Uniform Data System COVID Reporting

Many health centers have increased virtual visit capabilities during the COVID-19 pandemic. AAFCPAs would like to make Federally Qualified Health Center (FQHC) clients aware that the Health Resources and Services Administration’s Bureau of Primary Health Care (BPHC) recently provided updated guidance on the Uniform Data System (UDS) reporting framework in response to the COVID-19 pandemic.

We have summarized for your convenience how visits and patients should be reported on the UDS:

Visits and Patients

Virtual visits should be reported on table 5 within column b2. A virtual visit is defined as a “documented contact between a provider and a patient in which the provider exercises independent, professional judgement in the provision of in-scope services to the patient at an approved location.”

A virtual visit is one that must use a live video connection between a provider and a patient. Another acceptable form of a virtual visit would be two-way interactive audio technology (i.e. telephone). Pre-recorded videos and situations involving transmission of data only do not count as a UDS virtual visit.

Virtual visits should be coded as such within your electronic health record system.

A COVID-19 test or screening by itself (without any treatment or examination) would fail to qualify as a UDS visit.


Health Centers should continue to report any amount of staff full-time equivalents (FTEs) within Table 5 in which the health center is paying for or incurring costs during the reporting year, even if the given employee is not working or conducting visits with patients.

Any portion of the year in which employees were not working and not compensated (either due to furlough or leave under the Families First Coronavirus Response Act (FFCRA)) would be excluded from Table 5.

COVID-19 Tests, Diagnoses, and Vaccines

Table 6A has been updated to reflect COVID-19 testing and related diagnosis:

  • Line 4c (Novel coronavirus (SARS-CoV-2) disease)
  • Line 6a (Acute respiratory illness due to Novel coronavirus (SARS-CoV-2) disease)
  • Line 21c (Novel coronavirus (SARS-CoV-2) diagnostic test)
  • Line 21d (Novel coronavirus (SARS-CoV-2) antibody test)

Administered vaccines (separate from clinical trials) will be reported on Appendix E – Question 4 if the patient had a countable UDS visit during 2020. AAFCPAs anticipates that the 2021 UDS reporting will update Table 6A with the relevant vaccination clinical codes.

Revenue and Financial Reporting

Tables 9D and 9E have been updated to account for various revenue streams introduced during the COVID-19 pandemic:

  • Table 9D, Line 8c (“Other Public, including COVID-19 Uninsured Program”): will be used to report financial data related to the testing and treatment of uninsured patients with suspected or diagnosed COVID-19.
  • Table 9E, Lines 1l through 1p: COVID-19 Supplemental Funding will be used to reflect the grant amounts drawn from BPHC activity codes H8C, H8D, ECT or other COVID-19 related funding from BPHC.
  • Table 9E, Line 3b: Provider Relief Funds to reflect funds received through the U.S. Department of Health and Human Services (HHS) to provide relief to eligible providers for health care-related expenses or lost revenue attributable to coronavirus. If you received Provider Relief Funds but did not spend any (ie. recognize as revenue), you would report $0.

There is no consideration or a need to report financial data related to the Paycheck Protection Program (PPP) loan except for interest paid by the health center (if any) which would be reported on Table 8A as a cost.

For additional information on other COVID-19-related reporting considerations, such as temporary sites, health center staffing (e.g., volunteers), and funding and revenue, please refer to HRSA’s COVID-19 Frequently Asked Questions (FAQs).

AAFCPAs continues to monitor updates from BPHC and HHS and will provide additional updates and guidance as new information becomes available.

COVID-19 Business Resource Center

AAFCPAs has assembled resources to keep clients up to date and assist you in navigating in this time of crisis. As a firm, we are dedicated to helping you solve business, regulatory, and technological challenges to keep your company operating optimally in the short term and long term. Learn more. >>

If you have questions, please contact: Rob Constantino, CPA, MSA, at 774.512.4213, rconstantino@nullaafcpa.com; Matt Hutt, CPA, CGMA, at 774.512.4043, mhutt@nullaafcpa.com; or your AAFCPAs Partner.

About the Authors

Rob is responsible for planning and executing financial audits for sophisticated nonprofit organizations, including: community health centers, charter schools, behavioral health agencies, community development corporations, and community development financial institutions. Rob has significant experience working with audits in accordance with Uniform Guidance/Single Audit Standards and the Massachusetts Uniform Financial Report. Rob also has extensive experience with ERISA Employee Benefit Plan Audits, as well as the preparation and filing of the Federal Form 990 and Form 990-T unrelated business income tax (UBIT) returns.
Matthew Hutt CPA
Matt leads AAFCPAs’ Healthcare Division, providing assurance, tax and advisory solutions for Federally Qualified Health Centers (FQHCs), behavioral health providers, home care agencies and hospices, nursing homes, and senior care living centers. Matt advises healthcare providers on consolidation and coordination of care, including the integration of behavioral health into the primary care delivery system. He also provides consulting solutions for providers transitioning to new value-based reimbursement models, and data driven patient care, including: developing business process and controls for collecting and advantaging data to provide analysis on: provider activity, delivery of care, and analysis of efficiency & cost effectiveness. Matt is also highly-sought after for his knowledge on issues related to affordable housing developers with requirements related to the US Department of Housing and Urban Development, MassHousing, Low Income Housing Tax Credits, Historical Tax Credits and New Markets Tax Credits.