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AmeriCorps updated the Awardee Guide to NSCHC Enforcement of Cost-Based Disallowance. The guide explains how to calculate disallowance in cases of noncompliance. Updates related to the cost-based disallowance policy includes that prime grant recipients are not allowed to off-set or reduce payments to subrecipients to enforce the cost-based disallowance. Therefore, the cost-based disallowance would have to be repaid to AmeriCorps as described in the Debt Collection Notification issued to the prime grant recipient by the Office of Audit and Debt Resolution.
After review, AmeriCorps will continue to permit commissions and other prime grantees to submit requests to offset subrecipient costs disallowed on the basis of National Service Criminal History Check non-compliance with allowable costs to the agency for review, as they have in the past. AmeriCorps will revisit the guide with updated guidance on submitting documentation of offsets by January 2024.
In the interim, if you have questions, please contact Office of Audit and Debt Resolution at debtresolution@americorps.gov.
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