UDS Reporting for FQHCs: Countable Visits, the 2026 Changes, and the Move to UDS+

Why UDS is the hardest report FQHCs file

On paper, the Uniform Data System is a once-a-year submission: 11 tables and 3 forms covering patient demographics, clinical quality, staffing, services, and finances, due to HRSA by mid-February for the prior calendar year. In practice, it’s one of the most operationally and technically demanding requirements a Federally Qualified Health Center faces.

Health centers report through HRSA’s Electronic Handbooks (EHBs) portal, a reviewer works through the data from mid-February to the end of March, and a late, inaccurate, or incomplete report can put a condition on the grant award. For an organization whose Section 330 funding, and downstream benefits like 340B eligibility, depends on its standing, UDS isn’t just paperwork.

The countable visit problem

If there’s a single concept that determines whether a UDS report holds together, it’s the countable visit. HRSA’s definition is narrow and specific and it has to be applied identically everywhere it touches the report. The same visit logic drives the patient counts, the provider productivity tables, the utilization tables, and the denominators of the clinical quality measures. When the definition is applied inconsistently across those tables, the report stops reconciling, and reviewers notice.

This is why “countable visits” is one of the most common topics health centers call the HRSA UDS Support Center about. The three challenges below are where most UDS reports come apart:

Aggregating data across sites and systems

UDS asks a single organization to speak with one voice about data that usually lives in several. Clinical quality comes from the EHR; staffing and productivity from HR and scheduling; financials from the accounting system that has to tie back to the audited statements. The health center’s job is to reconcile all of it against HRSA’s definitions and produce tables that agree with each other.

Two situations make this harder:

• Multiple sites. A patient seen at two sites within the same center is still one unduplicated patient. Getting that deduplication right across locations, without dropping legitimate visits, is a recurring source of error.
• A mid-year EHR migration. Centers that switched systems during the reporting year have to stitch together two datasets with different definitions, code mappings, and data quality. HRSA publishes specific guidance for exactly this scenario because it’s so common.

The throughline is the same one that runs through ACO and hospital quality reporting: the hard part isn’t calculating a measure, it’s assembling a clean, deduplicated, definition-aligned dataset to calculate it from.

What’s changing for 2026

HRSA published the proposed changes in Program Assistance Letter 2025-05 on December 8, 2025. CY2026 data is reported in February 2027.

Table / Form	Proposed changes for 2026
Table 4 Selected Patient Characteristics	Managed care member months (Lines 13a–13c) removed. No other changes.
Table 5 Staffing and Utilization	The Selected Service Detail Addendum (Lines 20a01–21h) is removed entirely. “Enabling Services” (Line 29) is renamed Patient Support Services, with the personnel detail lines reordered and renamed. Quality Improvement personnel (Line 29b) move to Information Technology Personnel (Line 30c).
Table 6A Selected Diagnoses and Services Rendered	The largest single change. Thirteen measures removed, including COVID-19 diagnoses and tests, mammogram, Pap test, sealants, and oral surgery. Eleven new lines added: Type 1 diabetes (9a), intellectual and developmental disabilities (20g), autism spectrum disorder screening (26g), four patient support services measures (35–38), and four health-related needs measures (39–42) migrated up from the appendices. “Health supervision of infant or child” (Line 26) is renamed Well Child Visits (ages 0–11).
Table 6B Quality of Care Measures	Dental Sealants for Children 6–9 (Line 22) is replaced with Sealant Receipt on Permanent First Molars (SFM-CH), aligning with the CMS Core Set of Children’s Health Care Quality Measures.
Tables 6B & 7 eCQM alignment	Fourteen clinical quality measures updated to their 2026 eCQM versions. Most are straightforward version bumps, but several change scope. Breast Cancer Screening (CMS125v14), where the denominator age range widens from 52–74 to 42–74. See the eCQM section below
Table 8A Financial Costs	Full column redesign. Accrued Cost becomes Personnel (Salary + Fringe Benefits) (a1); the facility/non-clinical allocation column becomes Other Costs (a2); the two sum to Total Accrued Costs. The overhead allocation requirement is removed. Enabling services detail lines (11a–11h) collapse into a single Patient Support Services line, Quality Improvement moves into a new Information Technology line (14a), and donated facilities and supplies (Line 18) is removed.
Table 9D Patient Service Revenue	Shifts from cash basis to accrual basis. New Net Patient Service Revenue column (g), plus new lines for Bad Debt Expense, Pharmacy Net Patient Service Revenue, and Third-Party Incentive Revenue. Retroactive settlement columns (c1–c4) and the Medicaid and Medicare managed care payer categories are removed. Sliding fee moves from a column to Line 13a.
Table 9E Other Revenue	Also shifts to accrual basis. BPHC grant detail lines are aggregated into a single Total Health Center BPHC Grants line; other federal grant detail lines collapse into Total Other Federal Grants.
Appendices D & E Health IT and Other Data Elements	Appendix E is eliminated and folded into Appendix D, which is renamed Health IT Capabilities and Other Data Elements. Several EHR-specific questions are removed, and the health-related needs screening questions move to Table 6A. Three new questions (17–19) cover value-based purchasing contracts, Alternative Payment Model participation, and the share of revenue tied to value-based contracts. Net effect: the UDS goes from 11 tables and 3 forms to 11 tables and 2 forms.

