Accountant, at
(202)
551-3671.

								Sincerely,

								Angela J. Crane
								Accounting Branch Chief
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Michael Branca
MTS Medication Technologies, Inc.
August 26, 2005
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