New York RHTP Compliance Prerequisites

No solicitation has been published by New York for RHTP sub-grants as of March 22, 2026. New York is at Phase 0 — the CMS award was made on December 29, 2025, and no state RHTP program page, stakeholder engagement announcements, or solicitation framework has been located in accessible sources. Use this window to build compliance infrastructure.

No state-specific compliance requirements have been published by New York as of March 22, 2026. The lead agency has not been publicly confirmed (likely NYSDOH or the Office of Health Insurance Programs), and no solicitation document exists that would define the distribution mechanism — grant vs. contract, reimbursement vs. advance payment, or any state-specific layered requirements. As a federal pass-through award, New York's RHTP sub-awards will be subject to 2 CFR 200 (Uniform Guidance) regardless of the state-specific mechanism chosen. This sets the floor for cost allocation, financial management, and audit requirements. Organizations with existing federally funded programs (FQHCs under HRSA Section 330, CAHs under Medicare, CCBHCs under SAMHSA) already operate under 2 CFR 200 and are well-positioned for RHTP compliance. New York has prior experience with large Medicaid transformation programs (DSRIP, VBP) that created multi-layer sub-award structures. Those programs used state procurement mechanisms and direct grant contracts. The RHTP mechanism will likely follow a similar model — organizations should be prepared for both grant and contract compliance scenarios until the state publishes its framework.

SAM.gov registration will be required as a baseline federal compliance prerequisite for any RHTP sub-award in New York. Allow 7–10 business days for initial SAM.gov registration or reactivation of a lapsed registration. Annual renewal is required — an expired SAM.gov registration at application submission will disqualify your application. Tribal governments and tribal organizations applying under RHTP are also required to maintain SAM.gov registration for most federal grant programs.

2 CFR 200 cost allocation methodology will apply to all RHTP sub-awards in New York as a federal baseline requirement. Organizations must maintain a written, board-approved cost allocation methodology; consistent application of that methodology across programs; and documentation sufficient to demonstrate that any costs charged to RHTP are allowable, allocable, and reasonable under 2 CFR 200.405. FQHCs in particular should ensure their cost allocation methodology accounts for all funding streams — RHTP funds will be braided with existing grants.

Organizations receiving $1,000,000 or more in federal expenditures in a fiscal year are subject to Single Audit requirements under 2 CFR 200 Subpart F (updated threshold under the 2024 Uniform Guidance revision from $750,000 to $1,000,000). Any organization that could receive $1M or more in RHTP funds should confirm their most recent Single Audit status and whether any findings remain open; ensure their auditor is aware of the prospective award; and have three years of audited financial statements available.

None of the following state-specific requirements have been identified yet because no solicitation has been published: state vendor registration (New York State Vendor File, administered by OSC), organizational age requirements, insurance requirements, indirect cost rate, or match/cost-share. Lead agency monitoring: watch NYSDOH.ny.gov and ny.gov/programs/medicaid for any RHTP program announcements. The NYSDOH Charles D. Cook Office of Rural Health (518-402-0102; orh@health.ny.gov) administers federal rural health programs in New York and is a likely source of RHTP implementation guidance.