Industry Update - Preparing for October 2025 and Beyond: Key Updates and Action Steps for FQHCs

Between accelerating state planning for the Rural Health Transformation Program (RHTP), continued turbulence at HRSA, and a major federal grants policy overhaul taking effect October 1, 2025, FQHCs have a narrow window to secure funding, maintain compliance, and ensure operational readiness. This post recaps our prior guidance, outlines what’s new, and provides specific action steps to help you stay ahead. 

Where we left off from previous updates: quick recap 

• RHTP opportunity & timeline: $50B, five year Rural Health Transformation Program with applications in 2025 and funding beginning 2026. 

• Policy crosswinds & strategic readiness: Shifting federal priorities and practical steps to maximize current revenue and position for new funds. 

• HRSA staffing pressures: Staffing cuts and processing delays affecting grants management and risk mitigation moves for finance and compliance. 

What’s New and Actionable Now 

1.Major Grants Policy Changes – Effective 10/1/2025 

HHS is aligning with 2 CFR 200 + new HHS-specific rules in 2 CFR 300, supported by a new Grants Policy Statement (GPS). These updates modernize thresholds, timelines, and cost flexibilities. Here are the key changes: 

• Micro-purchase threshold: $50,000 

• Equipment/Supplies threshold: $10,000 

• Modified Total Direct Costs (MTDC) subaward exclusion: $50,000 

• Fixed amount subawards: up to $500,000 (with prior approval) 

• De minimis indirect cost rate: 15% 

• Single audit threshold: $1M (up from $750k) 

• Closeout window: 120 days post-period of performance 

Bottom line: Budget, procurement, and subaward policies must be updated before October 1 to stay compliant and to capture new flexibilities. 

Actions: 

• Review and revise internal policies to match updated thresholds. 

• Adjust internal controls to utilize $50K micro-purchase and $500K fixed subawards. 

• Update indirect cost strategies to consider using the new 15% de minimis rate. 

• Train staff on new closeout timelines and documentation requirements. 

Link to the full document: Grants Policy Statment 

2. HRSA Systems Transition: Electronic Handbook (EHB) → GrantSolutions 

HRSA has begun transitioning core grants lifecycle functions from EHB to GrantSolutions, affecting how grants are submitted, tracked, and managed. 

Actions: 

• Identify and train key staff who use EHB on the new GrantSolutions platform. 

• Establish dual-system workflows and assign accountability for monitoring both systems. 

• Track the system transition milestones to avoid missing important submissions.  

For more information on GrantSolutions: GrantSolutions at HRSA | HRSA  

3. FY 2026 Cycles: New Deadlines, Extensions, and RFIs 

• Grant periods will now be four years instead of three 

• SAC NOFOs (FY 2026) are live with Grants.gov and EHB windows spanning July–December 2025. 

• Oneyear performance period extensions issued for some January and February 2026 start dates. 

  • If your organization does not need to submit a grant because you have been extended another year, there is a Request for Information (RFI) that must be submitted. 

  • The RFI requires the following to be submitted: 

    • SF-424A 

    • Budget Narrative 

    • Form 1C 

    • Form 3 

    • Project Narrative Update 

    • Supplemental Award Update (if applicable) 

  • It is important to note from the RFI: 

    • “If HRSA does not receive a response to the RFI by the deadline, or the response to the RFI is incomplete or non-responsive, there may be a delay or lapse in the issuance of funding.”  

    • “The response should not exceed 20 pages, single spaced, and must include the following information.” 

  • These are being sent to Project Directors. It is important to monitor your e-mail and EHB as there could be a quick turnaround on these.  

4. Federal Budget expiration – September 30, 2025: 

• The federal budget deadline affects all FQHC funding.  

• We recently heard from NACHC that they are confident 330 funding will be renewed, but at a flat level (meaning no increase in funding). 

• Be prepared for a government shutdown should a new budget not be passed by September 30 

• Funds may NOT be able to draw down like they have in the past due to the number of approvals required to process the draws.  The staff who do these will not be able to work during the shutdown 

• It is VERY important that you pay attention to your cashflow and project your needs to be prepared for a shutdown 

Actions: 

• Model cashflow scenarios with delayed federal draws. 

