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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 an Audit Certification/FFATA form. This form is required <br />to be completed once per calendar year, per Subrecipient, and not per agreement. The <br />Department's Contracts Office will request the Subrecipient submit an updated form at the <br />beginning of each calendar year in which the Subrecipient has an active 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.g., agendas, sign -in sheets, meeting minutes), e- <br />mails, and correspondence; <br />iv. Review of reimbursement requests and supporting documentation to ensure allowability and <br />consistency with Agreement Work Plan (Attachments D-1, D-2, D-3), Budget (Attachment E), <br />and federal requirements; <br />v. Observation and documentation of Agreement -related activities, such as exercises, training, <br />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, for <br />any non-federal entity to which the Subrecipient makes a subaward as a pass-through entity <br />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, 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 />help-department-supported-organizations-provide-meaningful-access-people-limited and additional <br />resources on https://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 />DHS-FEMA-HSGP-SHSP-FY21 Page 8 of 42 Kittitas County, E22-131 <br />