Guide
The 20% match, and how to prove it.
Every Head Start and Early Head Start grantee must raise a fifth of its budget from non-federal sources and document every dollar. Here's what counts, how to value it and what to keep.
Updated 2026-11-01
The rule
Section 640(b) of the Head Start Act limits the federal share of a program's costs to 80 percent, unless a waiver is granted. The other 20 percent, the non-federal share or match, must come from somewhere else. It can be cash or in-kind, "fairly evaluated, including plant, equipment, or services."
45 CFR 1303.4 restates the 80/20 split. A program that doesn't obtain and document its match risks having federal funds disallowed.
What counts
- Cash from non-federal sources: local government, foundations, businesses, individual donors.
- Donated goods: classroom supplies, books, food, furniture, equipment.
- Volunteer time: parents in the classroom, community members, professionals donating services.
- Donated space: a classroom, office or playground provided free or below market rent.
A contribution can't be counted toward the match of another federal award, and a volunteer paid under another federal grant can't be counted.
How to value it
Under 2 CFR 200.306, contributions only count if they're verifiable from your records:
- Donated goods at fair market value at the time of donation, never more.
- Volunteer services at the rate you'd pay for the same work, plus reasonable fringe benefits if appropriate.
- Donated space at fair rental value, documented with a supportable method.
What to keep
- For volunteers: a log with date, name, the activity, where it happened, hours (many programs use 15-minute increments) and the rate used, signed.
- For goods: who gave what, when it was received, the value and how you arrived at it.
- For space: the agreement and how the rental value was set.
- For everything: proof it benefited the Head Start program and isn't counted anywhere else.
Appeals board decisions show what goes wrong: in-kind amounts without backup and donated space claimed without a current appraisal have both been disallowed.
Where the match shows up
- SF-425 Federal Financial Report, filed three times per budget period: lines for the recipient share required, the share spent so far and the share still to be provided.
- Monthly financial statements to the governing body and Policy Council.
- The Program Information Report (PIR), which counts your volunteers.
- Your annual report to the public, which lists funds received by source.
How Donorly helps today, and what's coming
Donorly records the donated goods behind your match: a wishlist per classroom or site, pledges with drop-off times, items received with an estimated value and date, and a receipt for every donor. Child and family data stays in your Head Start data system.
Volunteer hours with sign-in, a rate and sign-off, and a match report by budget period, are coming soon. If you'd like to shape them, book a walkthrough.
Sources
- Head Start Act 640(b) and ACF-PI-HS-12-02, non-federal match
- 45 CFR 1303.4, non-federal match and waiver requirements
- 2 CFR 200.306, cost sharing or matching
- Head Start: Federal Financial Report (SF-425)
- Head Start Act 642(d)(2), reports to the governing body and Policy Council
- HHS Departmental Appeals Board, DAB No. 1265
- First Five Years Fund, Head Start and Early Head Start: the program overview (Oct 2026)
Keep reading
Head Start programs
Track the donated goods behind your 20% non-federal match, classroom by classroom.
→Wishlists and inventory
Public wishlists donors pledge and drop off from, in-kind receipts, and an inventory of what came in and went out.
→Donation receipt requirements
What the IRS expects a donation receipt to say, and when you must send one.
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