ESI Insights • Rural Health Transformation

RHTP Implementation • Oversight • CMS Compliance

Every state has submitted its RHTP application. Once CMS releases awards, the real work begins: turning plans into action, coordinating vendors, launching pilots, modernizing systems, and delivering the outcomes CMS expects over the five-year cooperative agreement.

RHTP is a multi-year federal program with strict reporting, continuation checkpoints, and detailed requirements for evidence, equity, and impact. States that execute well will maintain full funding. Those that struggle risk findings, reductions, or clawbacks.

  • Implementation Oversight — Vendor-neutral oversight across pilots, modernization tracks, workforce initiatives, solvency strategies, and rural care redesign. We keep complex efforts aligned, accountable, and outcome-driven.

  • Strategic Delivery Roadmaps — We convert your approved RHTP plan into a working execution model: governance structures, milestones, KPIs, risk signals, reporting cadence, and decision pathways aligned to CMS continuation expectations.

  • CMS Compliance & Continuation Reporting — ESI acts as a state-side CMS liaison, preparing annual reports, validating allowable uses, documenting outcomes, identifying risks early, and supporting ongoing compliance to protect every dollar awarded.

ESI serves as an executive-level partner to help states implement, manage, and sustain RHTP activities — ensuring progress, compliance, and long-term funding retention.

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The Challenge - Creating a RHTP Plan to Achieve (and Keep!) Maximum Funding

Clawbacks & Compliance

CMS has clear rules for how RHTP funds must be managed. States must follow their approved plans and federal requirements — or risk losing money already awarded. In some cases, funds can be withheld, reduced, or recovered.

When Funds Can Be Taken Back

  • If funds are used in ways not approved by CMS.
  • If states deviate from their submitted/approved application.
  • If reporting or continuation requirements are not met.
  • If funds remain unexpended or unobligated by Oct 1, 2032 — they must be returned to the U.S. Treasury.

How to Maintain Funding

  • Stay aligned with the approved RHTP plan and allowable CMS activities.
  • Use each annual allotment within its 2-year window (the year awarded + the following year).
  • Submit required annual progress reports and continuation updates showing outcomes, milestones, and expenditures.
  • Respect the 10% administrative cost cap on funds.
  • Do not replace standard provider reimbursements (RHTP funds can’t duplicate existing Medicaid/Medicare payments).
  • Maintain records for at least 3 years after the final report (longer if under audit or litigation).

Source: CMS RHTP Assistance Listing (93.798) and CMS RHTP FAQs — funds must be used as approved, reported annually, and any unspent balance by Oct 1, 2032 must be returned to Treasury.

RHTP Fund Use
CMS Timeline