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e. Equipment purchased with QHS federal award funds is to be marked with "Purchased with funds <br />provided by the U.S. Department of Homeland Security" when practicable. <br />f. Prior to procuring pharmaceuticals, Subrecipients must have in place an inventory management <br />plan to avoid large periodic variations in supplies due to coinciding purchase and expiration dates. <br />Subrecipients are encouraged to enter into rotational procurement agreements with vendors and <br />distributors. Purchases of pharmaceuticals must include a budget for the disposal of expired drugs <br />within each fiscal year's period of performance for 16HSGP. The cost of disposal cannot be <br />carried over to another DHS/FEMA grant or grant period. <br />As a subrecipient of federal funds, the Subrecipient must pass on equipment and supply <br />management requirements that meet or exceed the requirements outlined above to any non- <br />federal entity to which the Subrecipient makes a subaward of federal award funds under this <br />Agreement. <br />5. ENVIRONMENTAL AND HISTORICAL PRESERVATION <br />The Subrecipient shall ensure full compliance with the QHS/FEMA Environmental Planning and <br />Historic Preservation (EHP) Program. The Subrecipient is required to comply with DHS/FEMA EHP <br />Policy Guidance which can be found at htt s://www fema. ov/office-environmental-alannin -and- <br />historic-preservation; FP 108-023-1 Environmental Planning and Historic Preservation Policy <br />Guidance at htto://www.fema.gov/media-libr,apL/assets/`documents/85376; and FP 108.24.4 <br />Environmental Planning and Historical Preservation Policy at hftos://www.fema.gov/media- <br />library/assets/documents/101 537, all of which are incorporated in and made a part of this Agreement. <br />a. The Subrecipient proposing projects that have the potential to impact the environment, including, <br />but not limited to, construction of communication towers; modification or renovation of existing <br />buildings, structures and facilities; or new construction, including replacement of facilities, must <br />participate in the DHS/FEMA EHP review process prior to project initiation. Modification of existing <br />buildings, including minimally invasive improvements such as attaching monitors to walls, and <br />training or exercises occurring outside in areas not considered previously disturbed also require <br />a DHS/FEMA EHP review before project initiation. <br />b. The EHP review process involves the submission of a detailed project description that explains <br />the goals and objectives of the proposed project along with supporting.documentation so FEMA <br />may determine whether the proposed project has the potential to impact environmental resources <br />and/or historic properties. <br />c. The Subrecipient agrees that to receive any federal preparedness funding, all EHP compliance <br />requirements outlined in applicable guidance must be met. The EMP review process must be <br />completed and approval received before any work, for which reimbursement will be later <br />requested, is started. Expenditures for projects started before the EHP review approval is <br />received will not be reimbursed. <br />6. PROCUREMENT <br />a. The Subrecipient shall comply with all procurement requirements of 2 CFR Part 200.318 through <br />200.326 and as specified in the General Terms and Conditions, Exhibit B, A.10. <br />b. For all sole source contracts expected to exceed $150,000, the Subrecipient must submit to the <br />Department for pre -procurement review and approval the procurement documents, such as <br />requests for proposals, invitations for bids and independent cost estimates. This requirement must <br />be passed on to any non-federal entity to which the Subrecipient makes a subaward, at which <br />point the Subrecipient will be responsible for reviewing and approving sole source justifications of <br />any non-federal entity to which the Subrecipient makes a subaward. <br />i. SUBRECIPIENT MONITORING <br />a. The Department will monitor the activities of the Subrecipient from award to closeout, The goal of <br />the Department's monitoring activities will be to ensure that agencies receiving federal pass- <br />through funds are in compliance with this Agreement, federal and state audit requirements, <br />federal grant guidance, and applicable federal and state financial regulations, as well as 2 CFR <br />Part 200 Subpart F. <br />DMS-FEMA-HSGP-SHSP-FFY16 Page 6 of 25 Kittitas, County of, E17-075 <br />