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If you are building an FQHC look-alike application, or preparing a Section 330 applicant packet, the care coordination narrative is the part reviewers read most carefully. Clinical services, staffing model, sliding fee scale, governance, these are the sections most applicants spend the most time on. The coordination narrative, which has to describe how patients move from the health center to the rest of the delivery system and back, is often the thinnest section in the packet.
HRSA reviewers know this. Imaging, which is one of the most common specialty touchpoints for FQHC patients, is one of the places where a thin narrative fails most visibly.
This article is for CEOs, COOs, and compliance leads at Section 330 applicants and look-alike applicants who are preparing their first packet or strengthening a resubmission. It walks through what HRSA expects to see in the imaging-related care coordination narrative, what the UDS reporting implications are once the health center is designated, and how to build a workflow now that will satisfy both.
The statute does not name imaging specifically. It requires that the health center provide, or arrange for the provision of, specialty referral services including diagnostic laboratory and radiologic services. The word that does the work there is "arrange."
Arrangement means more than a list of imaging facilities on a flyer. HRSA reviewers look for evidence of a functional referral workflow that includes:
If any one of those pieces is missing, the application narrative will read as aspirational rather than operational, which is the single most common reason care coordination sections are flagged in the review.
Once a health center is designated, UDS reporting becomes the mechanism by which HRSA tracks whether the care coordination the application described is actually happening.
Table 6A captures the full clinical service profile including diagnostic services. Table 7 captures selected clinical measures, several of which depend on diagnostic studies being completed and results being retrievable. The quality measures that depend on imaging, particularly colorectal cancer screening and certain cardiovascular measures, cannot be met without a functioning imaging referral workflow.
In practical terms, a health center that cannot document where its patients are getting imaged, at what rate those studies are completed, and whether results return to the chart will struggle to hit the UDS clinical quality thresholds that drive grant competitiveness and Patient-Centered Medical Home recognition.
UDS reporting is, effectively, the audit of the care coordination narrative. What you promised in the application has to show up in the data.
Whether you are writing the application or strengthening an existing center, the workflow needs three operational pieces to hold up under HRSA scrutiny and UDS reporting.
First, a defined ordering pathway. Every provider in the health center needs to know how an imaging order becomes a scheduled study. It should not depend on the individual MA's preferred workflow or the scheduler's personal Rolodex. There should be a documented process with clear handoffs.
Second, a network of imaging providers with known pricing and willingness to accept health center patients, including uninsured and sliding fee. The network does not have to be exclusive, and it does not have to be contracted in a formal sense. It does have to be real. Reviewers can tell the difference between a three-paragraph narrative about "partnering with community imaging providers" and a documented network with contact points, pricing, and patient flow.
Third, a tracking and reporting layer. The health center needs to be able to answer the question, at any point in time, "what percentage of the imaging orders placed in the last 90 days were completed, and where were they completed?" In the early stage of a look-alike application this can be a manual log. In a mature Section 330 center it has to be a system.
Strong narratives share a few structural features.
They quantify. Instead of describing a "robust referral process," they state that the health center placed 1,240 imaging orders in the prior 12 months, achieved an 84 percent completion rate, and returned 91 percent of results to the patient chart within 14 days.
They name partners. Instead of describing "relationships with community imaging providers," they list three to five specific imaging facilities and the arrangement each facility has for the health center's sliding fee and uninsured patients.
They close the loop. Instead of describing the referral as a handoff, they describe the full lifecycle including ordering, scheduling, completion, results retrieval, and follow-up care planning. HRSA wants to see that the patient does not fall off the map.
If you are 6 to 12 months out from submitting an application, the recommended sequence is straightforward.
Start with a volume baseline. Pull the last 12 months of imaging orders from your current practice or partner site. Categorize by modality and by destination facility. This becomes the quantified anchor for the narrative.
Build the imaging partner network next. Identify three to five facilities that can serve your target population, confirm their pricing for sliding fee and uninsured, and document the operational contact for scheduling and results retrieval.
Stand up the tracking layer third. For a new applicant, a simple log in a shared spreadsheet with completion and results status is enough to support the initial narrative. At designation and UDS reporting, this needs to become a more structured system.
Close with the care coordination function. Whether it is a dedicated care coordinator, a shared role, or a function embedded in the clinical team, there has to be an owner. Name the role in the application.
Medmo works with Section 330 applicants and designated FQHCs to operationalize the full imaging referral workflow, including imaging partner network, patient scheduling and engagement, completion tracking, and UDS-ready reporting. For applicants, the workflow becomes the quantified backbone of the care coordination narrative. For designated centers, the workflow holds up under reporting and scales without adding internal FTE.
The goal is the same in both cases. The care coordination narrative that you write in the application should still be true, in quantified form, at the point of your first UDS submission.
If you are preparing a 330 application or a look-alike submission and want your imaging referral workflow to read as operational rather than aspirational, Medmo can help you build it. Request a 330 workflow review.
