I would contact FN to get a accurate answer as I could not find any mention of the non reciprocating charging handle Phone: 703-288-3500 Fax: 703-288-4507 Email: info@fnamerica.com

Neely, no it is not. The NRCH version has a upc code of 845737013707. Also, the new NRCH model has a 2 added to the model number, so 38-100545-2 would be NRCH.

Neely, Buds Customer Service will need to verify whether or not this batch has the Non Reciprocating bolt with their Inventory Dept. at 1-859-368-0371 9am-9pm EST Mon-Fri. or use the Blue Chat now button at the bottom right corner 9am to 9pm Mon - Sat and 9am to 7pm Sunday.

It looks like The NRCH now comes on the new versions of the SCAR 20S, 17S and 16S rifles. But it is an "unlabeled update" the new versions appear to come with this as a standard feature and FN like sig doesn't always delineate new features, or models with a new upc/item number.
So it really comes down to date of manufacturer, you'd need to contact buds to get the serial number range, Call buds during buissnes hours at 859-368-0371, 9am-9pm eastern Mon-Fri
Or use the Blue Chat now button at the bottom right corner 9am to 9pm Mon - Sat and closed Sunday.
Then contact FN to see if that range is new production or pre 08-31-2021.
Contact FN
For customer service inquiries, call 1-800-635-1321 option 4,
Or info@fnamerica.com
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Or https://fnamerica.com/contact-us/
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Its going to take a bit of leg work for you to get a solids answer. But that's because there's not info put out by FN to positively identify the new from the old models.
Anyone on the community giving you a definitive answer is likely just guessing.