The Reporting Landscape
Section 330 grantees face a continuous cycle of reporting obligations. Unlike many federal grants where reporting is limited to quarterly financial reports and an annual progress report, health centers must produce a broad range of reports across different systems, timelines, and audiences. Missing a reporting deadline — particularly for UDS or SF-425 — can trigger conditions of award, delay funding disbursements, and negatively impact future competitive applications.
All Section 330 reporting flows through HRSA's Electronic Handbooks (EHBs) portal, with the exception of the Single Audit, which is submitted to the Federal Audit Clearinghouse. Health centers should designate specific staff responsible for each reporting obligation and maintain a compliance calendar with reminders at 60, 30, and 7 days before each deadline.
Uniform Data System (UDS) Annual Report
The Uniform Data System is the cornerstone of Health Center Program reporting. Mandated by Section 330 and administered by BPHC, the UDS collects standardized data from every Section 330 grantee and Look-Alike on a calendar year basis (January 1 – December 31). The report is due in mid-February of the following year — typically February 15, though the exact date is published annually by BPHC.
UDS Tables Overview
The UDS consists of multiple tables, each capturing a different dimension of health center operations:
| Table | Content | Key Data Points |
|---|---|---|
| Table 3A | Patients by Age and Gender | Unduplicated patient count, age distribution, gender |
| Table 3B | Demographics and Insurance | Race/ethnicity, language, insurance status (uninsured, Medicaid, Medicare, private) |
| Table 4 | Selected Patient Characteristics | Income levels (% FPL), homelessness status, agricultural worker status, veteran status |
| Table 5 | Staffing and Utilization | FTEs by provider type, visits by type, patients per provider, visits per patient |
| Table 6A | Selected Diagnoses and Services | Patients by diagnosis category (hypertension, diabetes, HIV, etc.) |
| Table 6B | Quality of Care Measures | Clinical quality measures (HbA1c control, blood pressure control, cancer screening, prenatal care, depression screening) |
| Table 7 | Health Outcomes and Disparities | Outcomes stratified by race/ethnicity to identify health disparities |
| Table 8A | Costs | Total costs by category (medical, dental, behavioral health, enabling, facility, administration) |
| Table 9D | Revenue | Total revenue by source (Section 330 grant, Medicaid, Medicare, private insurance, self-pay, state/local, other) |
| Table 9E | Other Revenue | 340B revenue, NHSC, other federal grants, state/local funding, foundation grants |
UDS Data Quality
HRSA applies automated validation checks to UDS submissions and will reject reports that fail data quality thresholds. Common data quality issues include:
- •Internal inconsistencies: Patient counts in Table 3A not matching totals in Tables 3B or 4. The unduplicated patient count must be consistent across all tables.
- •Missing data: Demographic fields (race, ethnicity, language, insurance status) with high “unknown” rates. HRSA expects health centers to capture these data elements at registration and update them at each visit.
- •Clinical measure denominators: Quality measures with denominators that seem too small relative to patient volume, suggesting that the EHR is not capturing all eligible patients in measure denominators.
- •Year-over-year variance: Large unexplained swings from prior year data flag for BPHC review. If patient volume increased or decreased significantly, be prepared to explain why.
- •Cost-per-patient outliers: Cost data that results in per-patient or per-visit costs far above or below national benchmarks will generate queries from HRSA.
UDS Preparation Timeline
Do not wait until January to begin UDS preparation. A disciplined approach starts mid-year:
- •July–September: Run preliminary UDS reports from your EHR for the first 6 months. Identify data quality issues and address EHR configuration problems, staff training gaps, or documentation workflows that are producing bad data.
- •October–November: Run 9-month preliminary reports. Verify that clinical quality measure logic in your EHR matches UDS measure specifications. Begin preparing Table 8A (costs) and Table 9D/9E (revenue) with your finance team.
- •December: Final data cleanup. Ensure all encounter data for December visits will be captured before the year closes. Coordinate with finance to close the calendar year books for cost and revenue reporting.
- •January: Pull final UDS reports. Run HRSA's Data Quality Check Tool. Reconcile tables. Prepare narrative explanations for any significant year-over-year changes.
- •February 1–15: Enter data into EHBs, run validation, resolve errors, obtain AOR certification, and submit.
Federal Financial Report (SF-425)
The SF-425 is the standard federal financial report required of all federal grant recipients. Section 330 grantees submit the SF-425 through EHBs on a quarterly basis, aligned with their budget period quarters (not the federal fiscal year).
SF-425 Submission Schedule
The SF-425 is due 30 days after the end of each budget period quarter. For example, if your budget period starts on April 1:
| Quarter | Period Covered | SF-425 Due |
|---|---|---|
| Q1 | April 1 – June 30 | July 30 |
| Q2 | July 1 – September 30 | October 30 |
| Q3 | October 1 – December 31 | January 30 |
| Q4 | January 1 – March 31 | April 30 |
The SF-425 reports cumulative federal expenditures against the authorized budget. It must reconcile with your general ledger and the Payment Management System (PMS) drawdown records. Common errors include reporting expenditures that exceed drawdowns, failing to report unliquidated obligations, or misclassifying expenditures between budget categories.
