TLDR
DOJ Office for Victims of Crime and Violence Against Women Act grants carry semi-annual progress report requirements, a 25% match obligation, and a hard federal confidentiality rule that prohibits sharing any client identifier with funders or federal systems. Most client-tracking software violates the VAWA confidentiality rule by default. Organizations that mis-classify match or enter client-level data into PMT without understanding de-identification requirements risk both audit findings and federal sanctions.
BLUF
DOJ Office for Victims of Crime (OVC) and Violence Against Women Act (OVW/VAWA) grants require semi-annual aggregate progress reports filed through the Performance Measurement Tool (PMT), quarterly or semi-annual SF-425 Federal Financial Reports, and documented non-federal match of 20-25% depending on program. The VAWA confidentiality requirement is a hard legal prohibition - not a best practice - against disclosing any personally identifying information about service recipients to funders, federal systems, or any third party without explicit informed consent. Most commercial CRMs and case management platforms are not configured to honor this requirement by default.
TL;DR
- Report through: DOJ Performance Measurement Tool (PMT) - aggregate counts only, no client PII
- Report frequency: semi-annual progress reports; SF-425 FFR quarterly or semi-annual per award
- Match: 25% non-federal for most VAWA programs; 20% for most VOCA programs
- Confidentiality: VAWA prohibits disclosure of any victim PII without informed written consent
- Violation consequence: funding termination, OIG referral, civil liability
Who receives OVC and OVW grants
OVC administers Victims of Crime Act (VOCA) funds through state victim assistance formula grants and direct discretionary awards to victim service organizations. OVW administers more than 30 VAWA programs, including STOP (Services, Training, Officers, and Prosecutors) formula grants, Transitional Housing, and Legal Assistance to Victims.
Organizations receiving these funds typically serve survivors of domestic violence, sexual assault, dating violence, stalking, human trafficking, and other violent crimes. Nonprofit shelters, rape crisis centers, legal aid organizations, and tribal victim service programs are the core grantee population.
PMT: what it is and what it requires
The Performance Measurement Tool is the shared reporting portal for OVC and OVW grantees. Semi-annual reports are due 30 days after each reporting period ends:
- Period 1 (October 1 - March 31): report due April 30
- Period 2 (April 1 - September 30): report due October 31
PMT captures aggregate service counts: number of victims served, services provided by category (shelter nights, legal advocacy, crisis counseling, etc.), and training delivered. These counts come from internal case management records but must be derived and de-identified before entry. Individual client records are never entered into PMT.
Common PMT entry errors include:
- Double-counting clients served across service categories
- Reporting fiscal-year totals instead of period totals
- Entering new clients only (rather than all unduplicated clients)
- Missing service-category mapping when case management software categories don’t align with PMT taxonomy
VAWA confidentiality: the non-negotiable rule
Section 13925(b)(2) of the Violence Against Women Act prohibits any VAWA grantee or subgrantee from disclosing personally identifying information (PII) about a service recipient without:
- Informed, written, reasonably time-limited consent from the individual
- A statutory exception (law enforcement records with court order, mandated reporting obligations)
PII under VAWA covers names, addresses, phone numbers, email addresses, Social Security numbers, and any other information that could be used to identify or locate an individual.
The VAWA 2022 reauthorization strengthened these protections and clarified they apply equally to victim service organizations serving LGBTQ+ survivors and to tribal programs.
What this means for software
Most cloud-based CRMs and case management platforms store client contact records in databases accessible to system administrators, support staff, and in some configurations, via API integrations. If a funder or federal program officer can access your system - including through shared logins, integrations, or support ticket data - your CRM is potentially non-compliant.
Compliant data practices require:
- Client records stored separately from donor/funder-facing systems
- No PII transmitted to PMT or any federal reporting portal
- Confidentiality notices signed at intake and documented in files
- Subcontractor data agreements that include VAWA flowdown language
Match requirements and documentation
Most OVW VAWA programs require a 25% non-federal match. OVC VOCA programs typically require 20%. Match can be cash contributions or in-kind contributions, but federal funds from any other federal source cannot be used as match.
| Match type | Documentation required |
|---|---|
| Cash from state/local government | Copy of award letter or check, general ledger entry |
| Cash from private foundations | Copy of grant letter, bank deposit record |
| In-kind staff time | Timesheets signed by employee and supervisor, payroll records |
| Volunteer time | Contemporaneous log with date, activity, hours, and fair-market rate |
| Donated goods/services | Fair-market-value documentation, receipt or vendor estimate |
Match must be documented before close of the project period. After-the-fact reconstruction of volunteer hours or in-kind contributions fails audit under 2 CFR 200 cost principles.
