Amend requirement for filing prescriptions to allow filing by date of initial dispensing or date of initial entry into pharmacy electronic record keeping system if such a system is employed by the pharmacy. The rationale for the request is that prescriptions are often placed into electronic systems for later dispensing, and retrieval and reassignment of the date is cumbersome and unnecessary and may promote errors in a patient's record.

The Board will receive public comment on the petition for rule-making and will review the petition and any comment at its meeting on September 8, 2010 to make decision on whether to initiate rule-making.

The Board denied the petition but agreed that it would like to query other states to determine policies and/or rules for entry of different dates into an electronic record keeping system. An informal opinion from the Drug Enforcement Administration states that, while not directly prohibited, the policy of "holding" a prescription in a computer for subsequent filling is not advisable and presents a diversion issue. The Board will revisit the request after additional information is obtained.