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completed and FEMA approval receaved by the Subrecipient before any work is started for which reimbursement will be later requesled, Expenditures fir projects starte-d before completion of the EHP review process and receipt of approval by the Subrecipient may not be reimbursed. 5. PROCUREMENT a. The Subrecipient shall comply with all procurement requirements of 2 CFR Part 200.918 through 200.326 and as specified in the General Terms and Conditions, Attachrnent B, A.10. b. For all sole source contracts expected to exceed $250,000, the Subrecipient must submit to the Department for pre-procurement review and approval the procurement documents, such as requests for proposals, invitations for bids and independent cost estimates. This requirement must be passed on to any non-federal entity to whlch the Subrecipient makes a subaward, at which point the Subrecipient will be responsible for reviewing and approving sole source justifi'cations of any non-federal entity to which the subrecipient makes a subaward, 7. SUBRECIPIENT MONITORING a. The Department will monitor the activities of the Subrecipient from award to closeout. The goal of the Department's monitoring activities will be to ensure that agencies receiving federaipass- through funds are in compliance with this Agreement, federaf and stale audi[ requirements, federal grant guidance, and applicable federal and state financial regulations, as weli as 2 CFR Part 200 Subpart F. b' To document compliance with 2 CFR Part 200 Subpart F requirements, the Subrecipient shall complete and return to the Department an Audit Certification/FFATA form. This form is requiredto be completed once per calendar year, per Subrecipient, and not per agreement. The Department's Contracts Office will request the Subrecipient submit an updatid form at the beginning of each calendar year in which the Subrecipient has an active agreement. c. Monitoring activities may include, but are not limited to: i. Review of financialand performance reports; ii. Monitoring and documenting the completion of Agreement deliverables; iii. Documentation of phone calls, meetings (e.g. agendas, sign-in sheets, meeting minutes), e- mails, and correspondence; iv. Review of reimbursement requests and supporting documentation to ensure allowability and consistency with Agreement Work Plan (Attachments D-1, D-2, D-3), Budget (Attachment E), and federal requirements; v. Observation and documenlation of Agreement-related activities, such as exercises, training, events, and equipment demonstrations; and vi' On-site visits to review equipment records and inventories, to veriff source documentation for reimbursement requests and performance reports, and to verif, completion of deliverables. d. The Subrecipient is required to meet or exceed the monitoring activities, as ouflined above, for any non-federal entity to which the Subrecipient rnakes a subaward as a pass-through entity under this Agreement. e. Compliance will be monitored throughout the performance period to assess risk, Concerns will be addressed through a conective action plan. 8. LIMITED ENGLISH PROFICIENCY (CIVIL RIGHTS ACT OF 1964 TITLE VI) The Subrecipient must comply with the Title Vl of the Civil Rights Act of 1964 (Tifle Vt) prohibition against discrimination on the basis of national origin, which requires that Subrecipienti'of federal financial assistance take reasonable steps to provide meaningiul access to persons w1h limited English proficiency..(LEP) to their programs and services. Providing meaningfui access for persons with LEP may entail providing language assistance services, including oral in-terpretation and written translation. Executive Order 13166, lmproving Access to Services for Persons witn Umiteo English Proficiency (August 11, 2000), requires federal agencies to issue guidance to recipients, assijting such organizations and entities in understanding their language access obligations. DHS publishedthe required recipient guidance in April 2011, DHS Guiaance to Federa-l Financial A'ssistance DHS-FEMA.HSGP-SHSP-FFYzO Page7 ol 41 Kittitas, County ol, E21-O82