Legality of Matching Pledge With Federal Funds

A decision was requested as to whether the National Endowment for the Humanities (NEH) may lawfully accept a pledge from a nonprofit organization and match the pledge with an equal amount of federal funds. The money pledged was treated by the nonprofit organization as a reduction of accrued liability in fulfillment of a contractual obligation for services rendered. Since the money was not treated as a donation, matching it with federal funds is prohibited by statute and legislative history.