Ohio RHTP Compliance Prerequisites

No solicitation has been published by Ohio for RHTP sub-grants as of March 22, 2026. Ohio is at Phase 0 — the CMS award was made December 29, 2025 and no state RHTP program page or implementation announcements have been located in accessible sources. Use this preparation window to build compliance infrastructure. The federal baseline requirements below apply regardless of which Ohio agency leads RHTP implementation.

No state-specific compliance requirements have been published by Ohio as of March 22, 2026. The lead agency has not been confirmed (likely Ohio Department of Medicaid / ODM, or the Ohio Department of Health / ODH), and no solicitation exists that would define the distribution mechanism. Ohio has administered several large Medicaid transformation programs, including the Ohio Value-Based Care and the Ohio Integrated Care Delivery System. These programs have used a mix of state procurement contracts and direct sub-awards. As a federal pass-through award, Ohio's RHTP sub-awards will be subject to 2 CFR 200 (Uniform Guidance) regardless of the state-specific mechanism.

Ohio's FQHC network is large and experienced with federal grant compliance (205 FQHC service sites, most with existing HRSA Section 330 grants and established 2 CFR 200 frameworks). FQHCs are well-positioned for RHTP compliance. CAHs with existing Medicare Conditions of Participation compliance and cost reporting frameworks are also relatively positioned. Behavioral health organizations and SUD treatment providers that have not previously administered federal discretionary grants may need to develop cost allocation methodologies and audit infrastructure before the application window opens.

SAM.gov registration (Unique Entity Identifier / UEI) is a federal baseline requirement for all recipients of federal pass-through awards. Allow 7–10 business days for initial SAM.gov registration or reactivation of a lapsed registration. Annual renewal is required. Organizations with existing federal grant portfolios (HRSA, SAMHSA, CMS) typically have active SAM.gov registrations — confirm the registration is current.

2 CFR 200 cost allocation methodology will apply to all RHTP sub-awards in Ohio as a federal baseline requirement. Ohio's FQHC applicants should ensure their cost allocation methodology accounts for all funding streams — RHTP funds will be braided with existing HRSA Section 330 grants and any Medicaid revenues. CAHs should ensure their cost allocation methodology is consistent with Medicare cost report practices. Behavioral health and SUD treatment organizations that have not previously maintained a written 2 CFR 200 cost allocation methodology should develop and board-approve one now.

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 $1M threshold under the 2024 Uniform Guidance revision). Hub-level or regional lead organizations are likely to receive awards well above the $1M threshold. Lead agency monitoring: watch medicaid.ohio.gov and odh.ohio.gov for RHTP program announcements. The Ohio State Office of Rural Health is housed at The Ohio State University. Organizations in Ohio's 32 Appalachian counties should specifically monitor for any Appalachian-priority language in the solicitation framework. The Appalachian Regional Commission and Ohio Appalachian Collaborative may have early insight into state intent before a formal solicitation is published.