Hawaii RHTP Compliance Prerequisites
What your organization needs in place before applying for RHTP sub-grants in Hawaii.
No sub-grant solicitation has been published by Hawaii's Department of Health as of March 2026. The state is finalizing its budget with CMS following the December 29, 2025 award of $188.9 million. Use this preparation window to build the compliance infrastructure your organization needs.
Hawaii's RHTP is coordinated through the Department of Health's Office of Primary Care and Rural Health (OPCRH), with oversight spanning multiple state departments. The distribution mechanism has not been formally published; Hawaii's application describes an "oversight team" coordinating state departments and healthcare organizations, suggesting a model that may combine state-designated partnerships with at least one competitive sub-grant fund (Initiative 6 — Rural Value-Based Innovation and AHEAD Readiness Fund). Because the mechanism is unconfirmed, organizations should prepare for 2 CFR 200 Uniform Guidance compliance as the federal baseline while remaining alert to solicitation-specific requirements. No state-specific compliance layers beyond the federal baseline have been published. Hawaii does not have a state-specific procurement portal identified for RHTP applications. The payment mechanism (advance vs. reimbursement) has not been stated; for Hawaii's geographically isolated rural providers and neighbor island facilities, this will be a material cash flow consideration.
Organizations operating under the Native Hawaiian Health Care Improvement Act (NHHCIA) — including Papa Ola Lōkahi and the Native Hawaiian Health Care Systems — should confirm with the Department of Health whether their existing federal compliance frameworks (HRSA award requirements, NHHCIA reporting) will interact with or substitute for any RHTP sub-award compliance requirements. No guidance has been published on this question.
SAM.gov registration with an active Unique Entity Identifier (UEI) is a baseline requirement for any organization receiving federal sub-award funds. Federal sub-award rules under 2 CFR 200 require active SAM.gov registration before award execution. Do not wait for the solicitation to initiate or renew your registration. Initial registration or renewal typically takes 7–10 business days.
Any organization receiving federal grant funds must maintain a written, board-approved cost allocation methodology that is consistently applied across all funding sources, per 2 CFR 200. Hawaii's rural providers commonly blend HRSA grant funding, Medicaid reimbursements, and state contracts — each with different indirect cost rules.
Any organization receiving $1,000,000 or more in federal financial assistance in a fiscal year is subject to Single Audit requirements under 2 CFR 200 Subpart F (updated $1M threshold, effective for fiscal years ending on or after October 1, 2024). Hawaii's neighbor island CAHs and FQHCs vary widely in their federal funding volume; organizations that would cross the $1M threshold with an RHTP award should ensure their single audit is current.
Required Prerequisites
SAM.gov Registration
All federal sub-grant applicants must have an active System for Award Management (SAM.gov) registration at the time of submission. Registration takes 7–10 business days for initial setup or annual renewal. Your Unique Entity Identifier (UEI) is assigned through SAM.gov. Do not wait until the application window opens to check your status.
Cost Allocation Methodology (2 CFR 200)
You must have a written, consistently applied cost allocation methodology that documents how shared costs are distributed across funding streams. This does not need to be complex, but it must be written and board-approved. An informal practice that hasn't been reduced to documentation will not satisfy this requirement. The methodology must be in place before you apply — not after you receive the award.
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