The Halliday Brief — March 28, 2026
- ◆ HHS stakeholder call March 30 — scoring rubric preview expected
- ◆ First RHTP applications filed ahead of deadline — early movers gaining edge
- ◆ CMS delays work requirement guidance — state planning stalls
- ◆ Measles cases reach 31 statewide — three new rural counties reporting
Week two. The RHTP grant window has been open for seven days, and the early signals are telling. A handful of critical access hospitals filed applications within the first 72 hours. Others are still assembling their teams. The gap between prepared and unprepared is already visible — and it will only widen as subsequent grant categories open.
Monday's stakeholder call is the next inflection point. If you're not on it, you should be.
DosonFounder, Von Halliday Consulting · BismarckEarly Filers Set the Pace as RHTP Grant Window Enters Second Week
At least six critical access hospitals submitted workforce retention applications in the first week — a signal that prepared organizations are moving fast while others risk falling behind.
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The first wave of RHTP workforce retention applications has landed at ND HHS, and the pattern is predictable: organizations with existing grant infrastructure and dedicated administrative staff moved first. Several of the early submissions came from CAHs that participated in the Rugby stakeholder meeting — suggesting that direct engagement with HHS staff gave applicants a meaningful head start.
For the remaining 31 eligible hospitals, the clock is now the primary constraint. The April 30 deadline does not allow extensions, and HHS officials have signaled that incomplete applications will not be reviewed.
The early filing pattern confirms what we've been saying: grant readiness is a competitive advantage. Organizations that waited for "more information" before starting their applications are now facing a 33-day sprint. The scoring rubric — expected to be previewed on Monday's call — will likely favor applications that demonstrate measurable retention targets and sustainability beyond the grant period. Start with your turnover data. Build from there.
CMS Delays Work Requirement Guidance Again — States Left in Limbo
Federal officials pushed the expected guidance release to "late April at the earliest," leaving North Dakota and 14 other states unable to begin implementation planning.
"We can't build a system for rules that don't exist yet."
— State Medicaid Director, speaking on backgroundThe delay is the second in two months. CMS originally targeted a February release for detailed implementation guidance on the Medicaid work requirements enacted in last year's reconciliation bill. The agency now says it needs additional time to resolve questions around exemption categories — particularly for tribal populations, individuals with disabilities, and residents of counties with unemployment rates above state averages.
For North Dakota, the delay creates a cascading planning problem. The state's Medicaid office cannot finalize its eligibility verification system, cannot begin the required public comment period, and cannot train county-level staff on new procedures. All of this must happen before the December 2026 federal implementation deadline.
Federal Work Requirement Implementation Deadline
All states must have work requirement verification systems operational by this date. With guidance still pending, the effective planning window is shrinking rapidly.
Measles Outbreak Expands to 31 Cases — Rural Infrastructure Under Strain
Three new rural counties reported confirmed cases this week, raising questions about whether North Dakota's public health network has the capacity to manage a sustained outbreak.
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The outbreak, which began in Cass County in early February, has now reached Ramsey, Walsh, and McLean counties — all of which have limited local public health staffing. Contact tracing in these areas is being supported by state-level epidemiologists, but the geographic spread is straining existing resources.
State Health Officer Dr. Nizar Wehbi emphasized that vaccination remains the most effective intervention and urged providers to check immunization records for all patients during routine visits. "This is not a Bismarck or Fargo problem anymore," he said. "This is a rural problem, and our rural providers are the front line."
The measles outbreak is a real-time stress test of rural public health infrastructure — and the results are not encouraging. It also creates a strategic opportunity: RHTP's upcoming "healthy lifestyles" grant category could plausibly fund preventive care coordination, mobile vaccination units, and public health partnerships. Organizations that can connect outbreak response to their RHTP applications will demonstrate exactly the kind of integrated thinking CMS wants to see.
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1Monday's HHS Stakeholder Call (March 30) The scoring rubric for RHTP workforce grants is expected to be previewed. This is the last major informational event before the April 30 deadline. Dial-in details on the ND HHS RHTP page.
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2CMS Guidance on Work Requirements Now pushed to late April. When it drops, expect a compressed timeline for state action. Legislative leaders have privately discussed a potential special session if budget impacts exceed projections.
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3RHTP Workforce & Infrastructure Surveys Still open. Completion rates remain low — under 40% of eligible organizations have responded. These surveys directly influence how subsequent grant categories are designed. Complete them.
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4Measles Response Coordination Watch for state-level requests for federal public health emergency support if case counts exceed 50. Rural hospitals should review isolation protocols and PPE inventory now.
Monday's call matters. Be on it. And if you haven't started your RHTP application yet — this weekend is the time. The organizations that move first will set the standard for what strong applications look like. Don't let that standard be set without you.
Von Halliday ConsultingNorth Dakota Rural Health Policy & Strategy