UDS clinical measures are aligning with eCQMs

HRSA has been steadily aligning the UDS clinical quality measures with the electronic clinical quality measure (eCQM) specifications used across CMS programs, the Medicaid Core Sets, and the Quality Payment Program. The stated goal is to reduce reporting burden and improve comparability across programs.

A measure engine that calculates eCQMs from certified EHR data can, in principle, produce the UDS clinical numbers from the same logic, rather than maintaining a separate UDS-only calculation path that drifts out of sync. For FQHCs that also sit inside an ACO, the same data foundation can serve both UDS and APP Plus reporting — a point we cover in our ACO eCQM Reporting Guide.

UDS+ and the move to patient-level FHIR reporting

With UDS+, HRSA’s patient-level modernization initiative, health centers submit de-identified patient-level data transmitted using FHIR R4, per the UDS+ Implementation Guide published through HL7. The legacy aggregate submission through EHBs remains the official submission of record.

Where it stands

HRSA made a minimum UDS+ submission a requirement for CY2024 reporting, then postponed it before the deadline. HRSA’s language was postponement, not cancellation. Word on the street is that UDS+ will come back at some point. Subsequent reporting cycles have centered on legacy UDS. Health centers should confirm current status against HRSA’s UDS Modernization pages and the latest Program Assistance Letters.

Why it still matters

The Implementation Guide remains published, and HRSA reporting with the FHIR-based standards being adopted across HHS hasn’t completely reversed. The practical difference between the two models is significant. Aggregate UDS is a set of numbers a health center can assemble and key in. UDS+ is an automated, standards-based data exchange: de-identified patient-level records structured as FHIR resources, transmitted on HRSA’s schedule. Standing that pipeline up in-house is hard, which is why most health centers would rely on their health IT vendor. The centers that already have FHIR-capable infrastructure for other reporting are the ones positioned to absorb UDS+ with the least disruption whenever it resumes.

About the DHIT UDS solution

Our CQMsolution platform calculates the UDS clinical quality measures (Tables 6B and 7) using eCQM-aligned logic and applies one consistent countable-visit definition across the patient, provider, utilization, and quality tables, which is exactly where most UDS errors originate.

For the move to UDS+, our Dynamic FHIR API handles the de-identified patient-level FHIR submission, so a health center doesn’t have to build that pipeline itself. And because the same infrastructure serves UDS, MIPS, and ACO reporting, FQHCs that report in more than one program aren’t maintaining separate calculation paths that drift apart. You can read more on our UDS solution page.

For a walkthrough, or a working session on your health center’s specific UDS or UDS+ challenges, get in touch.