OBRA 90 Requirements for Pharmacies

OBRA 90 mandates Medicaid programs require enrolled pharmacies to:

  • Perform prospective drug user review
  • Maintain a person’s medication records (profiles)
  • Counsel people on each new prescription

The Texas State Board of Pharmacy (TSBP) incorporated the OBRA 90 requirements into the pharmacy rules, adopted Dec. 1992.  Pharmacies in compliance with the TSBP rules are in compliance with the OBRA 90 Medicaid requirements.

Perform Prospective Drug User Review

At the time of dispensing a prescription drug order, the pharmacist must review the person’s medication record to identify:

  • Clinically significant drug-drug interactions
  • Therapeutic duplication
  • Drug-disease contraindication
  • Drug allergy interactions
  • Incorrect drug dosage or duration of drug treatment
  • Clinical abuse/misuse

Upon identifying any clinically significant conditions, situations, or items listed above, the pharmacist shall take appropriate steps to avoid or resolve the problem including consultation with the prescribing provider.

Medication Records

The pharmacist must make a reasonable effort to obtain and record, in the person’s medication record, the following information on the person presenting a prescription:

  • Full name of the person for whom the drug is prescribed
  • Address and telephone number of the person
  • The person’s age and/or date of birth
  • The person’s gender
  • Any known allergies, drug reactions, idiosyncrasies, and chronic conditions or disease states of the person and the identity of any other drugs currently being used by that person may relate to prospective drug review.
  • Pharmacist's comments relevant to the person’s drug therapy, including any other information unique to the specific person or drug.
  • A list of all prescription drug orders dispensed (new and refill) to the person by the pharmacy during the last two years. Such list shall contain the following information:
    • Date dispensed
    • Name, strength, and quantity of the drug dispensed
    • Prescribing provider’s name
    • Unique identification number of the prescription
    • Name or initials of the dispensing pharmacists

Individual medication records (profiles) must comply with and be maintained in compliance with TSBP regulations. The pharmacist may delegate the collection of the individual medication record to a technician. The pharmacist or designee is not required to obtain and record the person's information in a profile (medication record) if the person or his or her agent refuses to provide the necessary information for such individual medication records (profiles).


The pharmacist is required to communicate to the person (or his or her agent) information concerning the dispensed prescription drug or device, including at a minimum the following:

  • The name and description of the drug
  • Dosage form, dosage, route of administration, and duration of drug therapy
  • Special directions and precautions for preparation, administration, and use by the person
  • Common severe side or adverse effects or interactions and therapeutic contraindications that may be encountered, including their avoidance, and the action required if they occur
  • Techniques for self-monitoring of drug therapy
  • Proper storage
  • Refill information
  • Action to be taken in the event of a missed dose

The pharmacist is not required to provide consultation when the person (or his or her agent) refuses such consultation. The pharmacist shall document such refusal for consultation.

TSBP rules require that written information accompany prescription drug orders be delivered to the person or a representative agent of that person. Provision of written information must be in compliance with TSBP rules.

Counseling requirements are to be in compliance with TSBP regulations. The counseling function must be performed by the pharmacist and cannot be delegated to a technician.