Michigan RHTP Compliance Prerequisites

No solicitation has been published yet. Michigan is in Phase 0 — the CMS award is confirmed at $173 million and MDHHS has launched a stakeholder listserv, but sub-grantee grant programs are awaiting CMS final budget approval before release. Use this window to build compliance infrastructure. For Michigan's tribal health programs in particular, the confirmed 5% tribal set-aside means a dedicated funding track is coming — preparation now is critical.

Michigan's RHTP award flows through MDHHS as a cooperative agreement from CMS. MDHHS will administer sub-grants directly (not through a procurement contract mechanism), which means 2 CFR 200 Uniform Guidance applies to sub-recipients as the baseline compliance framework. Michigan does not use a centralized procurement portal for grant programs of this type. No state-specific compliance layer beyond the federal baseline has been published for RHTP. Payment mechanism (advance vs. reimbursement) has not been determined — MDHHS has indicated that grant program details, including payment terms, will be published once CMS final budget approval is received. Organizations in the Upper Peninsula with limited operating reserves should plan for potential reimbursement-basis cash flow requirements.

The confirmed 5% tribal set-aside ($8.7M calculated) creates a separate compliance consideration for tribal applicants. Michigan's 12 federally recognized tribes operating under ISDEAA 638 contracts or Title V self-governance compacts should verify whether their existing financial systems satisfy 2 CFR 200 sub-recipient requirements or whether additional documentation will be required under RHTP.

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 Michigan RHTP solicitation has been published, any organization expecting to apply — including tribal health programs applying under the 5% set-aside — should maintain active SAM.gov registration. Initial registration takes 7–10 business days; renewals require 3–5 business days. Tribal programs operating under 638 contracts typically already hold UEIs for other federal programs — confirm the UEI is associated with the entity that will apply, not a parent organization. Annual renewal is required.

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 consistently applied across programs. Michigan CAHs and FQHCs typically maintain cost allocation methodologies for Medicare/Medicaid cost reports — review these for consistency with 2 CFR 200 requirements before the application window opens. Tribal health programs with IHS-funded programs should document how RHTP funds will be separated from existing IHS-funded cost centers.

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). Michigan has not published solicitation language citing audit history as a prerequisite. However, RHTP sub-grant amounts may push previously sub-threshold organizations over the $1M line when combined with existing federal awards. Organizations approaching the threshold should consult their auditor before applying.

Tribal organizations: IHS-funded tribal health programs typically already undergo Single Audits or tribally-directed equivalent audits. Confirm with your auditor whether existing audit processes satisfy 2 CFR 200 Subpart F requirements for the RHTP sub-award.

No solicitation has been published. The following are anticipated and are not confirmed from RHTP-specific documents: Michigan nonprofit corporation registration — Organizations must be in good standing with the Michigan Department of Licensing and Regulatory Affairs (LARA) to receive state-administered grants. Tribal sovereignty note — Michigan's 12 federally recognized tribes operate as sovereign governments and may not need to meet standard nonprofit registration requirements. Confirm tribal status and eligibility documentation requirements with MDHHS directly. Insurance — Michigan MDHHS grant agreements typically require general liability coverage. RHTP-specific minimums not yet published. Indirect cost rate — Organizations should hold a NICRA or elect the de minimis 10% MTDC rate under 2 CFR 200.414. Tribal programs with existing NICRA agreements (often negotiated with IHS or another federal agency) should confirm the rate is current and accepted by MDHHS.

MDHHS RHTP listserv: Subscribe at michigan.gov/mdhhs RHTP page for program updates including sub-grantee solicitation announcements.

Monitor: https://www.michigan.gov/mdhhs/assistance-programs/medicaid/rural-health-transformation-program

For tribal health programs: The 5% tribal set-aside is confirmed. Engage MDHHS tribal health contacts now to understand the application mechanism before it is published. The Michigan Department of Health and Human Services maintains a Tribal Government Services and Policy office — this office is likely to be involved in the set-aside allocation process.

Michigan Health and Hospital Association RHTP page: https://www.mha.org/issues-advocacy/key-issues/rural-health/rural-health-transformation-program/