Is Your State Ready for CMS Reporting? A Practical Checklist for RHTP Year 1

Jun 26, 2026   |   McKinsey & Company

With the first CMS Annual Report due August 31, McKinsey is supporting states participating in the Rural Health Transformation Program as they enter a critical stretch, with roughly two months to demonstrate credible execution momentum across a complex, multi-pillar portfolio. The pressure is real: CMS will scrutinize not just what milestones were achieved, but whether spending was purposeful, policy commitments are on track, and there is a believable path into Year 2. For many states, that means confronting honest gaps, including delayed procurements, hiring backlogs, unobligated funds, and data systems that aren't yet reporting-ready.

The good news is that states are not starting from scratch. Across the national RHTP cohort, common patterns are emerging, both in what's working and where execution is stalling. States that are best positioned heading into August share a few traits: A) they have conducted a rigorous Year 1 “lookback,” B) they have assigned explicit owners to at-risk milestones, and C) they are proactively engaging their CMS officer ahead of formal review rather than waiting for the submission deadline. Equally important, they're building strong Year 1 narratives that acknowledge early-stage complexity while spotlighting tangible community impact.

To support states in this critical window, McKinsey has developed a practical preparation checklist spanning the four components of the CMS Annual Report: implementation progress and milestone evidence, use-of-funds documentation, policy action updates, and sustainability planning. Whether you're in active remediation mode or fine-tuning a strong Year 1 story, this checklist provides a structured lens to pressure-test your readiness and identify the highest-leverage actions remaining before August 30.

Reach out to Suzanne_Rivera@McKinsey.com to learn more.

Return to Industry Insights Blog