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Non-Federal Match Narrative

Non-federal matching information and explanations of difficult fiscal issues such as contributions, disallowances, documentation, in-kind, and volunteer services can be found below. Head Start administrators and grantees may find this information helpful.

Overview of Requirements 
Clarifying Definitions 
Audit Requirements 
Related Links 
Related Program Instructions, Information Memorandums, and Appeals Board Decisions 
Related Links 
Related DABs 

Overview of Requirements

The Head Start Act stipulates that the federal share of the total costs of the Head Start program will not exceed 80 percent of the total grantee budget unless a waiver has been granted (Head Start Act Section 640(b)). If the grantee agency fails to obtain and document the required 20 percent, or other approved match, a disallowance of federal funds may be taken. Non-federal share must meet the same criteria for allowability as other costs incurred and paid with federal funds.

Clarifying Definitions

Allowable Cost: Third party in-kind contributions shall count toward satisfying a cost-sharing or matching requirement only where, if the party receiving the contribution were to pay for them, they would be an allowable cost. Allowable costs are determined by the tests of reasonableness, necessity and allocability as defined in Title 2 of the Code of Federal Regulations (2 CFR 220, 2 CFR 225, and 2 CFR 230).

Cash Contributions: The grantee's cash outlay, which is generated by the grantee or donated by a third party, and is expended to fund allowable program costs. Cash match counts toward the non-federal share requirement when expended, not when donated to or generated by the grantee.

Disallowance: A cost determined during an audit, or other review conducted by the funding agency, to be unallowable under the OMB Cost Principles and/or the Terms and Conditions of the grant award that may require subsequent repayment to the Head Start Bureau. A cost can be disallowed whether paid for by federal or non-federal sources.

Documentation: Written proof that a service has been provided or a donation has been received. Examples include receipts, timecards and invoices or proof of payment.

In-Kind: Property or services that benefit a grant supported project or program and are contributed by non-federal third parties without charge to the grantee. In-kind contributions may consist of the value of real property and equipment and the value of goods and services directly benefiting the grant program and specifically identifiable to it. In-kind match is counted for the period when the services are provided or when the donated goods are received and used.

Non-Federal Share: That portion of the total costs of the program provided by the grantee agency in the form of in-kind donations or cash match received from third parties or contributed by the agency. In-kind contributions must be provided and cash expended during the project period along with federal funds to satisfy the matching requirements.

Total Costs: All allowable costs of a program incurred by a grantee including the Federal and non-federal share. Total costs do not include those paid by other sources that are not part of the approved budget such as the U. S. Department of Agriculture (USDA). Total costs are net of applicable credits such as refunds and rebates.

Volunteer: An individual providing a service that is necessary to the operation of the Head Start program at no cost to a grantee agency. Waiver: A reduction in the required amount of grantee non-federal share that is authorized by a federal official in writing. A waiver is justified if it meets one of five criteria defined in the Head Start Act Section 640(b)(1)-(5).


Non-Federal Share is a statutory requirement of the Head Start Act Head Start Act Section 640(b)). Administrative requirements are codified in 45 CFR 74.23 and 45 CFR 92.24. As stated in the Act, the grantee agency must provide 20 percent of the total costs of the Head Start program unless a waiver has been granted.


There are five criteria for receiving a waiver:

  1. Lack of community resources.
  2. Impact of cost an agency may incur in the early days of the program
  3. Impact of an unanticipated increase in cost
  4. Community affected by disaster
  5. Impact upon the community if the program is discontinued

To receive a waiver or a reduction in the required non-federal share, the grantee agency must provide the ACF Regional Office written documentation of need. This request may be submitted with the grant proposal document or during the budget period if a situation arises that will make it impossible to meet the requirement. Approval of the waiver request cannot be assumed by the grantee agency without written notice from the ACF Regional Office.


The grant application must include proposed budgets for the federal and non-federal funds. The Notice of Award (NOA) constitutes approval of both the federal and non-federal budgets as described in the approved applications. The budget should be reflective of proposed sources of match. For example, the budget may be based upon historical data inclusive of volunteer hours, cash match and other donations.


The normally required 20 percent of the total grantee budget (federal funds plus non-federal share) is the same as 25 percent of the federal funds. An alternative method of calculation is: Federal funds divided by 0.8 (0.8 = 1.0 - 0.2) minus the federal share, which equals the non-federal share.

