Tennessee RHTP Compliance Prerequisites

No solicitation from TDH directly to providers has been published yet. The Tennessee Rural Health Care Center of Excellence at UTHSC released a sub-grantee solicitation with a January 15, 2026 deadline — that window is now closed. Use this window to build compliance infrastructure ahead of the next UTHSC solicitation round and anticipated TDH direct solicitations for state-administered initiatives.

Tennessee's RHTP is administered by the Tennessee Department of Health (TDH) as the prime awardee and lead agency. TDH has used a sub-grantee intermediary model: the Tennessee Rural Health Care Center of Excellence at UTHSC (Memphis) received a $12 million sub-grant from TDH and operates as the primary grant distribution entity for planning and implementation awards. Organizations apply to UTHSC, not directly to TDH, for these grants.

TDH is also implementing several initiatives directly (Last Mile Teams, Memory Care Assessment Network, TennCare value-based payment expansion), which may involve separate procurement or grant solicitations issued directly by TDH. As of March 22, 2026, these have not been published.

The UTHSC Center of Excellence used a grant mechanism for its sub-awards. This means 2 CFR 200 applies to recipients of UTHSC planning and implementation grants. The Center of Excellence caps indirect costs at 10% of total award amount — recipients cannot recover indirect costs above this cap regardless of their NICRA.

SAM.gov registration was required by the UTHSC Center of Excellence solicitation. Organizations that applied in the first round should already be registered. Organizations preparing for the next round or for TDH direct solicitations should confirm active SAM.gov status and UEI now. Allow 7–10 business days for initial registration or renewal. Annual renewal is required to maintain active status. An expired SAM.gov registration at submission will disqualify your application.

The UTHSC Center of Excellence sub-grants are federal pass-through awards subject to 2 CFR 200. Recipients must maintain a written, board-approved cost allocation methodology, consistent application across programs and funding streams, and documentation sufficient to demonstrate allowability, allocability, and reasonableness under 2 CFR 200.405. The 10% indirect cost cap in the UTHSC solicitation means that organizations with higher actual indirect rates will absorb unreimbursed overhead. This is a financial planning issue, not just a compliance issue: applicants should budget carefully against the cap.

The 2024 Uniform Guidance revision raised the single audit threshold to $1,000,000 in federal expenditures per fiscal year. UTHSC planning grants (up to $100,000) are unlikely to individually trigger single audit requirements. UTHSC implementation grants (up to $500,000 over 36 months) may or may not cross the $1M threshold in a given fiscal year depending on spending pace.

Organizations seeking larger direct awards from TDH (for Last Mile, Memory Care, TennCare VBP expansion) will very likely exceed the $1M threshold and should plan for single audit compliance from the start of the award period. Clean audit history is a standard reviewer expectation even when not stated as a formal prerequisite.

Organizational eligibility (UTHSC CoE): The Center of Excellence accepts applications from nonprofits, healthcare institutions (nonprofit and for-profit), academic institutions, and community-based organizations. For-profit healthcare organizations are eligible, which is broader than many RHTP sub-grantee solicitations nationally. Indirect cost cap: 10% of total award amount, per the UTHSC solicitation. Organizations with higher indirect rates must absorb the difference. Recipients must serve rural Tennessee areas. Organizations applied through the InfoReady portal for UTHSC grants. For TDH direct solicitations, the portal will likely differ — monitor tn.gov/health/rural.html for procurement announcements. RHTP funds are 100% federally funded at the state level; sub-grantee match requirements have not been stated in UTHSC solicitation materials.

Tennessee's CON law may be under legislative review in 2026, potentially affecting which facility types can use RHTP funds for service expansion. Organizations planning facility-level expansion should monitor state legislative developments before designing implementation grant proposals.