The Rural Health Transformation (RHT) Program was created by Congress in July 2025 to strengthen rural communities across America by improving health care access, quality, and outcomes.
Under the Program, Centers for Medicare & Medicaid Services (CMS) will distribute $50 billion between FY 2026 and FY 2030 to improve health care access, quality, and outcomes by transforming the health care delivery ecosystem. This Program represents one of the largest federal investments ever made in rural health care, but it comes with significant compliance, reporting, and audit obligations.
Baker Donelson is uniquely positioned to help health systems, providers, and other stakeholders across the country pursue opportunities under the RHT Program while managing the compliance, audit, and recoupment risks that can accompany public funding. Our multidisciplinary team advises clients across the full RHT Program life cycle – from strategic program design and funding readiness to implementation, compliance infrastructure, and defense of challenged funding – so our clients can build programs that are successful, impactful, and compliant.
Strategic Program Design and Funding Readiness
During the application phase, Baker Donelson advises organizations on structuring RHT initiatives to align with CMS requirements and state implementation plans, including rural access expansion, workforce stabilization, care transformation, and value-based payment strategies. From eligibility analysis and program design to financial modeling and state-agency coordination, we help clients develop proposals that are compelling, defensible, compliant, and positioned for long-term sustainability. Because each state's RHT Program is unique, success requires counsel that can navigate both federal requirements and state-specific guidance.
Implementation and Operationalization of Approved Initiatives
Once funding is approved, Baker Donelson helps clients move RHT initiatives from concept to execution. We draft and negotiate the agreements needed to operationalize funded programs, including services agreements, participation agreements, affiliation arrangements, data-sharing agreements, and other contracts with vendors, community partners, participating providers, and academic institutions. We also help clients structure governance and accountability frameworks across multiple stakeholders so initiatives can be implemented efficiently; support program objectives; and manage regulatory, financial, and operational risk.
Compliance Infrastructure and Risk Mitigation
Because CMS may recoup RHT funds from states, with that exposure potentially flowing downstream to participating providers, we focus on compliance from day one. We help clients build the policies, internal controls, documentation protocols, and audit-ready processes needed to satisfy CMS conditions, federal cost principles, and reporting requirements, reducing risk before issues arise and strengthening clients' positions if funding is later challenged.
Ongoing Oversight, Audits, and Recoupment Defense
After funding is received, Baker Donelson's health care, government relations, and enforcement teams remain available to provide practical, coordinated counsel through implementation, oversight, audits, and recoupment disputes. This integrated approach helps providers and organizations pursue transformative funding opportunities while managing the regulatory, financial, and operational risks that come with accepting federal dollars.
Representative Matters
- Rural Health Care Technology Expansion Initiative
Baker Donelson is working with a health care client to use RHT funds to expand health care technology across a multicounty rural region. The initiative includes deployment of telehealth platforms, remote patient monitoring tools, and interoperable data systems to support care delivery in underserved communities. Our team is advising on program design, contracting requirements, allowable use of RHT funds, vendor arrangements, data governance, and compliance documentation to reduce audit risk and protect against potential CMS recoupment.
- New Provider Training Program to Address Rural Workforce Shortages
Baker Donelson is assisting a health system in securing RHT funding to support the development of a new medical training program focused on training providers for rural and underserved communities. Our team is helping shape a proposal that aligns with state transformation priorities and CMS workforce objectives, addresses data-sharing and health care regulatory compliance issues, and creates a reporting framework designed to withstand regulatory scrutiny and reduce downstream recoupment risk.
- New Rural Population Health Improvement Program
Baker Donelson is advising a nonprofit health improvement organization on the development and implementation of a sustainable rural population health improvement program supported by RHT funding. We are counseling the client on governance, drafting the agreements needed to operationalize the program, and establishing policies with partner organizations to help ensure the funding structure complies with federal and state financing requirements.
- Workforce Development and Expansion Initiative
Baker Donelson is assisting health system and academic medical center clients in expanding medical student and resident training opportunities by planning and developing and expanding residency and clinical training programs that will be eligible for RHT Workforce Development funds. Our team is advising on program design and implementation strategies to leverage these funds to create sustainable pathways to retain physicians in states where they train, and particularly in rural and underserved areas.