National Historical Publications & Records Commission

NHPRC Policy on Approving Changes to Grantee Cost-Share Obligations

When the NHPRC awards a grant to an institution, that institution is responsible for meeting the amount of cost share that appears in the approved budget. The following policy explains the criteria the NHPRC will use in considering approval to reduce the amount of cost share a grantee pledges toward a grant. The NHPRC will take into account whether the grantee notifies the NHPRC of cost share variances in a timely manner, is achieving the required minimum cost share amounts in the applicable grant announcement, and is meeting the agreed-upon performance objectives.

Cost Share Oversight

Since December 2010, grantees are required to report their current amount of cost share on any project payment requests and as a part of their federal financial reports. In addition, beginning in December grantees are notified at the time of their award that they must have written approval from the NHPRC to make any reduction in their total project cost share amounts.

If during the submission of a financial report or payment request a grantee falls short of its cost-sharing requirements, NHPRC payment/reporting instructions require an explanation of the shortfall along with an estimate of when the grantee expects to "catch up" on its cost share to meet the requirement. If the grantee does not expect to meet the amount of cost share agreed to in the award documents, the grantee must promptly notify the NHPRC.

Method of Notification

A grantee's authorized representative must send a signed letter to the NHPRC Executive Director that provides the necessary information to make a determination. In most cases, this will include an explanation of the changes in circumstances, a revised budget, and a revised work plan that indicates whether the original project performance objectives will be met.

NHPRC Policy in instances of Timely Notification

Timely notification is defined as a notification that occurs before the final payment request, or the last ninety days of the official project period, whichever is earliest.

  1. NHPRC will approve a request to decrease a cost share amount where a grantee: 1) is able to meet the minimum required cost share amount as stipulated in the relevant grant announcement (usually 50% of total costs); 2) provides a revised budget indicating an adjusted cost share amount; and 3) provides an acceptable revised work plan that indicates the project will have the necessary resources to complete the agreed upon performance objectives.

  2. NHPRC may approve a request to decrease a cost share amount where a grantee is within 5% of the required cost share as stipulated in the original grant announcement and the grantee provides an acceptable explanation for the shortfall. Acceptable explanations include indications that forces outside of the grantee's direct control occurred. These may include hiring freezes, unplanned restrictions on travel or spending, and/or unexpected staffing vacancies. In making its request for reduced cost share amount, a grantee must submit a revised budget and provide an acceptable revised work plan that indicates the project will have the necessary resources to complete the performance objectives.

NHPRC Policy in instances of Late Notification

If a grantee does not meet the above deadline for timely notification and its cost share obligation is not met, the NHPRC will withhold processing the final payment request. Further, the NHPRC will require that the grantee submit within 30 days a Final Financial Report and a detailed status report on the completion of the project's performance objectives. Based on the responses provided, the NHPRC will take one of the following actions:

  1. If a grantee has met the required minimum amount of cost share that is stipulated in the relevant grant announcement and has completed the project successfully, the NHPRC will accept the shortfall. The grant performance objective that requires grantees to meet the amount of cost share pledged in the approved budget will be marked as unsuccessful.

  2. If a grantee's amount of cost share is below the minimum required cost share in the original grant announcement, but the grantee has completed its project successfully, the NHPRC will require a proportional return of grant funds. Based on the total project costs reported in the Final Financial Report, new amounts for cost share will be calculated based on the minimum required amount of cost.

      For example, a grantee reports final total project costs of $90,000 but spent $50,000 in grant funds and supplied only $40,000 in cost share. The cost sharing requirement was 50%. The grantee will be required to return $5,000 so that NHPRC and the grantee each contributed $45,000 to the project.

    The grant performance objective that requires grantees to meet the amount of cost share pledged in the approved budget will be marked as unsuccessful.

  3. If a grantee has not met its pledged cost share and has not completed its project successfully, the NHPRC will require a proportional return of grant funds.

      For example, originally the grantee had pledged $100,000 in cost share and received $50,000 in grant funds. The final financial report notes cost share of only $75,000. This represents a 25% shortfall. The NHPRC will ask for 25% of grant funds to be returned, i.e. $12,500.

    The grant performance objective that requires grantees to meet the amount of cost share pledged in the approved budget will be marked as unsuccessful.

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