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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 />7. 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 />b. To document compliance with 2 CFR Part 200 Subpart F requirements, the Subrecipient shall <br />complete and return to the Department the "2 CFR Part 200 Subpart F Audit Certification Form" <br />located at http://mil. wa.qov/emerqency-management-division/grants/reguiredgrantforms with the <br />signed Agreement and each fiscal year thereafter until the Agreement is closed, which is <br />incorporated by reference and made a part of this Agreement. <br />c. Monitoring activities may include, but are not limited to : <br />i. Review of financial and performance reports; <br />ii. Monitoring and documenting the completion of Agreement deliverables; <br />iii. Documentation of phone calls, meetings, e-mails, and correspondence; <br />iv. Review of reimbursement requests and supporting documentation to ensure allowability and <br />consistency with Agreement Work Plan and Budget (Attachment 2), and federal requirements; <br />v. Observation and documentation of Agreement-related activities, such as exercises, training, <br />funded events, and equipment demonstrations; and <br />vi. On-site visits to review equipment records and inventories , to verify source documentation for <br />reimbursement requests and performance reports, and to verify completion of deliverables. <br />d. The Subrecipient is required to meet or exceed the monitoring activities, as outlined above and in <br />2 CFR Part 200, for any non-federal entity to which the Subrecipient makes a subaward as a <br />pass-through entity under this Agreement. <br />e. Compliance will be monitored throughout the performance period to assess risk. Concerns will be <br />addressed through a Corrective Action Plan. <br />8. LIMITED ENGLISH PROFICIENCY {CIVIL RIGHTS ACT OF 1964 TITLE VI) <br />The Subrecipient must comply with the Title VI of the Civil Rights Act of 1964 (Title VI) prohibition <br />against discrimination on the basis of national origin, which requires that Subrecipients of federal <br />financial assistance take reasonable steps to provide meaningful access to persons with limited <br />English proficiency (LEP) to their programs and services. Providing meaningful access for persons <br />with LEP may entail providing language assistance services, including oral interpretation and written <br />translation. Executive Order 13166, Improving Access to Services for Persons with Limited English <br />Proficiency (August 11, 2000), requires federal agencies to issue guidance to recipients, assisting <br />such organizations and entities in understanding their language access obligations. DHS published <br />the required recipient guidance in April 2011, OHS Guidance to Federal Financial Assistance <br />Recipients Regarding Title VI Prohibition against National Origin Discrimination Affecting Limited <br />English Proficient Persons, 76 Fed. Reg. 21755-21768, (April 18, 2011 ). The Guidance provides <br />helpful information such as how a recipient can determine the extent of its obligation to provide <br />language services, selecting language services, and elements of an effective plan on language <br />assistance for LEP persons. For additional assistance and information regarding language access <br />obligations, please refer to the OHS Recipient Guidance at https://www.dns .gov/quidance-published- <br />help-department-supported-organizations-provide-meaningful-access-people-limited and additional <br />resources on http://www.lep.gov. <br />DHS-FEMA-HSGP-SHSP-FFY18 Page 7 of 40 Kittitas County Sheriffs Office , E19-111