SF-425 Federal Financial Report
In addition to the PMT progress report, grantees file SF-425 Federal Financial Reports on a schedule defined in the Notice of Award - typically quarterly or semi-annual. The SF-425 captures:
- Federal cash received and disbursed
- Accrued expenditures vs. liquidated expenditures
- Non-federal match contributed to date
- Program income (if applicable)
For shelter and direct-service programs where most costs are personnel, the SF-425 requires careful payroll cost allocation when employees split time across grant-funded and non-grant-funded activities. Time and effort documentation under 2 CFR 200.430 governs those allocations.
Budget modifications and prior approval
VAWA and OVC grants require prior approval from the DOJ awarding office for budget modifications exceeding 10% of the total award in any budget category. This threshold is stricter than the standard 10% de minimis in some federal programs, and the specific threshold varies by award - always confirm in the Notice of Award.
Common modification requests include:
- Shifting personnel costs between positions
- Adding new staff categories not in the original budget
- Extending the project period
- Adding match sources not identified in the original award
Submit modification requests well before the project period end date. DOJ awarding offices generally require 90 days’ lead time.
Common audit findings in OVC/VAWA programs
The DOJ Office of Inspector General and DOJ awarding offices most frequently find:
- Match shortfall - grantee did not meet the required non-federal match percentage by period end
- Unallowable costs - personnel costs charged without adequate time and effort documentation
- PMT data errors - aggregate counts not reconcilable to case management records
- Confidentiality violations - client PII in systems accessible to unauthorized parties
- Subgrantee monitoring failures - primary grantee did not verify subgrantee compliance with award conditions including confidentiality
How GrantPipe helps
GrantPipe tracks OVC and OVW awards as distinct entities with their own reporting calendars, match ledgers, and cost tracking. The compliance calendar surfaces PMT semi-annual due dates and SF-425 deadlines alongside all other federal reporting obligations. Match tracking separates cash and in-kind contributions with documentation status for each entry. GrantPipe does not serve as a client case management system - it is intentionally separated from any system that could hold victim PII, which is the correct architecture for VAWA compliance. Start with a free trial to set up your OVC or VAWA award tracking alongside the rest of your grant portfolio.
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- VAWA
- The Violence Against Women Act. Federal legislation first enacted in 1994 and reauthorized most recently in 2022 that funds programs addressing domestic violence, sexual assault, dating violence, and stalking. The Act imposes confidentiality obligations on all recipient and subrecipient organizations.
DEFINITION
- OVC
- Office for Victims of Crime. A component of DOJ's Office of Justice Programs that administers the Victims of Crime Act (VOCA) formula grants to states and discretionary grants to victim service providers.
DEFINITION
- OVW
- Office on Violence Against Women. The DOJ component that administers VAWA formula and discretionary grants. OVW and OVC share the PMT reporting portal but have separate grant conditions.
DEFINITION
- PMT
- Performance Measurement Tool. The federal online system used by OVW and OVC grantees to submit semi-annual aggregate service output data. PMT captures counts of victims served, services provided, and training delivered - not individual client records.
DEFINITION
- Match
- The non-federal share of total grant project costs required by the federal award. Most VAWA and OVC programs require 25% match from non-federal sources. Match must be documented and allowable under the same cost principles as direct costs.
DEFINITION
Q&A
How does a grantee document VAWA match without exposing client PII?
Match documentation for direct service activities should capture hours, service type, and the fair-market value of the time or goods - without client names or other PII. Internal case management systems can generate de-identified aggregate reports showing total hours by service category. Those aggregates feed the match schedule without any individual record crossing to the funder.
Q&A
What is the difference between OVC VOCA and OVW VAWA grants?
VOCA (Victims of Crime Act) grants flow from the Crime Victims Fund through OVC to state victim assistance programs, which sub-award to direct service organizations. OVW grants come directly from Congress to OVW and are awarded as formula or competitive discretionary grants. Both use PMT for reporting and both impose VAWA confidentiality requirements, but the specific award conditions, allowable costs lists, and matching rules differ.
Q&A
Does VAWA confidentiality apply to subcontractors?
Yes. VAWA confidentiality obligations extend to all subgrantees, subcontractors, and agents of the primary grantee. The grantee is responsible for flowing down the confidentiality requirements in writing and monitoring compliance. CRMs or case management platforms used by subcontractors must not store or transmit PII in ways that could be accessed by federal program officers or other funders.
Frequently asked