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August 22, 2005

VIA EDGAR

Securities and Exchange
Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549

Attention: Angela J. Crane, Branch Chief

     Re:
MTS Medication Technologies, Inc.
               Form 10-K for the
fiscal year ended March 31, 2005 Form 8-K dated July 27, 2005

File No. 1-31578

Dear Ms. Crane:

        On
behalf of MTS Medication Technologies, Inc. (“MTS”), I am writing in response to
the comments set forth in your letter addressed to the Company dated August 11, 2005 (the
“Comment Letter”). For your convenience, the Staff’s comments are repeated
below, with MTS’s response to each comment set forth immediately following such
comment.

Form 10-K for the fiscal
year ended March 31, 2005

Item 9A.  Controls and
Procedures, page 21

          1.

          We note your disclosure that your “CEO and CFO concluded that the (y)our
          disclosure controls and procedures are designed,  and are effective, to
          ensure that information required to be disclosed in reports we file and submit
          under the Exchange Act is recorded, processed, summarized and reported
          as when required.” Revise future filings to clarify, if true, that your
          officers concluded that your disclosure controls and procedures are
          also effective to ensure that information required to be disclosed in the reports that
          you file or submit under the Exchange Act is accumulated and communicated to your management,
          including your chief executive officer and chief financial officer, to allow timely decisions
          regarding required disclosure. See Exchange Act Rule 13a-15(e).

Response to Comment 1:

MTS acknowledges the Staff’s
comment and confirms that it will make the requested changes in future filings.

Form 8-K, filed July 27,
2005

               2.

               We note that you present your non-GAAP measures in the form of pro forma
               statements of operations. That format may be  confusing to investors as
               it also reflects several non-GAAP measures, including pro forma operating
               profit, pro forma cost  and expenses, pro forma income (loss) before
               income taxes and pro forma net income (loss), which have not been identified
                and described to investors. In addition, you have not explained your
               purpose for presenting non-GAAP operational measures  that are the same
               as the GAAP amounts. Please note that Instruction 2 to Item 2.02 of Form 8-K
               requires that when  furnishing information under this item you must
               provide all the disclosures required by paragraph (e)(1)(i) of Item 10 of
               Regulation S-K and Question 8 of the FAQ Regarding the Use of Non-GAAP
               Financial Measures dated June 13, 2003, including a  reconciliation to
               the directly comparable GAAP measure for each non-GAAP measure presented.

               a.

               To eliminate investor confusion, please remove the non-GAAP statement of
               operation format from future filings and instead  only disclose those
               non-GAAP measures used by management with the appropriate reconciliations.

               b.

               Otherwise, confirm that you will revise your Forms 8-K in future periods to
               provide all the disclosures required by Item  10(e)(1)(i) of Regulation
               S-K for each non-GAAP measure presented in the statement, and provide us
               with a sample.

Response to Comment 2:

MTS acknowledges the Staff’s
comment and confirms that it will make the requested changes in future filings.

2

          3.

          In addition, we note that you refer to your non-GAAP information as “pro
          forma” results. The pro forma terminology has very  specific meaning
          in accounting literature, as indicated by Article 11 of Regulation S-X. In
          future filings, please revise  your presentation to omit the pro forma
          terminology when referring to your non-GAAP information.

Response to Comment 3:

MTS acknowledges the Staff’s
comment and confirms that, in future filings, it will refrain from using the term
“pro forma” when referring to non-GAAP information.

     *        *        *

        Please
direct any questions or comments regarding this letter to the undersigned at 813-227-8500
or to Michael Branca, MTS’s Chief Financial Officer at 727-576-6311.

     Very truly yours,

     HOLLAND & KNIGHT LLP

     /s/ Bob Grammig

     Robert J. Grammig

cc:      Mr. Todd E. Siegel, Chief
Executive Officer, MTS Medication Technologies, Inc.

Mr. Michael Branca, Chief Financial Officer, MTS Medication Technologies, Inc.

     Mr. Stanley I. Levy, Partner, Grant Thornton, LLP