Indiana RHTP Compliance Prerequisites

Indiana released its GROW Regional Grants RFA in March 2026, with Letters of Intent due May 1, 2026 and full applications due July 1, 2026. Use this window — between now and the July deadline — to build compliance infrastructure. Organizations that arrive at the coalition application stage with SAM.gov registration current, a documented cost allocation methodology, and clean audit history will be prepared to meet the fiduciary requirements that regional coalitions and their fiscal agents must carry.

Indiana's GROW program uses a federal grant mechanism (not a state contract/procurement), which means 2 CFR 200 Uniform Guidance applies in full to both the state-to-coalition and coalition-to-subrecipient funding flows. The state has not published advance payment vs. reimbursement language for the regional grants; based on the NC ROOTS precedent, a reimbursement basis should be assumed unless FSSA states otherwise in the grant agreement.

The coalition structure introduces a wrinkle: the primary subrecipient (fiscal agent for the regional coalition) carries full fiduciary accountability and cannot pass that accountability downstream via sub-awards. Organizations that anticipate serving as fiscal agents for their regional coalition face the most demanding compliance requirements — including the need for a documented, board-approved cost allocation methodology and a single audit track record if federal expenditures exceed $1 million. Subcontractors under the primary subrecipient face a different (though still significant) compliance threshold.

SAM.gov registration with an active Unique Entity Identifier (UEI) is a federal baseline requirement for all entities receiving federal pass-through funds under 2 CFR 200. The GROW RFA has not yet been fully published (RFA released March 2026; documents not text-extractable), so explicit UEI requirements cited from the solicitation are not confirmed here. Organizations should treat SAM.gov registration as a hard prerequisite regardless. Initial SAM.gov registration takes 7–10 business days. Annual renewal is required; a lapsed registration can disqualify an organization from receiving federal funds during the award period. Check current registration status at sam.gov before the May 1, 2026 LOI deadline.

Federal pass-through grants under 2 CFR 200 require subrecipients to maintain a written cost allocation methodology that is board-approved and consistently applied. For organizations serving as primary subrecipients (fiscal agents) for their regional coalition, this is non-negotiable — auditors will examine whether shared costs (personnel, facilities, administrative overhead) are being allocated consistently between the RHTP award and other funding sources. Organizations using the 10% de minimis indirect cost rate must document that election. Those with a negotiated indirect cost rate agreement (NICRA) should ensure it is current.

Organizations expending $1 million or more in federal funds in a single fiscal year are subject to Single Audit requirements under 2 CFR 200 Subpart F (threshold updated under 2024 Uniform Guidance revision). Regional coalition primary subrecipients managing large allocations — particularly in regions with higher base allocations — should anticipate crossing this threshold.

Organizations must participate through a regional coalition — individual applications are not accepted. FSSA has designated three TA providers (Indiana Hospital Association, Indiana Primary Health Care Association, Indiana Rural Health Association) by region. Engaging with the appropriate TA provider prior to the May 1 LOI deadline is the practical path to coalition inclusion. Organizations seeking to serve as coalition fiscal agents should be prepared to demonstrate fiduciary capacity, including current audited financial statements, a functioning grants management system, and staff with federal grants administration experience.