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Compliance Guide

Utah RHTP Compliance Prerequisites

What your organization needs in place before applying for RHTP sub-grants in Utah.

No solicitation has been published yet. Use this window to build compliance infrastructure — organizations that arrive at the application window with complete SAM.gov registration, documented cost allocation methodology, and clean audit status move faster than those that treat compliance as a post-award problem.

Utah's RHTP is administered by the Utah Department of Health and Human Services (DHHS) as the designated lead agency. As of March 22, 2026, DHHS has not published a sub-grantee solicitation, implementation framework, or procurement document. The program page (dhhs.utah.gov/ruralhealth/) is live and encourages communities to "convene, assess capacity and gaps, identify shared priorities" — a preparation-window posture that indicates DHHS is still in the governance and design phase.

No state-specific compliance requirements beyond the federal baseline have been published. The key open questions are: Mechanism — grant, contract, or mixed? DHHS has not signaled whether it will distribute sub-awards via grant or procurement contract. Tribal track — will DHHS create a dedicated tribal funding mechanism for the eight federally recognized tribes, or will tribal organizations compete on general solicitations? The application cited the Uintah and Ouray Reservation and the Navajo Nation as priority geographies. Frontier eligibility — how DHHS defines rural and frontier for program purposes has not been published.

Until the mechanism is announced, organizations should build readiness for both the grant track (2 CFR 200 compliance) and the contract track (state procurement requirements). Federal baseline compliance applies regardless.

Organizations operating under IHS 638 self-governance compacts (Navajo Nation, Ute Indian Tribe) should contact DHHS's Office of Indigenous Health and Family Services (IHFS, dhhs.utah.gov/ihfs) to clarify how the RHTP application pathway will work for 638 contractors. The interaction between 638 self-governance compliance infrastructure and 2 CFR 200 sub-recipient requirements has not been addressed in any published DHHS RHTP guidance. No technical assistance program for potential sub-grantees has been announced by DHHS as of March 22, 2026.

SAM.gov registration is a federal baseline requirement for all RHTP sub-awards. No Utah solicitation has cited it yet (no solicitation has been published), but it will be required. Complete or renew your organization's SAM.gov registration now. Initial registration takes 7–10 business days; annual renewal is required to maintain active status.

As a federal pass-through award, 2 CFR 200 applies to grant-mechanism sub-awards. Sub-recipients will be required to maintain a written, board-approved cost allocation methodology, consistent application across programs and funding streams, and documentation sufficient to demonstrate that costs are allowable, allocable, and reasonable under 2 CFR 200.405. Organizations with frontier or tribal health service geographies that allocate costs across multiple funding streams (HRSA grants, IHS funds, state Medicaid payments) should ensure their cost allocation methodology clearly distinguishes RHTP-funded activities from other program costs.

The 2024 Uniform Guidance revision raised the single audit threshold to $1,000,000 in federal expenditures per fiscal year. Given Utah's $195.7M award and seven-initiative scope, sub-awards at meaningful scale (particularly under SUPPORT, FAST, and LIFT) may approach or exceed the $1M threshold for individual organizations. Organizations should plan for single audit requirements from the start of any award period. No solicitation has cited clean audit history as a prerequisite — standard practice applies: unresolved prior audit findings reduce competitiveness even when not a formal disqualifier.

None identified as of March 22, 2026 for state-specific requirements. When DHHS releases its implementation framework or solicitation, check for: frontier county or rural area eligibility definitions, state vendor registration requirements, insurance minimums, organizational age or prior grant history requirements, match or cost-share requirements, indirect cost rate documentation, and tribal-specific application track or government-to-government agreement pathway.

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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