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Awardee Guide to National Service 

Criminal History Check (NSCHC)

Enforcement of Cost-Based 

Disallowance

Effective January 26, 2022

Updated June 23, 2023

Title: Awardee Guide to National Service Criminal History Check (NSCHC) Enforcement of 

Cost-Based Disallowance

Date posted: January 26, 2022

Unique identifier: CNCS 018

Topic: National Service Criminal History Checks

Summary: This document provides guidance on effective practices in assessing and

documenting cost-based disallowance resulting from NSCHC noncompliance.

The contents of this document do not have the force and effect of law and are not meant

to bind the public in any way. This document is intended only to provide clarity to the

public regarding existing requirements under the law or agency policies.

Produced and published at US taxpayer expense.
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Contents

Introduction....................................................................................................................3

Cost Categories.............................................................................................................3

Determining the Amount of Disallowance.................................................................4

 Cost Reimbursement Awards .............................................................................................4

 Fixed Price Awards...............................................................................................................4

Documenting Disallowance ........................................................................................5

 Reporting NSCHC Disallowance of Subrecipients............................................................5

Enforcement of NSCHC Disallowance..................................................................7

FAQs................................................................................................................................7

Change Log ...............................................................................................8
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Introduction

This document supports the implementation of the National Service Criminal History Check

(NSCHC) Manual, specifically, how to assess and document cost-based disallowance for 

findings of noncompliance. Refer to the NSCHC Manual for details on compliance

requirements for NSCHC, as well as the applicable administrative remedies and 

enforcement actions related to the nature of noncompliance. The NSCHC regulatory

requirements can be found at 45 C.F.R. § 2540.200 -.207 and the AmeriCorps NSCHC 

webpage, https://americorps.gov/grantees-sponsors/history-check.

AmeriCorps requires all prime grantees to implement this guidance for NSCHC 

disallowance.

Cost Categories

Grant recipients that have findings of noncompliance with NSCHC checks will have 

disallowance applied to the following cost categories, by AmeriCorps award type:

Grant Type Staff

Salaries

Staff 

FICA

Member

Living

Allowance

Member

FICA

Member

% MSY

Volunteer

Stipend

AmeriCorps State and National 

Operational Grant – Cost 

Reimbursement

✓ ✓ ✓ ✓

AmeriCorps State and National 

Operational Grant – Fixed Price

✓

Senior Companion Program & 

Foster Grandparent Program ✓ ✓ ✓

Retired and Senior Volunteer 

Program ✓ ✓

Senior Demonstration Program 

Grants receiving funding from 

AmeriCorps

✓ ✓ ✓

VISTA Program and Support 

Grants

✓ ✓

Martin Luther King, Jr. Day of 

Service; September 11th Day of 

Service

✓ ✓

Social Innovation Fund;

Volunteer Generation Fund

✓ ✓

Note: Cost-based disallowance will not include the disallowance of AmeriCorps 

member hours. In addition, meal or mileage reimbursements are not considered 

stipend payments and are not disallowable costs for NSCHC noncompliance.
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Determining the Amount of Disallowance

Cost Reimbursement Awards

To identify the total amount of grant funds expended on applicable disallowed cost 

categories, grant recipients should run payroll or accounting system reports for each 

NSCHC record identified for cost-based disallowance. The time range of the reports 

should align with the period of noncompliance identified by monitoring staff. If the 

period of work or service is less than six months or the period of noncompliance is less 

than six months, the cost will be adjusted to coincide with the period of service, work, 

or period of noncompliance. When periods of noncompliance are less than a full pay 

period, disallowance calculations may be prorated. Generally, the time period of 

disallowance will not exceed 6 months; however, please refer to the NSCHC Manual

for more information.

Grantees should use the financial expenditure records to estimate the amount of 

disallowed costs. If the organization’s financial system or practices cannot support the 

separation of payments to individuals into distinct categories that separates

salary/stipends from mileage and other reimbursements that are not disallowed cost 

categories, then timesheets should be used to determine the hours worked/served on the 

grant during the period of noncompliance. These hours should be multiplied by the 

individual’s hourly pay rate (or estimated hourly pay rate, if not paid hourly). 

