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September 2, 2026

CMS Rural Health Transformation Program: Early lessons about compliance, capacity, and implementation

Josh Zulauf
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Medical practitioners discuss rural health transformation program

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The Rural Health Transformation (RHT) Program was designed to move billions of dollars into rural healthcare systems at a pace rarely seen in federal funding programs. For many organizations, attention has understandably centered on application strategy, state priorities, and funding opportunities.

What recipients are learning now is that winning an award is only the beginning. The operational demands that follow can create challenges every bit as significant as securing the funding itself.

1.    Funding Awards Are Arriving Faster Than Guidance

As RHT funding is being awarded, many recipients are moving into implementation while states continue to interpret requirements and seek clarification on federal guidance.

Part of the challenge stems from the program's state-administered structure. Although funding was distributed on a common timeline, contract structures, eligible costs, reporting procedures, and approval processes vary significantly across states and programs, leaving some recipients to launch funded initiatives before all requirements are fully defined.

Organizations are being asked to procure equipment and services, hire staff, deploy technology, establish reporting processes, and demonstrate results within compressed timeframes. The challenge is not only implementing these initiatives quickly, but doing so in a way that satisfies changing compliance obligations.

2.    Procurement and Reporting Requirements Are Emerging as Major Risk Areas

Organizations that have limited experience administering federal assistance awards may not be familiar with the additional requirements imposed around competition, documentation, conflicts of interest, approvals, and audit thresholds.

A purchase can be operationally necessary and still fail a compliance review if proper procedures were not followed. If an organization cannot demonstrate that costs complied with grant requirements, reimbursement may be disallowed and expenses already incurred may become the organization’s responsibility.

Reporting obligations can create similar challenges. Awards commonly reimburse labor expenses, but federal funding generally requires detailed time-and-effort reporting that for-profit companies are not currently equipped to support. Many recipients are finding that they need to quickly modify their Human Resource Information System (HRIS), payroll, Enterprise Resource Planning (ERP), and reporting systems to capture this information from day one.

3.    The True Cost of Implementation Is Often Underestimated

Many applicants focus on the size of the award during the pursuit phase. Once funding is secured, attention turns to the resources required to deliver what was promised.

Personnel time, travel, oversight, reporting, program management, vendor coordination, compliance monitoring, and grant administration can add significant costs that are not always fully considered during application development.

With administrative costs capped at 10%, organizations have less flexibility to fund the infrastructure required to manage federal awards. At the same time, states are trying to maximize funding available for program activities, creating a zero-sum dynamic between service delivery and program administration.

Forward-looking recipients, often with advisory support, are proactively addressing compliance, reporting, and program management costs during contract negotiations and advocating for those expenses to be captured in grant terms and conditions.

4.    Program Income Adds Another Layer of Compliance

One issue receiving increased attention is the intersection of RHT funding and program income. Many recipients are participating in funding models that differ from traditional nonprofit or academic grant programs, raising questions about how revenue from grant-funded activities should be treated and reported.

Federal agencies are showing heightened interest in overseeing these arrangements, and states are often seeking additional clarification as they develop implementation requirements. For recipients, that can create uncertainty around reporting practices, reimbursement treatment, the risk of disallowed costs, and compliance obligations as guidance continues to be released.

5.    Funding Does Not Create Organizational Capacity

Organizations are being evaluated on their ability to improve care delivery, expand access, strengthen workforce capacity, deploy technology, and produce measurable outcomes. Those objectives require governance, staffing, accountability, and decision-making structures.

Many providers are discovering that implementing an RHT-funded initiative requires more internal capacity than anticipated. While leadership teams often came together to pursue funding, not all fully planned for the workforce needed to execute and sustain these initiatives over multiple years.

As a result, existing teams are frequently being stretched to absorb grant responsibilities alongside their current workloads.

What Rural Healthcare Leaders Should Be Preparing for Now

  • Compliance must start immediately and continue throughout the grant lifecycle.
  • Workforce initiatives require careful review. These awards may include residency-related conditions and unclear clawback provisions.
  • Variation across states. Funding priorities, approval processes, reporting requirements, and documentation standards can differ significantly.
  • RHT funding spans five years. Governance structures, staffing plans, and reporting systems established today may need to support years of monitoring and audit activity.

We Can Help

RHT funding introduces federal expectations around documentation, oversight, internal controls, and audit readiness that differ from many healthcare organizations' experience managing clinical operations, reimbursement, and commercial contracts.

We provide:

  • Federal compliance assessments and grant requirement reviews
  • Governance and accountability design
  • Procurement and internal control evaluations
  • Reporting, monitoring, and compliance tracking
  • Executive reporting and program oversight support

As requirements continue to develop, organizations that establish governance, reporting, and compliance processes early can manage funding more effectively throughout the life of the program. We help recipients build that foundation with clearer direction, stronger controls, and documentation that can withstand future scrutiny.

The information provided in this communication is of a general nature and should not be considered professional advice. You should not act upon the information provided without obtaining specific professional advice. The information above is subject to change.

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