Can the court impose a jail fee for CRV?

Probably not. A judge may, under G.S. 7A-313, order a $40 per day jail fee for time spent in the jail “pursuant to a probationary sentence.” That authority applies to special probation confinement (a split sentence) and probably also to dip confinement imposed by a judge as a community and intermediate condition of probation. The fee probably may not, however, be ordered for a CRV period served in a jail. CRV is not a condition of probation like special probation or a dip. It is, rather, more akin to a partial activation of a suspended sentence, and a defendant is never required to pay a jail fee for time spent in jail pursuant to an active sentence.