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SUBRECIPIENT MONITORING a. The Department will monitorthe activities of the Subrecipient from award to closeout. The goal of the Department's monitoring activities will be to ensure that agencies receiving federal pass- through funds are in compliance with this Agreement, federal and state audii requirements, federal grant guidance, and applicable federal and state financial regulations, as well 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 updated 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 financial and 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), + 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 (Attachmeht E), and federal requirements; v. Observation and documentation 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 verifu completion of deliverabtes. d. The Subrecipient is required to meet or exceed the monitoring activities, as outlined above, for any non-federal entity to which the Subrecipient makes a subaward as a pass-through entity under this Agreement. e. Compliance will be monitored throughoutthe performance period to assess risk. Concerns will be addressed through a conective action plan. 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 (Titte Vl) prohibition against discrimination on the basis of national origin, which requires that Subrecipienis of federal financial assistance take reasonable steps to provide meaningful access to persons with limited English proficiency (LEP) to their programs and services. Providing meaningfui access for persons with LEP may entail providing language assistance seryices, including oral interpretation and written translation. Executive Order 13166, lmproving Access to Services for Persons with Limited 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 published the required recipient guidance in April 2011, DHS Guidance to Federal Financial Assistance Recipients Regarding Title Vl Prohibition against National Origin Discrimination Affecting Limited English Proficient Persons, 76 Fed. Reg. 2175$21768, (April 18, 2011). The Guidance provides helpful information such as how a recipient can determine the extent of its obligation to provide language services, selecting language services, and elements of an effective pian on language assistance for LEP persons. For additional assistance and information regarding language access obligations, please referto the DHS Recipient Guidance at https://www.dhs,gov/quidante-publisneO- help-department-suoported-oroanizations-orovide-meaninqful-access-peopm resources on hft ps://www. lep. gov. NIMS COMPLIANCE a. The National lncident Management System (NIMS) identifies concepts and principtes that answer how to manage emergencies from preparedness to recovery regardless of their cause, size, location, or complexity. NIMS provides a consistent, nationwide -approach and vocabulary for 7 8. 9. DHS-FEMA-HSGP-SHSP-FY2 1 Page 8 of42 Kittitas County, E22-131