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RHTP Compliance & Spending Caps

Federal spending limits, compliance requirements, prohibited costs, and reporting obligations. This is the single most important page for avoiding audit findings and fund recapture.

This content is for general informational purposes only and does not constitute official RHTP guidance, legal advice, or compliance direction. Verify all information with the Alaska Department of Health and qualified professionals. Full Disclaimer.

RHTP Spending Caps

Federal requirements place limits on how much of Alaska’s total RHTP funding can be used for certain cost types. These caps apply across the full program (program-wide), not per-project.
Cost Category Cap Notes
Administrative Costs 10% Includes indirect costs, overhead, and general administration.
Provider Payments 15% Direct payments to healthcare providers. Does not include payments for services under a contract or subaward.
Capital / Infrastructure 20% Minor alterations, renovations, and equipment. Major new construction is prohibited entirely.
EMR Replacement 5% Only if organization had a certified EHR system prior to September 2025.
Technology & Innovation 10% or $20M Whichever is lower. Covers telehealth platforms, health IT, interoperability tools.

What This Means in Practice

Individual projects should not assume they can use the full cap amount. The state must manage these caps across all funded projects statewide. An organization requesting infrastructure spending may be approved at a reduced amount because the statewide cap is being approached.

Allowable Uses of RHTP Funds

Generally Allowable

  • Prevention and chronic disease management programs
  • Provider recruitment and retention incentives (5-year service commitment required)
  • Telehealth expansion, interoperability improvements, digital health tools
  • Minor building alterations and equipment upgrades (within 20% cap)
  • Workforce training and professional development
  • Behavioral health and substance use treatment expansion
  • Value-based care model development
  • Community health worker programs and certification
  • Child care supports for healthcare workers in remote communities
  • Housing placement assistance for recruited providers
  • Emergency medical services expansion
  • Health data analytics and population health management

Prohibited Uses of RHTP Funds

Explicitly Prohibited

  • Major new construction or land acquisition. Minor alterations allowed under 20% cap.
  • Services already covered by Medicaid or Medicare. Cannot duplicate existing federal coverage.
  • Student loan forgiveness or repayment.
  • Broadband infrastructure installation. Telehealth is allowable; physical broadband is not.
  • Lobbying or political activities.
  • Costs duplicating other federal funding sources.
  • Pre-award expenses. Costs before the official award date are not reimbursable.
  • Entertainment, alcohol, or food (unless directly related to a training event and pre-approved).

Federal Regulatory Framework

2 CFR 200 (Uniform Guidance)

The primary regulatory framework for all federal grants. Key sections:
  • Subpart D (200.300-345): Post-Federal Award Requirements: financial management, payment, property standards, procurement.
  • Subpart E (200.400-475): Cost Principles. Defines allowable, allocable, and reasonable costs.
  • Subpart F (200.500-521): Audit Requirements. Single Audit for organizations spending $1M+ in federal funds.
Read 2 CFR 200 at eCFR.gov →

Procurement Standards (2 CFR 200.317-326)

  • Micro-purchase ($10,000 or less): No competitive quotes required.
  • Small purchase ($10,001 – $250,000): Obtain quotes from adequate qualified sources.
  • Above $250,000: Formal competitive bidding.
  • Sole source: Written justification and pre-approval required above micro-purchase threshold.

Reporting Deadlines & Requirements

Report Type Frequency Deadline Details
Progress Report Quarterly + Annual 30 days post-period Programmatic and financial status.
Federal Financial Report (FFR) Annual January 28, 2027 Consolidated report submitted by state.
FFATA Subaward Report Upon subaward 30 days after award Required for subawards of $30,000+. File at fsrs.gov.
Single Audit Annual (if applicable) 9 months after FY-end Required if $1M+ in federal funds. Submit to Federal Audit Clearinghouse.

Audit Readiness Checklist

  • Maintain separate accounting for RHTP funds. Commingling is the most common audit finding.
  • Document all procurement decisions. Keep records of competitive quotes and vendor selection rationale.
  • Track time and effort for all personnel. Semi-annual certifications for 100% employees; monthly reports for split-funded staff.
  • Retain all records for 3 years after the final expenditure report.
  • Maintain current SAM.gov registration. Lapsed registration can make an organization ineligible.
  • Ensure all costs meet the four-part test: allowable, allocable, reasonable, consistently treated.

External Compliance Resources

 
⚖
2 CFR 200 (Uniform Guidance) – Full TextOfficial federal regulation at eCFR.gov
 
⚙
SAM.gov – System for Award ManagementRegister and maintain federal award eligibility
 
✉
FSRS.gov – FFATA Subaward Reporting SystemFile required subaward transparency reports
 
✆
Federal Audit ClearinghouseSubmit Single Audit reports
 
 

Federal regulations and program requirements may change. Always verify current requirements with the Alaska Department of Health and the official 2 CFR 200 text.