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

CY2026 reporting carries one of the heaviest sets of UDS changes in years. If your data-collection processes were built around the old table structures, several of them need to be revisited before the year’s data is locked in:

Table / Form	What’s changing for 2026
Table 4 — Utilization	Managed care utilization reporting is being eliminated
Table 5 — Staffing & Services	Service categories renamed and restructured (e.g., “Enabling Services” becomes “Patient Support Services”)
Table 6A — Services Detail	Clinical measure changes and relabeling (e.g., “Well Child Visit” for ages 0–11)
Tables 6B & 7 — Clinical Quality	Measures updated to align with current eCQM versions and CMS core sets
Table 8A — Financial Costs	Full redesign of the cost-reporting structure

Always confirm the specifics against HRSA’s official 2026 UDS Manual and Program Assistance Letters before finalizing. The items above summarize the direction of the changes, and the manual is the authority on the exact definitions.

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

The bigger structural shift is UDS+, HRSA’s modernization initiative. Alongside the traditional aggregate tables, health centers now submit de-identified patient-level data through UDS+, transmitted using FHIR. The legacy aggregate UDS submission through EHBs remains the official submission of record, but UDS+ is now part of the picture and expanding.

The practical difference is significant. Aggregate UDS is, in the end, 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, are transmitted on HRSA’s schedule. Most health centers will lean on their health IT vendor to produce and submit it, because it requires the kind of FHIR data pipeline that’s hard to stand up in-house. The centers that already have FHIR-capable infrastructure for other reporting are the ones that absorb UDS+ with the least disruption.

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.