What do RHTP grant recipients have to track and report?

What the state reports to CMS

The CMS funding notice lists these post-award reporting requirements (CMS Notice of Funding Opportunity CMS-RHT-26-001 (via Grants.gov)):

• Progress reports, submitted with the annual non-competing continuation (NCC) application, which CMS uses to make funding decisions for the next budget period. CMS says the NCC is due about 60 days before each budget period ends (CMS).
• Federal Financial Report (FFR)
• Federal Funding Accountability and Transparency Act (FFATA) subaward reporting
• Audit reporting to the Federal Audit Clearinghouse
• SAM.gov responsibility and qualification records
• Payment Management System draws
• Workplan updates

Some states also report more often. New York, for example, has described quarterly reports to CMS, according to public summaries of its webinars. Check your state's own schedule.

What the state measures

States had to propose performance metrics, baselines and targets, and they report progress on them every year (CMS Notice of Funding Opportunity CMS-RHT-26-001 (via Grants.gov)). Examples CMS gives include:

• Health outcomes: chronic disease rates, rural opioid overdose death rates
• Financial: rural hospital operating margins, reduction in uncompensated care
• Workforce: clinician vacancy rates, new providers recruited
• Technology: share of rural patients with telehealth access, EHR interoperability
• Implementation: new programs launched, patients served, training sessions held

CMS notes states may require participating providers to submit data. If your organization holds a subaward, expect to supply some of these numbers.

What a subrecipient should track

• Every dollar by approved use category and budget line, tied to your subaward scope
• Spending against the caps: provider payments (15%), capital and infrastructure (20%) and administrative costs (10%, which CMS says includes subrecipient administrative costs) (CMS; CMS Notice of Funding Opportunity CMS-RHT-26-001 (via Grants.gov))
• Evidence that RHTP dollars do not duplicate or replace existing payment for billable services (CMS)
• Obligation and spending deadlines set by your state (Oklahoma's chronic disease NOFO, for example, requires obligation by May 1, 2027 and spending by Sept. 30, 2027) (Oklahoma State Department of Health)
• Invoices and documentation for reimbursement-based awards
• Your milestones, outcome measures and baseline data
• Uniform Guidance requirements: under 2 CFR 200.501, an entity that spends $1 million or more in federal awards in a fiscal year (for fiscal years beginning on or after Oct. 1, 2024) generally needs a Single Audit (eCFR)

Common questions

What reports are required under the RHTP?

States submit annual progress reports with continuation applications, Federal Financial Reports, FFATA subaward reports, audit reports and workplan updates to CMS. Subrecipients report to their state on the terms in their subaward.

Do subrecipients have to follow federal grant rules?

Generally, yes. CMS notes that federal award terms flow down to subawards and subrecipients under 2 CFR 200.101(b)(1), and states are responsible for making sure subrecipients comply.

Does RHTP money count toward the Single Audit threshold?

RHTP subaward funds are federal awards. Under 2 CFR 200.501, non-federal entities spending $1 million or more in federal awards in a fiscal year generally need a Single Audit. Confirm with your auditor.

Sources

1. CMS Notice of Funding Opportunity CMS-RHT-26-001 (via Grants.gov)
2. CMS: Rural Health Transformation Program FAQ (Oct. 31, 2025)
3. CMS: RHT Program Provider Payments fact sheet
4. Oklahoma State Department of Health: RHTP Chronic Disease Management NOFO
5. eCFR: 2 CFR Part 200 (Uniform Guidance), incl. 200.101(b)(1), 200.332, 200.339, 200.501

More from the RHTP Guide

← Back to the RHTP Guide · HealthRoots.ai home

HealthRoots.ai is independent and is not affiliated with or endorsed by CMS or any state agency. This page is general information, not legal advice; always confirm requirements in your own award documents and with your state RHTP office.