I see no disadvantages to the proposed change to the filing requirements for "on hold" prescriptions.  As long as the original date written is captured at the time of order entry and a prescription number is assigned (as pharmacy computer systems do) the prescription hard copy would be readily retrievable.  Filing "on hold" prescriptions with active prescriptions will increase the security of the hard copy prescription and avoid misplacement.  I fully support the regulatory changes to practice.   

I fully support the proposed changes.  Many doctors offices will e-scribe or hand write prescriptions for patients with the intent to put them on-hold.  The proposed changes will eliminate excessive steps that could lead to an increase in filing errors.  

Allowing on-hold prescriptions to be entered the date they are received in the pharmacy, allowing correctness of data entered to be completed by pharmacist on duty, and allowing pharmacist on duty when dispensed to prospectively review would prevent possible filing errors or misplacement of an actual prescription. It will also allow someone performing remote dispensing to determine if prescriptions are on file at the pharmacy. I think this will make workflow simpler and cleaner without pharmacies having to keep track of paper prescriptions.

When a prescription is presented to the pharmacist to be data entered into the computer for on hold purposes, it is entered with the same "accuracy" as a prescription that is to be filled at that moment.  It is then assigned a prescription number and placed in hard copy files with other prescriptions. Most computer systems now have scanning capability so that when an on hold prescription request is made, whatever the date, the scanned copy of the original hard copy prescription can be reviewed by the pharmacist at any point in time.  To "renew" an on hold prescription for the sole purpose of getting it in chronologic order makes no sense, uses valuable time and increases the opportunity for errors.  

The original on hold prescription is assigned a number and can be retrieved anyway.  I cannot see any advantages for having to "renew" on hold prescriptions, but I can see plenty of disadvantages.