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Compliance Guide

Mississippi RHTP Compliance Prerequisites

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

No solicitation has been published yet. Mississippi is in Phase 0 — the CMS award is confirmed at $205.9 million and the Governor's office has announced a six-initiative structure, but no sub-grantee RFA or application framework has been released. Mississippi's governance model includes a third-party intermediary that will assist with fund deployment and milestone tracking — this means compliance relationships may run through both a third-party organization and the state agencies (DOM/MSDH), rather than directly through a state health department alone. Use this window to build compliance infrastructure.

Mississippi's RHTP award flows through the Office of the Governor as the lead entity, coordinating with the Mississippi Division of Medicaid (DOM) and the Mississippi State Department of Health (MSDH). A third-party organization will be procured to assist with fund deployment, milestone tracking, and outcome assessment. The compliance implications depend on whether this third-party entity serves as a pass-through entity (making sub-grantees subject to the third party's sub-award compliance requirements under 2 CFR 200) or as an administrative support contractor (leaving state agencies as the direct compliance counterparty).

No state-specific compliance mechanism beyond the federal baseline has been published for RHTP. Mississippi does not operate a centralized grant procurement portal equivalent to Washington's WEBS. DOM typically administers Medicaid-related grants through its own contracting process; MSDH administers public health grants separately. Whether RHTP sub-grants will flow through DOM, MSDH, or the third-party intermediary is not yet determined. Payment mechanism (advance vs. reimbursement) has not been published. Given Mississippi's at-risk hospital environment, reimbursement-basis cash flow requirements could be existential for the hospitals most in need of support.

SAM.gov registration with an active Unique Entity Identifier (UEI) is a federal baseline requirement for organizations receiving federal funds as sub-recipients. Any organization expecting to apply for Mississippi RHTP sub-grants — including CAHs, FQHCs, RHCs, and the Mississippi Band of Choctaw Indians' tribal health programs — should maintain active SAM.gov registration. Initial registration takes 7–10 business days; renewals require 3–5 business days. Annual renewal is required. For Mississippi's large population of rural health clinics (240 RHCs), many operate as small private practices that may not have prior experience with SAM.gov — allow adequate time for first-time registration.

As a federal sub-award, RHTP sub-grants will be subject to 2 CFR 200 cost principles regardless of whether the sub-award flows through the state directly or through the third-party intermediary. Organizations must maintain a written, board-approved cost allocation methodology consistently applied across programs. Mississippi's 238 FQHC sites typically maintain cost allocation methodologies for UDS reporting and other federal programs — review these for consistency with 2 CFR 200 requirements. CAHs with Medicare cost reports should confirm their cost allocation frameworks are documented and board-approved before applying.

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). Mississippi has not published solicitation language identifying audit history as a prerequisite or review criterion. However, given the scale of Mississippi's RHTP award and the number of at-risk hospitals whose financial position is already under scrutiny, organizations with qualified audit opinions or material weaknesses should address those issues before application. Reviewers in any competitive process will likely view audit history as a signal of organizational capacity.

The Mississippi Band of Choctaw Indians: Choctaw tribal health programs typically undergo Single Audits for IHS-funded programs. Confirm with your auditor whether existing audit processes satisfy 2 CFR 200 Subpart F requirements for RHTP sub-awards.

No solicitation has been published. The following are anticipated and are not confirmed from RHTP-specific documents: Mississippi Secretary of State registration — Nonprofit organizations must be registered with the Mississippi Secretary of State to operate in the state and receive state-administered grants. Third-party intermediary requirements — When the intermediary is selected, it may impose its own sub-recipient eligibility requirements (organizational age, financial statements, board governance documentation) in addition to or in lieu of state requirements. Monitor DOM and MSDH announcements for the intermediary procurement. Insurance — State grant agreements typically require general liability and professional 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. Mississippi's large population of small rural health clinics operating as private practices should confirm their cost accounting method before applying.

Monitor: https://medicaid.ms.gov/rural-health-transformation-program/ (Mississippi Division of Medicaid RHTP page)

Monitor: https://msdh.ms.gov/page/44,0,111.html (MSDH Rural Health and Population Studies)

Governor's office RHTP announcements: https://governorreeves.ms.gov/

For the Mississippi Band of Choctaw Indians: The Choctaw Nation was engaged as a stakeholder during application development. Contact DOM and MSDH directly for information on tribal program eligibility and whether a dedicated tribal process will be established. The Band's tribal health programs operate primarily in Neshoba County and surrounding areas through ISDEAA self-determination contracts.

For at-risk hospitals: Organizations in immediate closure risk (Chartis 2026) should prioritize RHTP readiness alongside other financial stabilization strategies. RHTP funds cannot replace Medicaid DSH or rural hospital payment adequacy, but the RHTP Infrastructure initiative may provide facility and operational support for hospitals that survive to the application window.

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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