The purpose of subrecipient monitoring is to ensure that the subaward is being used for the authorized purpose, in compliance with the Federal statutes, regulations and the terms and conditions of the subaward, and the subaward performance goals are achieved.
All pass-through entities are required to monitor their subrecipients and monitoring must include such things as reviewing financial and performance reports, following up and ensuring subrecipients take timely and appropriate action on all deficiencies and issuing a management decision for audit findings as required by §200.521.
Rules and Regulations surrounding subrecipient monitoring are described in:
- 2 C.F.R. § 200.331 – Requirements for pass-through entities
- 2 C.F.R. § 200.521 – Management decisions
- DOJ Grants Financial Guide, Section 3.14 – Subrecipient Management and Monitoring
- 28 C.F.R. § 94.106 – VOCA subaward monitoring requirements
As described in 28 C.F.R. § 94.106, unless the Director grants a waiver, SAAs must develop and implement a monitoring plan, which must include a risk assessment plan. SAAs must conduct regular desk monitoring of all sub-recipients. Onsite monitoring must be performed at all subrecipients at least once every 2 years, unless a different frequency based on the risk assessment is set out in the monitoring plan.
Additional clarifications on subrecipient monitoring are located within VOCApedia and the Subgrantee Monitoring and Risk Assessment Principles training.
The monitoring toolkit for VOCA Victim Assistance Administrators was created with input of fellow assistance administrators. Access this toolkit on the MyVOCA Resources website. This site is a password-protected portal for State Assistance and Compensation Administrator staff.
Sample Suitability Determination Award Condition Subrecipient Monitoring Checklist
This sample checklist contains six sections to assist VOCA Victim Assistance Administrators in monitoring compliance with the OJP Suitability to Interact with Minors Special Condition.
Sections include: Applicability, Subrecipient Policies and Procedures, Subrecipient Practices, Availability of Fingerprint-Based Searches, Covered Individuals, and Pass-Through Administration.