SF-425 and PMS Reconciliation
HRSA cross-references SF-425 data with PMS drawdown records. Significant discrepancies between reported expenditures and actual drawdowns will trigger HRSA follow-up. Best practice is to reconcile PMS drawdowns with your general ledger monthly and to report SF-425 expenditures from the same general ledger data used for reconciliation.
Non-Competing Continuation (NCC)
The NCC application is submitted annually by current grantees to continue their funding within the project period. HRSA typically opens the NCC application in EHBs approximately 120 days before the start of the next budget period. The NCC is not a competitive application, but it is a compliance checkpoint — HRSA reviews the application before releasing continuation funding.
NCC Components
A typical NCC submission includes:
- •Updated SF-424A budget: Reflect any changes in planned expenditures for the upcoming budget period. Major budget shifts may require narrative explanation.
- •Budget narrative/justification: Explain any significant changes from the prior year budget.
- •Progress report: Summarize accomplishments during the current budget period, including patient volume, service expansion, quality improvement achievements, and any challenges encountered.
- •Scope of project updates: If your scope has changed via approved CIS requests, the NCC should reflect the current scope.
- •Response to conditions of award: If you have outstanding conditions, the NCC must address progress toward resolution.
Late NCC submissions delay funding. If your NCC is not approved by the budget period start date, you may operate under a restricted interim budget until HRSA completes its review. Aim to submit the NCC within 30 days of when HRSA opens the application.
Progress Reports
In addition to the NCC progress report, HRSA may require interim progress reports as conditions of award or as part of supplemental funding requirements. Progress reports typically require:
- •Summary of activities completed during the reporting period
- •Progress toward project objectives and milestones
- •Patient volume and service utilization data
- •Staffing changes (vacancies, new hires, departures)
- •Challenges and corrective actions taken
- •Plans for the next reporting period
When HRSA requests progress reports as conditions of award, the reports have specific due dates and content requirements defined in the condition. Treat these as high-priority deliverables — failure to submit on time can escalate progressive action.
FTCA Deeming Application
Section 330 grantees that wish to receive Federal Tort Claims Act (FTCA) medical malpractice coverage must submit an annual deeming application through EHBs. FTCA coverage is a significant benefit — it provides malpractice coverage for the health center and its providers at no cost, which can save hundreds of thousands of dollars annually in commercial malpractice premiums.
Deeming Application Components
The FTCA deeming application requires:
- •Credentialing and privileging documentation: Evidence that the health center has a credentialing process meeting HRSA standards, including primary source verification, peer review, and current privilege delineation for all covered providers.
- •Risk management program: Documentation of a formal risk management program including incident reporting, quality assurance, claims history, and staff training.
- •Claims history: Information on any malpractice claims filed against the health center or its providers.
- •Provider roster: Complete list of providers to be covered, with their credentials, employment status, and site assignments.
FTCA coverage extends only to acts performed within the approved scope of project and only to providers who are employees or deemed employees of the health center. Independent contractor providers may not be covered. Health centers should review their provider arrangements carefully to ensure that all providers who should be covered are properly documented.
Single Audit Requirements
Health centers that expend $750,000 or more in federal awards during their fiscal year must obtain a Single Audit in accordance with 2 CFR 200 Subpart F. The audit must be completed and submitted to the Federal Audit Clearinghouse (FAC) within 9 months after the end of the health center's fiscal year. For health centers with a December 31 fiscal year end, the audit is due by September 30.
The $750,000 threshold applies to total federal expenditures across all federal programs, not just Section 330. Given that most health centers receive Section 330 funding plus other federal grants (Ryan White, SAMHSA, CDC, etc.) and also receive Medicaid and Medicare payments, virtually all Section 330 grantees exceed this threshold and are subject to Single Audit requirements.
EHBs Reporting Portal Tips
The EHBs portal is central to all Section 330 reporting. These practical tips can help prevent common submission problems:
- •Save frequently: EHBs sessions time out after periods of inactivity. Save your work after completing each section or table.
- •Use the validation tool: EHBs provides built-in validation for UDS and other reports. Run validation before submission and resolve all errors. Warnings should be reviewed and explained if the data is correct.
- •Coordinate AOR availability: Only the Authorized Organization Representative can certify and submit reports. Ensure the AOR is available during submission windows, or designate an alternate AOR.
- •Keep confirmation receipts: After submission, save the confirmation page and receipt number. These are your evidence of timely submission if questions arise.
- •Avoid deadline-day submission: EHBs can experience heavy traffic near reporting deadlines. Aim to submit at least 3–5 business days early to allow time for technical issues.
For details on how reported financial data must align with your budget management practices, see the budget and financial management guide. For common reporting errors that new grantees make, see common mistakes.