For example if the match is 20 percent:

Federal funds: $1,000,000 
Non-federal share = $1,000,000 / 0.8 = $1,250,000 minus the federal share of $1,000,000 = $250,000, which is the non-federal share.

This could be verified as: 
Federal share = $1,000,000 
Non-federal share = $ 250,000 
Total cost = $1,250,000 X 20% = $250,000

If the non-federal share is 10 percent, then:

Federal share = $1,000,000 / 0.9=$1,111,111 
Non-federal share = $1,111,111 - 1,000,000 = $111,111

This could be verified as: 
Federal share = $1,000,000 
Non-federal share = 111,111 
Total cost = $1,111,111 X 10% = $111,111

The required non-federal share for a budget period is calculated at the close of the period based upon the federal funds expended.


Factors affecting allowability of matching expenditures (whether cash or in-kind) are the same as for federal expenditures in that the costs must be reasonable, allocable, and necessary for the accomplishment of the project objectives and are allowable under the applicable cost principles. (Title 2 CFR 220, 2 CFR 225, and 2 CFR 230).

The Administration for Children and Families (ACF) enforces matching requirements on a budget period basis for the Head Start programs. (Other discretionary awards that have a defined project period, require matching requirements be met at any time during the project period. However, grantees are encouraged to provide match on a proportionate basis, although this is not a requirement.) Head Start grantees are required to meet matching requirements on a budget year basis. Match cannot be saved or "banked" for a future period. However, if a cash contribution is not expended in the year received, it can be used to meet the matching requirement in future periods.

Initial Early Head Start (EHS) grants were funded for a five-year project period. In these situations, the required match was not required to be met until the end of the project period. Beginning in 2000, however, all new EHS grants, funded on a competitive basis, were for an indefinite project period. For EHS grantees that are also Head Start grantees, the EHS will no longer be a separate program if they are in the same service area. Instead, EHS will be shown as a separate program account in the single grant document and will be subject to the same match requirements. In these cases, non-federal share will be counted towards the overall requirement regardless of the program that generated the match.

Match received from federal sources is not allowable unless there is specific statutory language allowing this use of federal funds. There are very few sources, which have been determined to be allowable.

The Bureau of Indian Affairs, Indian Self Determination Act (PL 93-638) authorizes the use of funds for matching purposes so long as the identified use is specifically related to the approved grant. An example of this match might include the provision of medical and/or dental services by a tribally operated health center, if it is operated under the authority of the Self Determination Act. Funds received under the Indian Child Welfare Act can be used to match other federal funds.

The primary source of allowable in-kind contributions for the Head Start program is the Head Start Program Performance Standards (45 CFR 1304). The Performance Standards contain the basic allowable activities of Head Start programs. Therefore, any cost or in-kind contribution directly associated with these activities is allowable.

Grantee agencies may propose an overmatch (e.g. greater than the required 20 percent required), but must be aware that once proposed and approved, they are required to provide the approved amount of match. Acceptance of proposed overmatch can be determined by a review of the NOA document.

Cash Match

Cash match can consist of state or local funds, or private or corporate donations. It cannot include funds received from any federal source except as defined in specific statutory language. The match is counted when expended, not when received. A grantee may provide matching in the indirect cost category by reducing the allowable charges to the grant per the indirect cost rate as approved in the indirect cost agreement. Grantees must be aware that this allowability is subject to the 15 percent administrative cost limitation.


All matching contributions must be verifiable from the grantee's records. This includes the source and application of cash match, services received and donations of supplies and equipment.

The use of volunteer time as match must include the establishment of a wage scale based upon the grantee agency's internal scale or prevailing wages in the area. Time sheets must be used to document hours contributed to the program. These time sheets must follow the same standards of documentation as employee time and attendance records, and must include:

  • Volunteer's name.
  • The dates, including year, the volunteer provided services.
  • The duration of time of services the volunteer provided to the program.
  • The volunteer's supervisor's signature.
  • The volunteer's signature.
  • The volunteer activity.
  • The rate applied to this activity.
  • Total valuation for the time period.

Documentation should be maintained on a regular basis. Programs may choose to use a monthly time sheet for regular volunteers or daily time sheets for occasional volunteers.

Documentation for receipt of supplies and/or equipment should include a copy of a receipt issued to the donor. Information on the receipt should include a description of the item, an estimate of the current fair-market value of the item, the date received and signatures of the donor and the recipient.

