11. ALLOWABLE VOLUNTEER SERVICES
FOR MATCHING REQUIREMENTS

     For a Head Start grantee to count volunteer services as part of its non-Federal match of Federal funds, several conditions must be met. These are briefly noted in the subsections below with excerpts of policy statements. The overriding principle concerning valuation of volunteer services is that all cost sharing or matching must comply with Federal accounting practices. It is, therefore, imperative that all procedures for the kinds of volunteer services and the recording and valuing of these services be developed with and approved by the agency's chief fiscal officer with the concurrence of an independent auditor. In developing these procedures, the complete Federal policies on cost sharing and matching ("HDS Discretionary Grants Administration Manual," TN86-1, Attachment A, Subpart G, and 0MB Circular A-122, "Cost Principles for Nonprofit Organizations," also contained in the Manual) should be used, as those sections reprinted here are, of necessity, not complete.
 

11.1 Cost Sharing or Matching
 

     Volunteer services are those provided to the Head Start program without cost to the agency. The services provided by persons supported by other Federal funds may not be used to meet Federal matching requirements. Many State programs are supported all or in part by Federal funds. The agency has to determine whether services from such sources meet Federal regulations for matching funds.

     Volunteer services may be counted as part of the matching requirement for one, and only one, Federal grant.

REFERENCE 
 TEXT CITATION 

"HDS Discretionary Grants 
Administration ManuaL" TN86-1, 
Attachment A--Administration of Grants. 
Federal Regulations, Title 45, Part 74, 
Subpart G, Cost Sharing or Matching. 

74.51 Definitions
Third-party in-kind contributions means property or services which benefit a grant-supported project or program and which are contributed by nonfederal third parties without charge to the grantee, the sub grantee or a cost-type contractor under the grant or sub grant.

"HDS Discretionary Grants 
Administration ManuaL" TN86-1, 
Attachment A--Administration of Grants. 
Federal Regulations, Title 45, Part 74, 
Subpart G, Cost Sharing or Matching 

74.53 Qualifications and exceptions
(b) Costs or contributions counted toward other Federal cost-sharing requirements 
Neither costs nor the values of the third-party in-kind contribution may count towards satisfying a cost-sharing or matching requirement of an HES grant if they have been counted towards satisfying cost-sharing or matching requirement of another Federal grant, a Federal procurement contract, or any other award of Federal funds.

"HDS Discretionary Grants Administration Manual." TN86-1. 

Chapter 3. Cost Principles and 
Procedures
B. Unallowable Costs 

Federal funds generally may not be used for...[unallowable costs nor may such costs be used to meet cost-sharing or matching requirements. Recipients should. consult the appropriate cost principles for specific guidance on allowable/unallowable costs.

"HDS Discretionary Grants 
Administration Manual" TN86-1, 
Attachment A--Administration of Grants. 
Federal Regulations, Title 45, Part 74, 
Subpart G, Cost Sharing or Matching 

74.53 Qualifications and exceptions
(e) Special standards for third-party in-kind contributions 

(1) Third-party in-kind contributions shall count towards satisfying a cost-sharing or matching requirement only where, if the party receiving the contributions were to pay for them, the payments would be allowable costs.
 

11.2 Services Provided Within Grant Period
 

     Only those volunteer services provided during the Federal grant period may be counted as part of the match for the Federal funds.

REFERENCE 
 TEXT CITATION 

"HDS Discretionary Grants 
Administration Manual" TN86-1, 
Attachment A--Administration of Grants. 
Federal Regulations, Title 45, Part 74, 
Subpart G, Cost Sharing or Matching 

74.52 Basic rule: Costs and contributions acceptable
With the qualifications and exceptions listed in 74.53, a cost-sharing or matching requirement may be satisfied by either or both of the following: 
    (a) Allowable costs... 

    (b) The value of third-party in-kind contributions applicable to the period to which the cost-sharing or matching requirement applies.
 

11.3 Services Provided from Outside Agency (Accounting Technicality)
 

     For accounting purposes, a distinction is made between volunteer services provided by persons separate from the agency and staff time donated to the Head Start program by the agency.

REFERENCE 
 TEXT CITATION 

"HDS Discretionary Grants 
Administration ManuaL" TN86-1. 

Chapter 2. Cost Sharing or Matching
D. Valuation of Third-Party In-Kind Contributions 

1. Volunteer Services 

Volunteer services are services which are not paid for by the recipient or cost-type contractor vis-a-vis the paid services a recipient may use to meet a cost-sharing or matching requirement. Volunteer services may be- furnished by professional and technical personnel, consultants, and other skilled and unskilled persons...
 

11.4 Services as an Indirect Cost

     If the agency applies an indirect cost rate, it will be necessary to determine whether the volunteer service,: if paid for, would be an indirect cost.

REFERENCE 
 TEXT CITATION 

"HDS Discretionary Grants 
Administration Manual." TN86-1, 
Attachment A--Administration of Grants. Federal Regulations, Title 45, Part 74, 
Subpart G, Cost Sharing or Matching 

74.53 Qualifications and exceptions
(e) Special standards for third-party in-kind contributions 

(2) A third-party in-kind contribution shall not count as direct cost sharing or matching where, if the party receiving the contributions were to pay for it, the payment would be an indirect cost....
 

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