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d. The Subrecipient agrees that to receive any federal preparedness funding, all EHP <br />compliance requirements outlined in applicable guidance must be met. The EHP review <br />process must be completed and approval received by the Subrecipient before any <br />work is started for which reimbursement will be later requested . Expenditures for projects <br />started before completion of the EHP review process and receipt of approval by the <br />Subrecipient will not be reimbursed. <br />6. PROCUREMENT <br />a. The Subrecipient shall comply with all procurement requirements of 2 CFR Part 200.318 <br />through 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 <br />to the Department for pre-procurement review and approval the procurement documents, <br />such as requests for proposals, invitations for bids and independent cost estimates. This <br />requirement must be passed on to any non-federal entity to which the Subrecipient makes <br />a subaward, at which point the Subrecipient will be responsible for reviewing and <br />approving sole source justifications of any non-federal entity to which the Subrecipient <br />makes a subaward. <br />7 . SUBRECIPIENT MONITORING <br />a. The Department will monitor the activities of the Subrecipient from award to closeout. The <br />goal of the Department's monitoring activities will be to ensure that agencies receiving <br />federal pass-through funds are in compliance with this Agreement , federal and state audit <br />requirements, federal grant guidance, and applicable federal and state financial <br />regulations, as well as 2 CFR Part 200 Subpart F. <br />b. <br />C. <br />To document compliance with 2 CFR Part 200 Subpart F requirements, the Subrecipient <br />shall complete and return to the Department the "2 CFR Part 200 Subpart F Audit <br />Certification Form" located at http:1/mil.wa.gov/emergency-management- <br />divislon/grantslregui~edgrantforms with the signed Agreement and each fiscal year <br />thereafter until the Agreement is closed, which is incorporated by reference and made a <br />part of this Agreement. <br />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 <br />allowability and consistency with Agreement work plan, budget, and federal <br />requirements <br />v. observation and documentation of Agreement related activities, such as exercises, <br />training, funded events, and equipment demonstrations <br />vi. on-site visits to review equipment records and inventories, to verify source <br />documentation for reimbursement requests and performance reports, and to verify <br />completion of deliverables. <br />d. The Subrecipient is required to meet or exceed the monitoring activities, as outlined <br />above, for any non-federal entity to which the Subrecipient makes a subaward as a pass- <br />through entity under this Agreement. <br />e. Compliance will be monitored throughout the performance period to assess risk. <br />Concerns will be addressed through a Corrective Action Plan. <br />8. LIMITED ENGLISH PROFIENCY (CIVIL RIGHTS ACT OF 1964 TITLE VI) <br />a. The Subrecipient must comply with the Title VI of the Civil Rights Act of 1964 (Title VI) <br />prohibition against discrimination on the basis of national origin, which requires that <br />Subrecipients of federal financial assistance take reasonable steps to provide meaningful <br />access to persons with limited English proficiency (LEP) to their programs and services. <br />DHS-FEMA-EMPG-FY 18 Page 7 of 34 Kittitas County Sheriff's Office , E19-136