Accounting practices vary regarding the summarization and entry of the match into the agency general ledger or books of entry. To ensure internal control, cash match must follow the same cash controls as other agency revenue. For example, cash match might be maintained in the general ledger as a separate subaccount within the Head Start fund. This would provide a means of tracking the cash match and related expenditures. Third party in-kind service or other donations might be tracked on a spreadsheet at the Head Start office and the information given to the fiscal department monthly for entry to the general ledger if required by agency accounting policies and procedures. This could be accomplished by having general ledger accounts for non-federal share revenue and non-federal share expense.

Volunteer Services

Volunteer services are an integral part of the Head Start program. Professional and technical personnel, consultants, and other individuals, such as Head Start parents may furnish volunteer services. Each hour of volunteered service may be counted if the service is an integral and necessary part of the program. To count the time of a volunteer as match, the volunteer must be providing a service to and not receiving a service from the program. The procedures for valuing volunteer services are in 45 CFR 74.23 and 92.24.

If a volunteer's time is being paid under another federal grant, it may not be used for match. However, if a volunteer is paid from a grant that is funded by state and/or local and federal sources, (e.g. 60 percent state/local and 40 percent federal), part of the volunteers may be used as match. In this example, 60 percent of the costs may be used as match if the state/local funding is not already used as a match for the federal funds. It may be necessary for the agency to contact the volunteer's funding agency to verify the funding status. A volunteer's time may not be counted as match for more than one grant.

Volunteer time valuation should include fringe benefits. For example, if the agency has an estimated 30 percent fringe rate, then 30 percent should be allocated to volunteer time. In this case if a volunteer provides $100 of volunteer services (e.g. 10 hours at $10/hour), the total valuation would be $130 or $100 X 1.3.

For a volunteer's time to be counted as in-kind:

  • The services provided by the volunteer would have to otherwise be allowable costs that would be purchased from a consultant or other individual or provided by salaried personnel.
  • The duties of the individual must be controlled by the agency.
  • The value of the service provided by the individual must be measurable and material.
  • The value must be based upon the service provided by the individual. For example, a dentist who volunteers time to provide dental services to Head Start children, should have time valued according to normal compensation for the service provided. If the dentist chooses to volunteer as a volunteer in a different capacity, such as working in the classroom, his service should be valued according to the agency's current wage scale.

Consultants and other individuals may provide their services to a program at a reduced rate. The difference between this reduced rate and the amount normally charged by the individual may be used as in-kind. The grantee should have a written agreement with the individual, which will document the reduction, and documentation should be maintained of the services provided. This may be in the form of an invoice or other grantee developed form.

Time spent by governing bodies such as the Board of Directors, Tribal Councils and the Policy Council may be used as in-kind for time spent in their decision-making capacity related to the Head Start program. A reasonable valuation should be developed by the program, and applied based upon documentation from the meeting minutes and sign-in sheets. In determining the valuation, the agency or program should bear in mind the nature of the contribution rendered by these individuals. Policy Council time would be considered to be programmatic, however Board or Tribal Council time could be considered an administrative match that is subject to the 15 percent limitation.

The value of donated employee time can be used only in specific circumstances and only when the employee's time is given freely. Donated employee time can be used as in-kind only if the employee is not being compensated through salary, overtime or compensatory time, and if the service and time donated are not in the scope of the employee's paid employment. Consideration should be given to Fair Labor Standards Act requirements as well as agency personnel policies.

Allowability of parent volunteer time is based upon whether the parent is giving a service to the grantee or receiving a service from the grantee. For example, time spent by parents in special programs such as literacy is unallowable because the parent is not providing a service to the program. Time spent by a parent working in the classroom is allowable because a service is being provided to the program.

The time spent by parents on fundraising activities is unallowable as match because fundraising is specifically unallowable under the OMB Cost Principles. However, expenditure of the proceeds is allowable when expended for allowable program costs.

Donations of Supplies

As defined in 45 CFR 74.23 and 92.24, the agency should value third-party donations of supplies at their current fair market value of the supplies as determined by the agency using sources such as the guide issued by the IRS. Generally, donations of supplies to be used as gifts, prizes and awards are not allowable. Value of such items can be counted as match only if the program would otherwise have had to purchase the items to implement the program objectives. The Head Start Program Performance Standards provide the guidance to acceptable program objectives.