• Build a contingency plan with at least 2 – 3 months of operating reserves or accessible credit. 

• Brief your board and leadership team about potential funding disruptions and response plans.  

5. Updated Operational Site Visit (OSV) Resource: 

• Naming Convention – this resource details the documents and samples required to prepare and upload for an OSV.  It is important to follow this guidance to organize, label, and upload the documents for your OSV. 

• Link to Updated document: Naming Convention for Required Documents 

• Link to all Site Visit Resources: Site Visit Resources | Bureau of Primary Health Care 

Actions if you have an upcoming OSV: 

• Download and review the new OSV naming convention document. 

• Organize, label, and upload OSV documentation according to the new format. 

• Assign a team lead to oversee OSV readiness and conduct a mock upload. 

Link to Updated document: Naming Convention for Required Documents 

Link to all Site Visit Resources: Site Visit Resources | Bureau of Primary Health Care 

Don’t Let Compliance Slide 

Staying ahead of federal changes and maintaining compliance isn't optional, it’s mission-critical. Even minor gaps in documentation or outdated policies can lead to audit findings, funding delays, or grant denials. 

Ongoing Compliance Essentials: 

• Submit all required reports ON TIME: FFRs, SACs, BPRs, RFIs, etc. 

• Maintain accurate system access: EHB, PMS, Grants.gov 

• Document accessibility issues immediately in case of audit or appeal. 

Rural Health Transformation Program (RHTP): Updates 

If you missed out last blog – check it out here and see the summary below: Rural Health Transformation: What It Is, What It Isn’t, and How Federally Qualified Health Centers (FQHCs) Should Prepare 

Quick Summary of the CLC RHTP Blog from August 15 

• Introduction to RHTP: The blog outlines the Rural Health Transformation Program (RHTP), a state-driven, $50 billion initiative over five years (FY2026–2030) created under the “One Big Beautiful Bill” to modernize rural healthcare through digital enhancements, better patient engagement, and sustainable systems. 

• Funding Breakdown: It explains that each year, $10 billion will be allocated: 

  • 50% is divided equally among all states with an approved plan; 

  • 50% is distributed based on need considering metrics like rural population share, facility density, and other CMS criteria. 

• What FQHCs Should Do Now: Federally Qualified Health Centers (FQHCs) are encouraged to mobilize immediately by organizing key data, participating in state planning, proposing viable projects, and staying informed on state-level responses and CMS timelines. 

 
New Updates on the RHTP 

• CMS Updates on their website detailing more on the application and process: Rural Health Transformation (RHT) Program | CMS 

• State Responses: 

  • Check out the map here to see what each State has done so far: https://shvs.org/tracking-state-preparation-for-the-rural-health-transformation-program/ 

RHTP - What FQHCs Should Do 

• Connect with your PCA: Understand their involvement in shaping the state’s RHTP plan. 

• Monitor milestones: Comment periods, RFIs, RFPs, state legislative actions. 

• Package your pitch: Prepare a short, compelling project packet with: 

  • Community need 

  • Budget and impact projections 

  • Implementation timeline 

Final Thought 

The upcoming policy shifts, funding cycles, and system transitions signal a period of both challenge and opportunity. FQHCs that proactively adapt will be best positioned to retain funding, remain compliant, and lead in transforming rural health. 

Let us help you assess your readiness, update policies, and develop your funding strategies, so you’re not just compliant, but confident heading into 2026. 

About the Author  

Amy Brisson, Chief Strategy Officer  
Community Link Consulting  
Phone: 509-226-1393  
Email: info@communitylinkconsulting.com  

Amy combines over 15 years of progressive financial leadership experience with 11 years of specialized FQHC industry expertise to guide health centers through complex federal policy transitions and compliance requirements. Her deep understanding of grants management, federal funding cycles, and rural healthcare transformation initiatives positions her as a trusted advisor for FQHCs navigating regulatory changes and positioning for new funding opportunities like the Rural Health Transformation Program.