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Plain-English guide · for small nonprofits
2 CFR 200.306, explained in plain English
Updated September 2026
Match is where small nonprofits are strongest and least well documented. Volunteer hours count. They only count if you recorded them properly.
Match is cash or in-kind contributions you put toward the project alongside the federal money. Volunteer time counts, donated goods and space count, and your own unrecovered overhead can count with permission. All of it has to be verifiable in your records, and none of it can be counted twice.
The conditions every contribution must meet
- Verifiable in your records
- Not counted toward any other federal award
- Necessary and reasonable for the project's objectives
- Allowable under the cost principles
- Not paid for by another federal award, unless a statute allows it
- In the approved budget where the agency required that
"Verifiable in your records" is the one that fails. A number reported to a funder that exists only in an email thread is not verifiable.
Valuing volunteer time
Volunteer services count where the service is necessary for the program. That is the current wording, and it matters: guidance written before the 2024 revision says "integral and necessary part of an approved project," which is a different test. The rate is what you pay your own employees for similar work. Where the volunteer brings a specialized skill your organization does not employ, the rate is what that work commands in your local labor market. Reasonable, allocable fringe benefits may be included.
Note what this is not: a single national "value of a volunteer hour" figure. That number is useful for storytelling and is not the basis ยง200.306 gives you for match.
Donated goods, space and equipment
Value cannot exceed fair market value at the time of donation. For donated land and buildings, an independent appraiser establishes the value. Donated space is capped at the fair rental value of comparable space in a privately owned building in the same locality, and the section asks for that comparison to be established by an independent appraisal too. That second appraisal is the one organizations skip, and self-estimated donated space is a recurring audit finding. It also rules out valuing the free room a member offers at downtown office rates.
Unrecovered indirect costs
If your negotiated or de minimis rate would have produced more overhead than you actually charged, the difference can be counted as match, with prior approval from the federal agency or the pass-through entity. If you are a subrecipient, that second one is you: ask your pass-through, not the agency. For an organization struggling to find match, this is the most overlooked provision in the section.
What to actually do
Record volunteer hours the way you record payroll
Name, date, hours, what they did, and the rate basis. Retrofitting this at report time is where match falls apart.
Write down the rate basis once per role
Which employee rate or which labor-market rate, and why.
Ask about unrecovered indirect before you scramble for cash match
It needs prior approval, so it has to be raised early.
This is general information, not legal or accounting advice. Federal grant rules change and are applied differently by different agencies and auditors. Check with your auditor, your grant officer, or an attorney before relying on any of it.
The Ember tool for thisEmber Volunteers
Ember Volunteers lets volunteers sign up and log their own hours. The hours you count toward a match are recorded as they happen, not reconstructed later. Unlimited users on every tier.
Sources: 2 CFR Part 200 (eCFR), read 29 August 2026 and re-checked 1 September 2026. Federal grant rules change; check the current text before relying on this.