TLDR
The 75/25 core-medical-services rule is a pass/fail audit point that cuts funding mid-cycle if missed. Organizations that don't track core versus support service expenditures in real time routinely discover they are out of compliance at year-end when nothing can be corrected.
HRSA Ryan White Part A Reporting Requirements
Ryan White Part A is among the more compliance-intensive federal funding streams for health-focused nonprofits. The 75/25 core-medical-services rule, the dual-layer reporting structure (lead agency reports; subrecipients contribute), and the annual RSR submission create reporting obligations that span the entire grant year - not just the final weeks before the deadline.
Organizations that treat Ryan White compliance as a year-end task rather than a continuous monitoring function routinely discover 75/25 violations when there is no time to correct them.
The 75/25 Core Medical Services Rule
The rule originates in 42 USC 300ff-22: Part A recipients must spend at least 75% of their Ryan White Part A funds on core medical services and no more than 25% on support services. These percentages apply to the total EMA or TGA award - not to individual subrecipients.
Core medical services include:
- Antiretroviral drugs (ARVs)
- AIDS Drug Assistance Program (ADAP)
- Medical case management
- Oral health services
- Outpatient and ambulatory medical care
- Mental health services (in some funding configurations)
- Substance use disorder services (where clinically integrated)
Support services include:
- Transportation
- Food assistance
- Housing assistance
- Health education and risk reduction
- Outreach
Mental health and substance use services occupy a gray zone - their classification as core or support depends on how HRSA has categorized them in a given EMA’s approved service delivery plan. Misclassifying mental health services as core when they should be support (or vice versa) creates the 75/25 discrepancy.
RSR Submission: Structure and Deadlines
The Ryan White Services Report captures all client-level data for the grant year. It is submitted through HRSA’s Electronic Handbook by January 31 following the grant year end.
Key RSR data elements:
- Unduplicated client counts by service category
- Client demographics (age, gender, race/ethnicity, HIV status, insurance coverage)
- Clinical outcome data (viral load suppression rates, CD4 cell counts)
- Service visits by type
- Total expenditures by service type reconciled to financial records
The RSR submission is a three-step process for Part A: subrecipients submit PSRAs to the lead agency; the lead agency reviews and reconciles PSRAs; the lead agency submits the complete RSR to HRSA through EHB.
Administrative Cost Caps
Ryan White Part A imposes two spending caps that most grantees manage simultaneously:
| Cost category | Cap |
|---|---|
| Administrative costs | 10% of total award |
| Planning and evaluation (combined) | 5% of total award |
Administrative costs include grant management, finance, and overhead not directly tied to service delivery. Quality management (QM) counts against the planning and evaluation cap, not the administrative cap - but both must be monitored.
Exceeding either cap requires the lead agency to absorb the overage from non-Ryan-White funding sources. HRSA financial monitoring visits review administrative cost percentages in detail.
How GrantPipe Helps
GrantPipe’s restricted fund tracking maps expenditures to HRSA service categories as costs are posted, giving lead agencies real-time visibility into the 75/25 ratio without manual monthly compilation. The activity log captures subrecipient payment and reconciliation documentation in a format that supports HRSA monitoring visits. When the RSR deadline approaches, the financial data is already organized by service type and reconciled to grant records - the format the EHB requires.
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- Eligible Metropolitan Area (EMA)
- A metropolitan statistical area with 2,000 or more cumulative AIDS cases and a population over 500,000. EMAs receive the base Part A funding allocation.
DEFINITION
- Core medical services
- The HRSA-defined list of services that must consume at least 75% of Part A grant funds, including antiretroviral treatment, AIDS Drug Assistance Program (ADAP), medical case management, oral health, mental health (in some categories), and outpatient/ambulatory medical care.
DEFINITION
- Support services
- Non-medical services allowable under Part A that may consume no more than 25% of grant funds, including transportation, food assistance, housing assistance, outreach, and health education.
DEFINITION
- HRSA Electronic Handbook (EHB)
- HRSA's online grants management platform where grantees submit applications, progress reports, the RSR, and other required documents. Access requires HRSA account credentials with appropriate organizational roles.
DEFINITION
- Unduplicated client count
- The count of unique individuals served during a grant year, regardless of how many services or service visits they received. The RSR requires unduplicated counts by service type and in aggregate.
DEFINITION
Q&A
How is the 75/25 tracking conducted during the grant year?
The lead agency must track core versus support service expenditures by subrecipient in real time. Most EMA lead agencies require subrecipients to report monthly expenditures by service type. The lead agency aggregates these to monitor the EMA-wide 75/25 ratio. If a subrecipient's support service spending trends high, the lead agency can redirect funding to core service providers mid-year - but this requires remaining contract modification windows and responsive administrative infrastructure.
Q&A
What is the administrative cost cap?
Ryan White Part A limits administrative costs to 10% of the total grant award (combined recipient and subrecipient administrative costs). Administrative costs include management, finance, and accounting functions not directly connected to service delivery. Quality management activities and planning and evaluation are separately limited to 5% combined. Organizations that exceed either cap face disallowance.
Q&A
How does RSR data quality affect future funding?
HRSA uses RSR data to calculate performance measures, assess grantee effectiveness, and inform future funding decisions. RSRs with data quality issues - high percentages of clients with unknown demographics, low rates of linked medical records, or inconsistencies between service volumes and expenditures - appear in HRSA's grantee monitoring reports and can trigger technical assistance visits or compliance reviews.
Frequently asked