CDC Cooperative Agreement Reporting Requirements

Overview of CDC Reporting Requirements

CDC cooperative agreement recipients face a multi-layered reporting landscape that includes performance reporting, financial reporting, data system submissions, and program-specific deliverables. The volume and complexity of reporting requirements is one of the most significant operational challenges for health departments managing multiple CDC awards.

Each CDC cooperative agreement generates its own set of reporting obligations, defined in the NOFO, the Notice of Award (NOA), and the CDC standard terms and conditions. For a health department with 5 to 10 CDC cooperative agreements — not unusual for a state health agency — the aggregate reporting burden can involve 40 to 100 distinct reports and data submissions per year across all awards.

Annual Performance Reports

The annual performance report is the primary mechanism for communicating program accomplishments, challenges, and results to CDC. It is typically due 90 days before the end of the current budget period and serves as the performance basis for continuation funding decisions.

Content Requirements

Annual performance reports vary by program, but most CDC programs require the following elements:

• Progress narrative: Detailed description of activities completed during the budget period, organized by NOFO strategy or objective. Include specific accomplishments, numbers reached, services delivered, and milestones achieved. Be quantitative wherever possible.
• Performance measures: Reporting on CDC-defined and recipient-defined performance measures. Most programs require reporting on both process measures (activities completed, outputs generated) and outcome measures (changes in health indicators, behaviors, or systems).
• Challenges and barriers: Honest assessment of obstacles encountered and how they were addressed. CDC project officers value transparency about challenges — it enables them to provide targeted technical assistance and adjust expectations appropriately.
• Evaluation results: Findings from evaluation activities, including data analysis, program effectiveness assessments, and quality improvement actions taken based on evaluation findings.
• Work plan status: Line-by-line accounting of work plan activities: completed, in progress, delayed, or modified. Explain any deviations from the approved work plan.

Submission Process

Annual performance reports are typically submitted through GrantSolutions or the specific reporting system designated in the NOFO. Some programs use custom online reporting tools. Confirm the submission method and format with your CDC project officer well before the due date. Reports submitted late or in the wrong format can delay continuation funding.

Interim Progress Reports

Many CDC cooperative agreements require interim progress reports in addition to the annual performance report. These are typically semi-annual (every 6 months) or quarterly, depending on the program. Interim reports are shorter than annual performance reports but serve the important function of keeping your CDC project officer informed between annual reporting cycles.

Interim progress reports generally cover:

• Summary of major activities and accomplishments since the last report
• Status of work plan milestones (on track, delayed, modified)
• Emerging challenges or anticipated delays
• Technical assistance needs
• Key personnel changes or organizational updates

SF-425 Federal Financial Reports

The SF-425 (Federal Financial Report) is the standard form used to report on the financial status of federal awards. CDC cooperative agreement recipients typically submit SF-425 reports on a quarterly or annual basis, depending on the specific award terms. The SF-425 tracks:

• Federal cash on hand: The amount of federal funds drawn down that have not yet been disbursed. Excessive cash on hand indicates non-compliance with cash management requirements.
• Federal expenditures: Total federal funds expended during the reporting period, broken out by direct costs and indirect costs.
• Recipient share: Non-federal contributions (cash and in-kind) if the award includes a match requirement or the recipient provides voluntary cost sharing.
• Unobligated balance: Federal funds authorized but not yet obligated. A large unobligated balance late in the budget period signals potential problems with program implementation or spending pace.
• Program income: Any income generated by the CDC-funded program, including fees, royalties, or interest earned on federal advances.

SF-425 Due Dates and Submission

Quarterly SF-425 reports are due 30 days after the end of each federal quarter (January 30, April 30, July 30, October 30). Annual SF-425 reports are due 90 days after the end of the budget period. The final SF-425 for the entire project period is due 90 days after the project period end date. SF-425 reports are submitted through the HHS Payment Management System (PMS).

