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Compliance Guide

Maryland RHTP Compliance Prerequisites

What your organization needs in place before applying for RHTP sub-grants in Maryland.

No solicitation has been published yet. Maryland is in Phase 0 — the CMS award is confirmed and the Maryland Department of Health has launched its Rural Health Transformation Committee, but no sub-grantee RFA has been released. Use this window to build compliance infrastructure. Organizations that arrive at the application window ready move faster than those that treat compliance as a post-award problem.

Maryland's RHTP award flows through the Maryland Department of Health (MDH) as a cooperative agreement from CMS. The state is structured as a dual-track grant program: "Immediate Impact Funds" for rapid deployment and competitive "Transformation Funds" for longer-term initiatives. Based on MDH's existing grant-making history, sub-awards will likely follow Maryland's standard grant agreement (SGA) model, which means 2 CFR 200 compliance requirements will apply to sub-recipients as a baseline. No state-specific procurement portal equivalent to Washington's WEBS has been identified for RHTP — applicants are expected to apply directly through MDH processes. Payment mechanism (advance vs. reimbursement) has not been published. Reimbursement is the more common default under state grants of this type and would impose a cash-flow burden on smaller organizations.

SAM.gov registration with an active Unique Entity Identifier (UEI) is a federal baseline requirement for organizations receiving federal funds as sub-recipients. While no Maryland RHTP solicitation has been published yet, any organization expecting to apply should maintain active SAM.gov registration. Initial registration takes 7–10 business days; renewals require 3–5 business days. Check active status at sam.gov before any solicitation deadline. Annual renewal is required — lapsed registrations are a common disqualifier.

As a federal sub-award, RHTP sub-grants will be subject to 2 CFR 200 cost principles. Organizations should maintain a written, board-approved cost allocation methodology that consistently allocates shared costs across programs. This is implied by the federal funding flow, not yet cited from a Maryland-specific solicitation document. Organizations operating multiple programs (FQHCs with multiple funding streams, CBOs with braided grants) face the most risk here and should document their methodology before the solicitation window opens.

Organizations that expend $1 million or more in federal funds in a fiscal year are subject to Single Audit requirements under the 2024 revision to the Uniform Guidance (2 CFR Part 200, Subpart F). The $1M threshold is cumulative across all federal sources — RHTP sub-grant funds count toward this total alongside existing federal awards. Maryland has not published any solicitation language identifying clean audit history as a prerequisite or review criterion. Organizations that have never undergone a Single Audit and may cross the $1M threshold should consult their auditor before application.

No solicitation has been published. The following are anticipated based on Maryland SGA standards: Maryland state registration — organizations contracting with Maryland state agencies typically must be registered as a business entity with the Maryland State Department of Assessments and Taxation (SDAT); nonprofits must maintain active charitable organization registration with the Office of the Secretary of State. Insurance — standard Maryland grant agreements typically require general liability coverage ($1M per occurrence / $2M aggregate) and professional liability where applicable; RHTP-specific minimums not yet published. Indirect cost rate — organizations should either hold a Negotiated Indirect Cost Rate Agreement (NICRA) or elect the de minimis 10% modified total direct costs (MTDC) rate allowed under 2 CFR 200.414; documenting this election before application prevents delays at award.

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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