Pennsylvania RHTP Compliance Prerequisites
What your organization needs in place before applying for RHTP sub-grants in Pennsylvania.
No solicitation has been published by Pennsylvania for RHTP sub-grants as of March 22, 2026. Pennsylvania is at Phase 0 — the CMS award was made December 29, 2025 and no state RHTP program page has been located at the Pennsylvania Department of Health (PADOH), Department of Human Services (DHS), or any other state agency. Use this preparation window to build compliance infrastructure.
No state-specific compliance requirements have been published by Pennsylvania as of March 22, 2026. The lead agency has not been confirmed. Both PADOH and DHS administer large federal pass-through programs in Pennsylvania with distinct compliance requirements: PADOH administers public health grants through the Bureau of Rural Health with typical 2 CFR 200 sub-award structures; DHS administers Medical Assistance through HealthChoices and Community HealthChoices managed care, and if DHS leads RHTP, sub-awards may interact with Medical Assistance provider enrollment requirements. The Pennsylvania Office of Rural Health (Penn State) may serve a coordination role. As a federal pass-through award, Pennsylvania's RHTP sub-awards will be subject to 2 CFR 200 (Uniform Guidance) regardless of the state-specific mechanism. Pennsylvania has no federally recognized tribes, which eliminates tribal-specific compliance complexity from this state's framework.
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 HRSA, SAMHSA, or other federal grant portfolios typically have active SAM.gov registrations — confirm the registration is current and renewal is upcoming.
2 CFR 200 cost allocation methodology will apply to all RHTP sub-awards in Pennsylvania as a federal baseline requirement. Pennsylvania's FQHC applicants (167 FQHC service sites statewide) should ensure their cost allocation methodology accounts for all funding streams — RHTP, HRSA Section 330, Medical Assistance reimbursements, and other federal or state sources. CAHs in Pennsylvania submit Medicare cost reports (CMS-2552), which provide a basis for cost allocation. Behavioral health and SUD treatment organizations applying to RHTP for the first time should develop and board-approve a 2 CFR 200 cost allocation methodology before the application window opens.
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.
Organizations should monitor for the following state-specific requirements when the solicitation is published: PA Supplier Portal (supplier.budget.pa.gov) for state contracts; SAP Ariba (Pennsylvania may use SAP Ariba for procurement); organizational age requirements (2–3 years historical for direct award recipients in DHS and PADOH programs, not confirmed for RHTP); insurance requirements; indirect cost rate (NICRA or de minimis rate); match/cost-share (not confirmed); Medical Assistance provider enrollment (if DHS leads). Lead agency monitoring: watch health.pa.gov and dhs.pa.gov for RHTP program announcements. Pennsylvania Office of Rural Health (Penn State): 814-863-8214, porh@psu.edu, porh.psu.edu.
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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