Texas RHTP Compliance Prerequisites

No solicitation window has closed yet; Texas is actively releasing solicitations across all six initiatives as of March 22, 2026. Use this period to complete compliance infrastructure before your specific initiative's solicitation closes. Because Texas uses multiple procurement instruments (RFP, RFA, Request for Offer, direct award), the compliance requirements may differ by instrument type.

Texas's RHTP — branded "Rural Texas Strong" — is administered by the Texas Health and Human Services Commission (HHSC), specifically through the Provider Finance Department. HHSC submitted the application and is the CMS prime awardee. All sub-grantee solicitations are issued through the Electronic State Business Daily (ESBD) and announced via GovDelivery.

Critical procurement structure distinction: Texas is using multiple instrument types across its six initiatives. This is not a single competitive grant process. Initiative 1 uses direct awards to Rural Hospital Districts (no competitive process for qualifying districts). Initiatives 2 and 3 use Requests for Proposal (RFP) — contract mechanism; state procurement rules apply. Initiatives 4 and 6 use Requests for Application (RFA) — likely grant mechanism; 2 CFR 200 applies. Initiative 5 uses Request for Offer — contract-like; specific compliance obligations per solicitation. Organizations should determine which instrument type governs their specific initiative before assuming compliance requirements.

Procurement blackout: HHSC has stated it is not meeting with potential vendors or applicants for the Rural Texas Strong Program to maintain fairness for all parties and protect future procurements. Direct agency contact for solicitation clarification is not available during the active procurement period. Questions must be submitted through the formal solicitation process for each instrument. No technical assistance program for potential sub-grantees has been announced as of March 22, 2026.

SAM.gov registration is a federal baseline requirement for all RHTP sub-awards and is likely required for the RFA-instrument solicitations (Initiatives 4 and 6). For contract-mechanism solicitations (RFP, Request for Offer), state vendor registration requirements may apply separately. Complete or renew SAM.gov registration immediately. Allow 7–10 business days for initial registration or renewal. Organizations responding to Texas contract-mechanism solicitations (RFP, Request for Offer) may need to register as a state vendor through the Texas SmartBuy system.

For RFA-instrument awards (Initiatives 4 and 6), 2 CFR 200 applies. Recipients must maintain a written, board-approved cost allocation methodology consistently applied across programs and funding streams. For contract-mechanism awards (Initiatives 2, 3, 5), cost allocation under 2 CFR 200 may not apply directly — Texas state contract requirements govern. Organizations applying for Initiative 6 (Infrastructure and Capital Improvement) should note that construction costs and significant capital improvements are prohibited as direct RHTP program costs under federal rules — funds must cover equipment replacement and operational upgrades, not building construction or major physical plant investment.

The 2024 Uniform Guidance revision raised the single audit threshold to $1,000,000 in federal expenditures per fiscal year. For contract-mechanism awards, single audit requirements depend on whether the contract is a federal pass-through or a purely state-funded instrument. HHSC has not published guidance on this distinction. Organizations with unresolved prior audit findings should address them before submitting applications. Oral presentation processes (for multi-applicant counties) will include financial capacity assessments.

County-level competition: Texas uses a county-by-county award model. HHSC will issue at least one award per rural county. For counties with multiple eligible applicants, HHSC selects the top applicants for oral presentations with a scoring panel. Organizations must confirm their county's rural designation status and identify other potential applicants in their county before committing to application development. HHSC materials indicate preference for entities "headquartered in Texas" for governmental, nonprofit, and for-profit entities. Rural Hospital Districts (a specific Texas legal entity type) may receive direct awards under Initiative 1 without a competitive process. No match required at the federal-to-state level; whether HHSC imposes match requirements on sub-recipients has not been stated in published materials as of March 22, 2026.