Disallowance of Match

Matching funds are held to the same requirements as federal funds and any disallowed 

match may not be used to support a statutory match requirement. Where costs were paid 

with matching funds, the disallowance of those matching costs may also result in 

disallowance of the related Federal funds. When AmeriCorps is made aware of 

disallowance that includes match, AmeriCorps will notify grantees of the required 

corrective action related to these instances when the disallowed match impacts the 

grantee’s ability to meet the match requirement.

Calculating FICA Disallowance

Organizations vary in their approach to charging FICA costs. Grant recipients should 

consult with their payroll and accounting administrators to determine the amount of 

FICA their organization charges individuals in NSCHC-required positions. If applicable 

to the AmeriCorps award type, obtain a report showing the total funds expended for 

FICA for each member and/or staff with noncompliant NSCHC records during the 

period applied to disallowance.

Fixed Price Awards

For each noncompliant member file, a share of the cost per member service year 

(MSY), proportional to the period of noncompliance, will be disallowed. The following 

formula is used to calculate disallowance of each noncompliant member: 

(Cost/MSY x Slot Type Value) x (# Days Noncompliant / 365 Days) = Total Disallowance 

Amount Per Member
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Use the following table to determine the Slot Type Value:

Slot Type eGrants Slot Type Value 

FT (Full-time) 1.00000000

TQT (Three-quarter-time) 0.70000000

HT (Half-time) 0.50000000 

Reduced Half-Time (RHT) 0.38095240 

QT (Quarter-time) 0.26455027 

MT (Minimum-time) 0.21164022 

Additional Calculation Notes: 

• Slot type values sub-calculation should be entered in 8-decimal point figures. 

• Generally, the time period disallowed will not exceed 6 months. When the 

noncompliant period exceeds 6 months and only 6 months of costs will be 

disallowed, use 182.5 as the # Days Noncompliant to calculate 6 months. 

• Final disallowance amounts should be rounded to the nearest dollar.

Documenting Disallowance

Cost estimates must be justified by the financial expenditure records related to each 

disallowed cost category, which should be the primary evidence source for 

disallowance calculations. This includes documentation of matching funds, where 

applicable. Financial records should reflect the dates of noncompliance identified by 

monitoring staff. In situations where calculations are being used to determine the 

disallowance amount, including MSY share calculations for fixed price awards and 

any necessary calculations for cost reimbursement awards, totals reported must be 

supported by detailed calculations. 

AmeriCorps monitoring officials will conduct reviews of how prime grant recipients 

implement enforcement action and document disallowance calculations. It is 

recommended that prime grant recipients ensure that disallowance implementation 

includes certification of a higher-level review. 

Reporting NSCHC Disallowance of Subrecipients Costs

Prime grantees must enforce NSCHC cost-based disallowance with subrecipients for 

applicable NSCHC noncompliance. Refer to the NSCHC Manual for details on NSCHC

findings and disallowance. When noncompliance is discovered, those monitoring 

must contemporaneously document the deficiency in writing. Prime grant recipients 

must notify AmeriCorps when NSCHC noncompliance results in the implementation of 

cost-based disallowance. The notification may take place as they are processed or at 

the completion of a monitoring cycle involving multiple subrecipients. Please note 

that discoveries of ineligible staff or participants require immediate notification to 

AmeriCorps, for awareness.

To inform AmeriCorps of NSCHC noncompliance of a subrecipient that results in costbased disallowance, prime grant recipients should email the Office of Audit and Debt 

Resolution (OADR) at debtresolution@cns.gov and ‘cc’ their Portfolio Manager and the 

Office of Monitoring at monitoring@cns.gov. In the email, prime grant recipients should 
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identify the prime and subrecipient grant award number(s) that have NSCHC 

noncompliance resulting in cost-based disallowance and should identify if the grant is a 

fixed or cost-reimbursement grant. Upon being notified, OADR will email the prime grant 

recipient instructions to upload to a Secure Folder the required additional information

listed below. Please note, the additional information should not be provided via email. 

Prime grant recipients should upload the information to their Secure Folder set up by 

OADR. 

Information prime grant recipients should upload to the Secure Folder:

1. A roster indicating the first and last name of each covered individual with 

noncompliant NSCHC, their role (e.g., staff, member, volunteer), the nature of

noncompliance (refer to the NSCHC Manual for details on nature of 

noncompliance), the individual’s start date of work/service, the date NSCHC was 

brought into compliance, the disallowance period, and the disallowance amount 

per individual broken out by federal and/or match share.