Your SF-425 data must reconcile with your accounting system. Discrepancies between your SF-425 figures and your general ledger are a common audit finding. Implement a reconciliation process that verifies SF-425 amounts against your accounting records before each submission.

Program-Specific Data System Requirements

Beyond standard performance and financial reporting, most CDC cooperative agreements require data submission to one or more CDC data systems. These systems are the backbone of national public health surveillance and program monitoring. The specific systems vary by program:

Data system requirements represent a significant operational commitment. Each system has its own data standards, submission formats, training requirements, and quality control expectations. When developing your CDC cooperative agreement budget, ensure you allocate sufficient staff time and technical resources for data system compliance.

Evaluation Reporting

CDC has significantly increased its emphasis on program evaluation across all cooperative agreement programs. Many NOFOs now require recipients to develop and implement evaluation plans that go beyond routine performance monitoring. Evaluation reporting requirements may include:

• Evaluation plan submission: A formal evaluation plan due within the first 6 months of the award, subject to CDC review and approval
• Annual evaluation findings: Integration of evaluation results into the annual performance report, showing how data informed program modifications
• Final evaluation report: A comprehensive evaluation report due at the end of the project period, synthesizing findings across all budget periods and assessing overall program impact
• Participation in cross-site evaluation: Some programs require recipients to participate in CDC-led cross-site evaluations, providing data and cooperating with external evaluation contractors

Annual Continuation Reporting

The annual continuation application (for Years 2–5) includes a reporting component that overlaps with but is distinct from the annual performance report. The continuation application performance narrative should focus on demonstrating that continued funding is justified based on accomplishments to date and a well-planned upcoming year. See the Application Guide for detailed continuation application guidance.

No-Cost Extension Reporting

If you receive a no-cost extension (NCE), you must continue all reporting requirements through the extension period. This includes SF-425 quarterly reports and any program-specific data submissions. At the end of the NCE period, all close-out reporting requirements apply.

Close-Out Requirements

When a CDC cooperative agreement ends — whether at the end of the project period, after a no-cost extension, or through early termination — recipients must complete a formal close-out process within 90 days. Close-out includes:

• Final SF-425: Due within 90 days of the project period end date, reporting all cumulative expenditures for the entire project period
• Final performance report: Comprehensive narrative summarizing accomplishments across the entire project period, final outcome data, and lessons learned
• Final inventions report: Disclosure of any inventions or intellectual property developed under the award
• Equipment disposition: Accounting for any equipment purchased with CDC funds (items ≥$5,000), including current location, condition, and proposed disposition
• Return of unobligated funds: Any unexpended federal funds must be returned to CDC through the Payment Management System. Adjust final draws to ensure no federal cash remains on hand.
• Data transfer: For surveillance and data collection programs, ensure all required data has been submitted to CDC systems and that data management plans for long-term preservation are in place

Close-out is not complete until all reports are submitted, all funds are reconciled, and CDC issues a formal close-out letter. Failure to complete close-out can affect your eligibility for future CDC awards and may result in the establishment of a debt to the federal government for unresolved amounts.

Reporting Best Practices

Based on common challenges observed across CDC cooperative agreement recipients:

• Collect data continuously: Do not wait until the reporting period ends to compile data. Implement data collection systems that capture information in real time, so reporting is a matter of summarization rather than reconstruction.
• Align with work plan structure: Organize your performance reports around the same structure as your work plan. This makes it easy for your CDC project officer to assess progress and for you to identify gaps.
• Reconcile SF-425 with your ledger: Before submitting each SF-425, verify that reported amounts match your accounting system. Flag discrepancies and resolve them before submission. SF-425 errors are a frequent Single Audit finding.
• Build internal review time: Set internal deadlines 2 weeks before CDC deadlines to allow time for supervisor review, corrections, and the inevitable last-minute data updates.
• Engage your PO proactively: If you are struggling with a reporting requirement, contact your CDC project officer before the deadline. POs can often provide guidance, extensions, or alternative formats when contacted early.