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

Monitoring Frequency: 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. On-site monitoring must be performed at all sub-recipients at least once every two 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. 

Monitoring Toolkit:  The new monitoring new toolkit for VOCA Victim Assistance Administrators, which was created with input of fellow assistance administrators, is now available.  The Monitoring Toolkit has been added as a new tab on the MyVOCA site on the OVC TTAC website. MyVOCA Resources is a password-protected portal for use by State Assistance and Compensation Administrator staff.