Justification for a Non-Substantive Change

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To:	Erica Zielewski
	Office of Information and Regulatory Affairs (OIRA)
	Office of Management and Budget (OMB)

From:	William N. Parham III
	Office of Strategic Operations and Regulatory Affairs (OSORA)
	Centers for Medicare and Medicaid Services (CMS) 

Date:	October 27, 2026

Subject:    Non-Substantive Change Request – Rural Health Transformation (RHT) Program Reporting (OMB No: 0938-1498; CMS-10949)


This memo requests approval of a non-substantive change to the approved information collection titled Rural Health Transformation (RHT) Program Reporting (OMB No: 0938-1498; CMS-10949)

Background
The Rural Health Transformation (RHT) Program reporting (CMS-10949) is completed annually and quarterly by all approved State awardees to track programmatic milestones, performance metrics, and funding expenditures. Grounded in the program's authorizing legislation under Section 71401 of Public Law 119-21 (the Working Families Tax Cut legislation), this data collection promotes robust oversight, fiscal accountability, and data-driven performance management. The data reported is used by CMS to monitor progress against state-specific workplan milestones and evaluate compliance with the terms of the award. This reporting captures the specific technical and performance-based metrics required by CMS to re-calculate each State’s technical score, which directly determines their workload funding allocations for subsequent budget periods.

The scope and nature of the information collection remain largely unchanged. In accordance with the initial information collection request, subsequent reporting following the first Annual Report will transition to a web-based application housed within the Medicaid Data Collection Tool (MDCT). The MDCT RHTP reporting platform will be formally deployed prior to the initiation of the first Quarterly report in November 2026. The proposed changes are limited to revising instructional language and supplementary guidance to support adoption and transition upon initiating tool use. 

OVERVIEW OF REQUESTED CHANGES

We are not proposing any changes to our currently approved Supporting Statement.

We are removing our currently approved Screenshot file. It is now embedded within the Resubmission State Reporting Expectations Guide (10.20.26).

Otherwise, the Office of Rural Health Transformation (ORHT) in the Center for Medicaid & CHIP Services (CMCS) is requesting to make the following non-substantive edits to the currently approved information collection request. The reporting tool (MDCT RHTP) for States is planned to be launched on October 29th. As such, OHRT requests a review deadline of October 28th to allow States 30 days access to the reporting tool prior to their next report date (November 30th, 2026). Please see the attached redline document for a visual illustration of the non-substantive edits to the State Reporting Expectations and Obligated and Spent Funds Reporting Guides [PRA Resubmission Obligated and Spent Funds Reporting Guide 10.20.26 Redline and PRA Resubmission State Reporting Expectations Guide 10.20.26 Redline]. The following changes have no impact on the currently approved burden for this information collection. No data elements have been added or removed.
Reporting Expectations Guide: 
    • Screenshot Enhancements: Updated screenshots of the MDCT RHTP platform interface were integrated throughout the manual to reflect interface enhancements resulting from user-testing feedback. 
        ◦ The following screenshots were updated to reflect the current structure of the MDCT RHTP platform: General Information, Initiatives, Initiative Number/Name, Tracking Initiative Performance Metrics, Checkpoint Stages 0-2 and 3-5, Upload Initiative Attachments Dropdown Menu, Upload Initiative Attachments, Managing Attachments (Continued), Viewing an Attachment's Comments, State Policy Action Commitments, Obligated and Spent Funds Budget Periods, Obligated and Spent Funds File Upload, Review and Submission, Request PO Feedback, and Status Definitions
    • Historical Archiving: Details pertaining to the initial Annual Report, in the “Getting Started - Submitting the Initial Annual Report” section, were archived in the Appendix for historical reference purposes. 
        ◦ The following screenshots of the Excel Reporting Template were moved to the Appendix: Initiative Form, State Policy Actions Form, Success Stories, Sustainability Planning, and Rural Definition 
        ◦ The following instructional tables, for completing the Excel Reporting Template, were moved to the Appendix: Initiative Form Instructions, State Policy Actions Form Instructions, and Additional Information Form Instructions
    • Reporting Guidance: Step-by-step reporting guidance was revised to provide additional clarity based on States’ questions during Office Hours and to reflect the updated MDCT workflow, interface, and user actions. 
        ◦ Instructions were updated throughout the MDCT RHTP Platform Overview and Guidance section
            ▪ Information was updated in the “Review & Submit” section to reflect that States will no longer need to export their MDCT submissions into GrantSolutions, reducing administrative burden on States
            ▪ Information was updated in the “Sustainability & Highlights” section to clarify instructional text for the “Sustainability Planning” data field
        ◦ Information was updated for clarity in the Reporting Cadence & Periods, Annual, Quarterly, and Final Reports, and Completing Reports sections
    • Title Updates: The "Use of Funds" form and corresponding guidance screenshots were updated to reflect the reporting template form title of “Obligated and Spent Funds.”
    • Reporting Deadline Adjustments: Reporting dates were corrected to restore dates inadvertently shifted to the next business day and to extend three deadlines that fall on a weekend or holiday to the next business day. A footnote was also provided to clarify that deadlines falling on a weekend or holiday extend to the next business day.

Obligated and Spent Funds Reporting Guide: 
    • Data Validation: Updates were made to enhance data validation to reduce user errors.
    • Reporting Guidance: Step-by-step reporting guidance was revised to provide additional clarity. 
    • Program-Specific Limitations: Program-specific limitations were updated to now be reported as disbursed funds rather than obligated funds.
Obligated and Spent Funds Reporting Template: 
    • Separated the Obligated and Spent Funds Reporting tabs out from the Excel annual reporting template for each State to report solely on obligated and spent funds.
    • Reordered columns and refined conditional formatting on the Use of Funds tab to make the required information clearer.