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e. For OPSG Subrecipients, equipment purchased with DNS federal award funds is to be marked <br />with "Purchased with funds provided by the U.S. Department of Homeland Security" when <br />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 17HSGP. The cost of disposal cannot be <br />carried over to another DHSIFEMA grant or grant period. <br />The Subrecipient must pass on equipment and supply management requirements that meet or <br />exceed the requirements outlined above to any non-federal entity to which the Subrecipient <br />makes a subaward of federal award funds under this Agreement. <br />5. ENVIRONMENTAL AND HISTORICAL PRESERVATION <br />The Subrecipient shall ensure full compliance with the DHSIFEMA Environmental Planning and <br />Historic Preservation (EHP) Program. EHP program information can be found at <br />https:ltwww.fema.gov/office-environmental-planning-and-historic-preservation, all of which are <br />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 interior walls, <br />and training or exercises occurring outside in areas not considered previously disturbed also <br />require a DHS/FEMA EHP review before project initiation. <br />b. The EHP review process involves the submission of a detailed project description that includes <br />the entire scope of work, including any alternatives that may be under consideration, along with <br />supporting documentation so FEMA may determine whether the proposed project has the <br />potential to impact environmental resources 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 EHP 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.1 I , <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 />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.gov/emergency-management-division/grants/reguiredgrantforms with the <br />DI IS-FEMA-HSGP-S1ASP-FFY17 Page 6 of 34 Kittitas County, E20-168 <br />