How Do You Document In-Kind Match on a Federal Grant?

Sep 15 / Rachel Werner
In-kind match has real value to your program, but it never arrives with an invoice. This article explains what counts as in-kind match, how to value volunteer time and donated property, and what your records need to show under 2 CFR 200.306.
When your award includes a match, the cash portion is usually the easy part. It runs through your accounting system and shows up on a report without much extra effort.

In-kind matches work differently. Volunteer hours, donated meeting space, and a partner's staff time all have real value, but none of them come with an invoice. Unless someone builds the record as the contribution happens, that value can be hard to prove when a monitor or auditor asks for it.

What Counts as Match?

Under 2 CFR 200.1, cost sharing is the portion of project costs not paid by federal funds, and matching is a required level of cost share. Third party in kind contributions are property or services given to your project without charge by a non federal third party, such as volunteer time, loaned partner staff, donated supplies, or donated space.

Your organization should document these parameters in a written policy so staff understand what may count as in kind match, how contributions should be valued, and what records must be maintained.

If you pledged a match in your proposal that the program did not require, 2 CFR 200.1 treats that voluntary committed cost sharing as a binding requirement of the award.

What makes a contribution eligible to count?

Under 2 CFR 200.306(b), a contribution has to be verifiable from your records, necessary and reasonable, allowable under the cost principles, and not counted toward any other federal award. When the agency requires it, the contribution also has to appear in the approved budget.

Of those conditions, "verifiable from your records" is where in-kind match most often comes apart.

How do you document and value volunteer time?

Under 2 CFR 200.434, donated services should be supported, to the extent feasible, by the same methods you use for regular staff time. A record that holds up shows:

  • The volunteer's name
  • The date and hours contributed
  • The activity and how it connects to the grant
  • A supervisor's approval
  • The rate used to value the time


Under 2 CFR 200.306(e), that rate should be consistent with what your organization pays for similar work, or what's paid for similar work in your labor market. The rate follows the task, so a volunteer doing data entry is valued at a data entry rate regardless of what they earn in their day job.

When a partner organization lends you an employee, 2 CFR 200.306(f) values that time at the employee's regular pay plus allowable fringe benefits and indirect costs. Get those rates from the partner in writing at the start of the award.

How do you value donated property and space?

Donated equipment and supplies can't exceed fair market value at the time of donation. Donated space can't exceed the fair rental value of comparable space in the same area, as established by an independent appraisal (2 CFR 200.306). For each donation, keep a donor letter describing what was given, when, and how the value was set, along with any appraisal you relied on.

Final Thoughts

In-kind match reflects a community showing up for your program, and a simple record kept as the contribution happens is what lets that support count. This week, pick one active award and check that every in-kind entry has a name, a date, a value, and the source of that value.

Frequently Asked Questions

Can the same contribution count as a match on two federal grants?

No. Under 2 CFR 200.306(b), a contribution counted toward one federal award can't be counted toward another. Decide which award it supports and note that decision in both files.

What should we do if we're falling short of our committed match?

Check your award terms and contact your federal program officer or pass-through entity as soon as you see the gap. A shortfall raised during the period of performance leaves you more options than one discovered at closeout.

Can unrecovered indirect costs count toward our match?

They can, but only with prior approval from the federal agency under 2 CFR 200.306(c). If your organization doesn't recover its full indirect costs on an award, ask about using the unrecovered amount as cost share before you count it, and keep the approval in your grant file.