The Traumatic Brain Injury Act of 1996 (Public Law 104-166) gave new authority to the Health Resources and Services Administration (HRSA) in the United States Department of Health and Human Services (DHHS) to establish a grant program for states to assist in addressing the needs of persons with traumatic brain injury (TBI). The resulting State Demonstration Grant Program has made available two categories of grants: planning and implementation. Planning grants are awarded to assist states in building infrastructure through the development of four core components. One of the core components is a statewide needs and resource assessment encompassing the full spectrum of services, from initial acute treatment through rehabilitation and long-term community supports. In 1999, assessments completed in 11 states were subjected to a comparative analysis to identify trends across states and to extract salient issues for the State Demonstration Grant Program. This article summarizes the context of the HRSA-funded needs assessments and contrasts the methods of needs assessment utilized. Over-arching issues are discussed, including exemplary qualitative and quantitative methods, and the diversity of theoretical models employed in designing assessments and interpreting findings. Several limitations in approaches were also identified, including shortcomings of convenience samples for conducting mail surveys and the unlikely validity of using a needs and resource discrepancy approach to identify gaps in services.