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If project costs exceed the SAT due to cost overruns paid entirely with non-Federal funds, does the small grants waiver still apply?  No. Any project that is funded in whole or in part with federal assistance must comply with the BABA requirements.  The threshold for the small grants waiver is at the total award level, which includes all federal funds, cost share contributions, and other costs required to complete the approved project (i.e., “overmatch”).  Since the total costs exceed the SAT, the small grants waiver would not apply (see project expenses section above).

De Minimis General Applicability Waiver

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