To assist prime grant recipients with reporting this information, grantees may use the 

optional NSCHC Disallowance Summary workbook. Please note, there are two 

versions of the NSCHC Disallowance Summary workbook, one for costreimbursement grants and the other for fixed-price grants. A copy of the 

applicable NSCHC Disallowance Summary workbook will be saved to the prime 

grant recipient’s Secure folder. Prime grant recipients may also access a copy of 

the workbooks at https://americorps.gov/grantees-sponsors/history-check.

2. For Cost-Reimbursement Grants, provide source documentation that supports the 

federal and/or match disallowance amounts reported for each individual, such as

payroll records or other relevant accounting system reports that show the salary, 

wages, allowance, stipend etc. paid during the disallowance period to the 

individual with noncompliant NSCHC. Timesheets should also be provided if the 

organization’s accounting system reports cannot separate salary/stipends from 

mileage and other reimbursements that are not disallowed. Timesheets should be 

used to determine the hours worked/served on the grant during the disallowance 

period. These hours should be multiplied by the individual’s hourly pay rate (or 

estimated hourly pay rate, if not paid hourly). 

3. For Fixed Priced Awards, provide documentation that supports the cost per 

member service year (MSY) and Slot Type for each applicable member with 

noncompliant NSCHC.

In addition to providing the information listed above to OADR, prime grant recipients must 

maintain within their grant records documentation of NSCHC noncompliance of a 

subrecipient that resulted in cost-based disallowance and the corrective actions taken to 

remediate the noncompliance.
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Enforcement of NSCHC Disallowance

Upon OADR receiving the required information and supporting documents described 

above, OADR will confirm with the prime grant recipient the cost-based disallowance 

amount. If additional information is needed, OADR will email the prime grant recipient. 

Once the cost-based disallowance is verified, OADR will issue a Debt Collection 

Notification to the prime grant recipient for repayment of disallowed federal expenses. 

FAQs

1. Salary is identified as a disallowable cost category. Is the employee responsible for 

paying back salaries received and, if so, is this gross income or net income?

Under no circumstances are grant recipients permitted to require employees to reimburse 

the agency for any disallowed salaries. The prime grant recipient is responsible for paying 

disallowances to AmeriCorps for disallowed costs associated with staff salary, FICA, and 

living allowance/stipend payments to national service members or volunteers.

2. Are stipends paid out for holiday, vacation, or sick leave included in the disallowance? 

Yes. All stipend funds within the period of noncompliance, regardless of type or purpose, 

that have been paid to an individual in an NSCHC-required program with noncompliant 

NSCHC records are to be disallowed. Note that meal or mileage reimbursements are not 

considered stipend payments and are not disallowable costs for NSCHC noncompliance.

3. Many of our staff positions are paid for, partly or completely, out of matching funds. How 

is disallowance handled in this situation? (Updated 6/23/2023)

The prime grant recipient should report the disallowed staff salaries, wages, and FICA that 

were paid for with federal and/or match funds to OADR. This information should be 

provided for each staff who is identified as having noncompliant NSCHC and should be 

uploaded into the prime grant recipient’s Secure folder set up by OADR. When the 

disallowance includes match, the prime grant recipient should remove the amount 

disallowed from their match ledger or other financial record of match and the prime grant 

recipient should not report the match disallowance as part of their recipient share.

4. Can prime grant recipients off-set or reduce payments to subrecipients when NSCHC

noncompliance that results in cost-based disallowance is identified? (Added 6/23/2023) 

No. Prime grant recipients may not off-set or reduce payments to subrecipients to enforce 

the cost-based disallowance. The cost-based disallowance must 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.
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Change Log

This table lists the changes made in the most recent revision of this document. 

# Date Section Change

1 6/23/23 Change Log Change Log created

2 6/23/23 Cost Categories; 

Determining the Amount of 

Disallowance

Clarified calculations for fixed-price awards

3 6/23/23 Reporting NSCHC 

Disallowance of

Subrecipients

Updated process, resources, and agency contact 

email

4 6/23/23 Enforcement of NSCHC 

Disallowance

Reports of subrecipient disallowance result in a Debt 

Collection Notification to the prime grant recipient for 

repayment

5 6/23/23 FAQs FAQ 3 updated to clarify match disallowance details. 

Added FAQ 4