Data has become one of the most powerful tools in healthcare, helping demonstrate impact, improve quality, and inform key policy decisions. For community health centers, the Uniform Data System (UDS) serves as the nation’s annual snapshot of the Health Center Program, which captures key information on the patients served, services provided, workforce, and health outcomes.

Recently, the Bureau of Primary Health Care (BPHC) has proposed several important updates to Uniform Data System (UDS) reporting beginning with the 2026 reporting year. While the proposed changes are not final, they provide important insight into how BPHC is thinking about the future of UDS reporting—including the types of data, quality measures, and financial information it believes are increasingly important to capture. 

Taken together, the proposed revisions signal BPHC’s continued effort to modernize UDS by collecting more meaningful clinical, operational, and financial data while reducing unnecessary reporting burdens on CHCs. Several of the proposed changes are designed to better capture the full scope of services health centers provide to ensure policymakers have a more complete picture of the Health Center Program’s overall impact. (The proposed UDS revisions are outlined in the Federal Register notice, with a summary of the changes available on pages 8–15.)

Bringing Greater Visibility to Pharmacy Revenue

One proposed change is particularly noteworthy: the addition of Pharmacy Net Patient Service Revenue, a new financial reporting line that would capture the revenue a health center expects to collect from pharmacy patient services after contractual adjustments and other allowable reductions. At a time when the 340B Drug Pricing Program faces unprecedented challenges, ACH was encouraged to see BPHC propose this measure that better reflects the role pharmacy operations play in supporting health center finances. This approach aligns with ACH’s longstanding support for meaningful transparency that strengthens understanding of the Health Center Program while remaining practical for health centers to implement. The proposal also reflects ongoing conversations ACH has had with HRSA about advancing practical reporting measures that improve transparency while recognizing the operational realities facing community health centers.

According to BPHC, the Pharmacy Net Patient Service Revenue measure is intended to better assess health center finances and align UDS reporting with generally accepted accounting principles (GAAP) and health centers’ financial statements. Although this measure is not intended to directly collect 340B savings, ACH believes it represents a meaningful step towards strengthening transparency by helping policymakers better understand the financial contribution of pharmacy operations without implementing burdensome reporting requirements. 

For many health centers, pharmacy revenue supports services that are essential to patient care but are often under-reimbursed (or not reimbursed at all), including behavioral health, care coordination, enabling services, transportation assistance, language access, and other programs that address patients’ medical and social needs. ACH has reported on this, but without uniform data, only estimates and anecdotes are available. Better financial reporting can help policymakers and stakeholders understand how these resources strengthen access to care in medically underserved communities.

Preparing Today for Potential 2026 UDS Updates

While BPHC is still accepting feedback and the proposals are not yet final, the changes offer health centers an opportunity to begin evaluating how their reporting processes may need to evolve. As the updates are being considered, health centers can begin assessing whether changes to their data collection processes, financial reporting systems, and clinical workflows may be needed if the revisions are finalized. Early coordination among finance, pharmacy, clinical, quality improvement, and information technology teams can help ease implementation and reduce reporting burden. ACH encourages health centers to:

• Review current UDS reporting processes.
• Identify any new data elements that will need to be collected.
• Coordinate with EHR and practice management vendors.
• Evaluate financial reporting capabilities for the new Pharmacy Net Patient Service Revenue measure.
• Train staff on any new documentation or screening requirements.

As policymakers continue to examine the future of the 340B Drug Pricing Program and UDS reporting evolves, ACH remains committed to advancing transparency and accountability measures that demonstrate the value community health centers provide while preserving the flexibility and resources they need to serve patients. Thoughtful reporting should strengthen understanding of the Health Center Program—not create unnecessary administrative burden or divert resources away from patient care.