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In-Kind Match Documentation: How to Value and Prove Donated Grant Match

Checked against official sources · 5 min read

In-kind match documentation is the paper trail that turns donated time, goods and space into match a funder will accept. On a federal award, volunteer hours or a donated room count only if you can show who gave what, when, and how you valued it. Here is what federal rules accept, how to value each contribution, what to keep and wording to adapt.

What counts as in-kind match

The Uniform Guidance (2 CFR 200.1) defines cost sharing as "the portion of project costs not paid by Federal funds or contributions", and says the term includes matching, meaning "required levels of cost share that must be provided." Third-party in-kind contributions are non-cash contributions of property or services that benefit the federally funded project and are given by non-federal third parties, without charge, to the recipient. So the contribution must come from someone other than your organization, and the project must actually use it. For example, National Endowment for the Arts (NEA) Challenge America grants are all for $10,000 and require a nonfederal cost share/match of at least 1 to 1, which "may be all cash, all in-kind (third-party) contributions, or a combination." Its match cannot include funds from any NEA or other federal award.

The seven tests every match item must pass

Under 2 CFR 200.306(b), a federal agency or pass-through entity must accept cost sharing, cash or in-kind, when it:

  • is verifiable in your records;
  • is not counted as a contribution to any other federal award;
  • is necessary and reasonable for achieving the objectives of the award;
  • is allowable under the cost principles in subpart E;
  • is not paid by the federal government under another award, unless the program's statute allows it;
  • is provided for in the approved budget when the agency requires it; and
  • conforms to the other provisions of 2 CFR 200.

A contribution you cannot trace to a record will not pass the first test. Unrecovered indirect costs can also count as cost sharing, but only with the prior approval of the federal agency or pass-through entity (200.306(c)).

How to value each type of contribution

Section 200.306 sets a method or a ceiling for each kind of contribution; write down the one you use.

Contribution How the value is set Rule
Volunteer services Rate you pay for similar work, or the local labor market rate when your staff lack the skill; allowable fringe may be added 200.306(e)
An employee lent by another organization That employee's regular pay plus reasonable fringe benefits, plus indirect costs at the lender's federally negotiated rate or a rate under 200.414(d), when they use the skills they are normally paid for 200.306(f)
Donated supplies and equipment No more than fair market value at the time of donation 200.306(g), (i)(2)
Donated space No more than the fair rental value of comparable space, set by an independent appraisal of comparable space in a privately owned building in the same locality 200.306(i)(3)
Loaned equipment No more than its fair rental value 200.306(i)(4)

What to keep in the file

Under 200.306(j), the fair market value of third-party in-kind contributions "must be documented and, to the extent feasible, supported by the same methods used internally" by your organization. If staff time is tracked on timesheets, track volunteer time the same way. A complete file usually holds:

  • Volunteer services: dated sign-in sheets or timesheets with hours, the task, the volunteer's signature and a supervisor's sign-off, plus the source of the hourly rate.
  • Lent employees: a letter from the lender with hours, pay rate and fringe rate.
  • Goods and equipment: a donor letter describing the items and their condition, with the evidence of value (receipt, quote or price list).
  • Space: a letter from the owner with dates, square footage and hours of use, plus the appraisal or comparable rental evidence.

The NEA is explicit about the risk: in its cost reimbursement instructions revised August 20, 2026, it "reserves the right to disallow any in-kind contributions that are not adequately documented." Keep these records with the award file: 2 CFR 200.334 requires you to retain federal award records for three years from the date you submit the final financial report.

A donor acknowledgement to adapt

Ask each donor to sign a short letter at the time of the gift, not at report time.

[Donor name or organization] confirms that on [date or period] it provided [description: hours of service, items, use of space] to [your organization] for [project title], grant [number], without charge. The value of [amount] is based on [method: our regular rate for this work, fair market value at donation, comparable local rent]. This contribution has not been and will not be counted as match for any other federal award. Signed: [name, title, date].

Put the match in your budget

Show in-kind match line by line, with the values you will report. In the Grant Budget & Justification Kit, the Budget tab of Essentials_BudgetJustification_Budget_TRACKER.xlsx calculates each line as quantity x unit cost and the share you request from this funder, and its Justification tab drafts one sentence per line, where you can name the in-kind source and its valuation method.

General information: this article is general information, not legal, tax or fundraising advice. No template can guarantee funding. Always follow each funder's own guidelines.

The Funder File is not affiliated with, endorsed by or connected to the National Endowment for the Arts.

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