Donated Equipment

(45 CFR 74.23(h)(2)) Equipment, donated for use in a Head Start program, is defined as having a fair-market value greater than $5,000 and a useful life longer than a year. Equipment donated for use in the program may be valued at the market value of the equipment at the time of the donation. Documentation for the receipt of the equipment must include the description of the equipment and should reference the proposed use in the program and the condition at time of receipt. Donated equipment used as match is subject to equipment regulations found at 45 CFR 74.34.

Donated Equipment (45 CFR 92.24(e)) Title Passes to the Grantee

Equipment, donated for use in a Head Start program, is defined as having a fair-market value greater than $5,000 and a useful life that is longer than one year. Fair-market value at the time of the donation can be counted as in-kind if prior approval is received from ACF. If approval is not received, only depreciation or use-allowance can be counted as match. Donated equipment used as match is subject to equipment regulations found at 45 CFR 92.32.

Donated Land and Buildings (45 CFR 74.23(h)(1)) Title Passes to the Grantee

The value of donated land and buildings shall not exceed its fair market value at the time of donation to the grantee as established by an independent appraiser and certified by a responsible official of the grantee.

Donated Land (45 CFR 92.24(e)(2)(i)) Title Passes to the Grantee

If approval is obtained, the value of the donated land may be counted as cost sharing or matching. If approval is not obtained, no amount can be counted for donated land. Approval will be granted only if it can be determined that it would be appropriate to rent the land as an allowable direct cost.

Donated Buildings (45 CFR 92.24(e)(2)(ii)) Title Passes to the Grantee

ACF does not allow the fair market value of donated buildings to be counted as cost sharing or match for grantees subject to 45 CFR Part 92. Only depreciation or use allowances based on the property's market value at the time it was donated may be counted. They can be counted as match if not reimbursed as a direct or indirect cost.

Depreciation may be computed following any generally accepted method and is to be based on the acquisition cost of the building. The computation will exclude the cost of the land. Use allowance for buildings may be computed at an annual rate not to exceed two percent of acquisition cost.

Loaned Equipment or Space

Loaned equipment or space (e.g. the donor retains title) shall be valued at its current fair market rental rate.

Potential Disallowances

Failure to meet the non-federal share requirement without an approved waiver can have a severe impact on the grantee agency. 

An example of the impact of a disallowance of non-federal share follows: 

Funded     Actual  
Federal share: $ 800,000   Federal share expended:  $ 800,000
Required non-federal share: 200,000   Allowable non-federal share: 180,000
Total grant award: $ 1,000,000   Actual grant amount:  $ 980,000

Recalculated maximum federal share: $980,000 x 80% = $784,000 (80% of Actual grant amount)

Amount of disallowance: $800,000 - $784,000 = $16,000

The amount of disallowance must be repaid by the grantee agency from agency funds.  Federal funds may not be used to repay the disallowance.  The shortfall may be the result of a failure to accumulate the match, lack of documentation or incorrect valuation that results in a subsequent disallowance.  

Audit Requirements

Under the Single Audit Act, and OMB Circular A-133, auditors are required to assess internal control and compliance. In the area of non-federal share, this includes assessing whether the grantee agency provided the minimum amount of match required, that match allocated was allowable, and whether the grantee appropriately valued and documented match sources.

To accomplish this, the auditor must verify:

  • That the required matching contributions were met.
  • Ascertain the sources of matching contributions and perform tests to verify they were from an allowable source.
  • Test records to verify that the values placed on in-kind contributions (including third-party contributions) are in accordance with the OMB cost principles circulars, OMB Circular A-102, Title 2 CFR 215, program regulations and the terms of the award.
  • Test transactions used to match for compliance with the allowable costs/cost principles requirement.

Related Links

45 CFR 1301.20 Matching requirements
45 CFR 1301.21 Criteria for increases in federal assistance
45 CFR 74.23 Cost sharing or matching
45 CFR 74.24(b) Program income used to finance non-federal share
45 CFR 92.24 Matching or cost sharing
45 CFR 92.25(g)(3) Program income used to meet the cost sharing or matching requirement

Related Program Instructions, Information Memorandums, and Departmental Appeals Board Decisions

ACYF-IM-HS-01-06 Attachment: Considerations for Grantees with Multiple Sources of Funding
DAB Decision 1603 Telamon Corporation: Failure to Satisfy Non-federal matching requirements
DAB Decision 1787 White Mountain Apache Tribe: Failure to Meet Non-federal Matching Requirements

Related DABs

  • DAB Decision No. 1603: Telamon Corporation
  • DAB Decision No. 1787: White Mountain Apache Tribe

Last Updated: May 15, 2018