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s igned 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 Agree ment 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 Attachment 2, and federal requirements <br />v. observation and docurnentation of Agreement-related activities, such as exercises, training, <br />funded events, and equipment demonstrations <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 Subreciplent 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 Subreciplent 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 Subreclplent 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 reclpieht gu idance In April 2011, DHS 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 DHS Recipient Guidance at https://www.dhs.gov/guidance-published- <br />he lp-department-supported-orqan lzations -prov,ide-mean 1ngful-access-peopte-llmited and additional <br />resources on http://www.lep.gov. <br />9. NIMS COMPLIANCE <br />a. The National Incident Management System (NIMS) identifies concepts and principles that answer <br />how to manage emergencies from preparedness to recovery regardless of their cause, size, <br />location, or complexity. NIMS provides a consistent, nationwide approach and vocabulary for <br />multiple agencies or jurisdictions to work together to build, sustain, and deliver the core <br />capabilities needed to achieve a secure and resilient nation. <br />b. Consistent implementation of NIMS provides a solid foundation across jurisdictions and <br />disciplines to ensure effective and integrated preparedness, planning, and response. NIMS <br />empowers the components of the National Preparedness System, a requirement of Presidential <br />Policy Directive 8, to guide activities within the public and private sector and describes the <br />planning, organizational activities, equipping, training and exercising needed to build and sustain <br />the core capabilities In support of the National Preparedness Goal. <br />c. In order to receive FFY 2017 federal preparedness funding, to include HSGP, the Subreclpient <br />will ensure all NIMS objectives have been initiated and/or are in progress toward completion. <br />DHS-FEMA-HSGP-SHSP-ffY17 Page 7 of 34 Kittitas County, E20-168