Non-Federal Share Requirements for Head Start Agencies
At the Gravely Group, we’ve been getting a lot of questions about the non-federal share requirements for Head Start agencies.
On the federal Head Start website, it states:
The Head Start Act stipulates that the Federal share of the total costs of the Head Start program will not exceed 80 percent of the total grantee budget unless a waiver has been granted (Head Start Act Section 640(b)). If the grantee agency fails to obtain and document the required 20 percent, or other approved match, a disallowance of Federal funds may be taken. Non-Federal share must meet the same criteria for allowability as other costs incurred and paid with Federal funds.
What this means is that each Head Start agency that receives federal funds must provide at least 20% of their operating costs through in-kind donations or cash. These contributions must be used to support actual operations of a program and be used for expenses that a grantee would otherwise use federal funds for if those funds were available.
Non-federal share is not about “funny money” – these are essential costs to operating a successful Head Start program that are not borne by the federal government. The cost of a operating a program might be either federal or non-federal, but it is always going to be real.
While the requirement has always been there, since the Head Start Act of 2007, enforcement has stepped up. That’s why it’s more important than ever to make sure you’re meeting your non-federal share requirements and providing adequate documentation. If not, there could be a financial penalty.
One of the most common ways that Head Start agencies meet their share requirements is through in-kind donations of services and equipment. For example:
- A volunteer helped you put a website together or is helping manage social media for the agency
- A company provided free A/V equipment for an event or training
- A group of volunteers donated time and materials to update some of your playground equipment
- A local catering company donated food for your event
As a result of the non-federal share requirement, agencies are forced to think creatively about ways they might procure donated services or goods, or raise cash through grants and fundraising.
For some, however, meeting the share is impossible due to extraordinary circumstances. In those cases, agencies can apply for a waiver.
Waivers for Non-Federal Share – Head Start Act, Section 640(b)(1)-(5)
Waivers may be granted for the following reasons:
- Lack of community resources
- Impact of cost an agency may incur in the early years of the program
- Impact of an unanticipated increase in cost
- Community affected by disaster
- Impact upon the community if the program is discontinued
What about your agency? What are you doing to meet your non-federal share? Leave your comments below.
1. I have been researching inkind and found policy clarifications that are no longer listed on ECLKC but I also have not seen them amended. It was stated that State funded blended pre-k programs can be allowed as a match for program income. Is this current?
2. Policy Council parents that attend trainings and conferences that assist them with their decision-making can be counted as in-kind? is this current? I haven’t found anything that amended this inkind policy. Plus staff in Head Start recieve training all of the time to assist them with their decision making within the program and they receive regular pay. So I am almost positive that the Policy Council can earn in-kind for the same processes.
Our organization is currently struggling in this area. There is a disconnect between fiscal and the teachers and my job, as in kind coordinator, is to bridge that gap. In my review of the in kind sheets, the teachers seem to have the right idea, although it doesnt appear to be properly executed. For example: a classroom activity for Mother’s Day wherein the children made tissue paper flowers. The domain was physical well being and motor development; touch; grasp; coordinate use of hands, etc. The mothers spent an hour in the classroom. It is presumed that the parents helped children other than their own; however, it is not specifically stated on the in kind sheet. Fiscal denied the time sheets, indicating that this wasn’t considered a benefit to the program. I would love any feedback, as well as any suggestions. Many thanks!
Any time a parent assist in the classroom with or without helping their own child is considered in-kind.
Please use this information from the Performance Standards for your reference:
http://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/mang-sys/fiscal-mang/Non-Federal%20Share.htm
or this information from the Head Start Governing Body and Tribal Certification:
In-Kind Match: Property, goods, or services that benefit a grant-supported project or
program and are contributed by non-federal third parties without charge to the grantee. Inkind
contributions may consist of the value of real property, equipment, goods, and
services directly benefiting the grant program and specifically identifiable to it. In-kind
match is counted for the period when the services are provided or when the donated
goods are received and used.
I think the answer to that question is a little more nuanced, as a parent volunteering at a center that is helping only their child, in their role of a parent, rather than for the purpose of supporting the program, is not In-Kind. If a parent is supporting their child in a setting of children, for a program reason-such as an Associate Teacher would perform, and it is documented as such-it is In-kind.
The “In Kind ToolKit” that came out last year from OHS was pretty clear in its interpretation of the policy-determination of something for In-Kind is dependent on who receives the benefit of the action-which is why parent time working with their own children is limited to assignments issued individually, provided in writing, related to a specific program goal.
I work under Region 12 & 9, and my agency takes a conservative approach to In-Kind. Personally, if I received a sign in sheet for the activity you described, I would accept it; as long as it is documented as you described. If the documentation was along the lines of “Participated in Mother’s Day Activity”, or “Helped my child make a flower for me for Mother’s Day”, I would not accept it. It’s all in the documentation-which is a staff training issue.