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in the DHS/FEMA EHP review process prior to project initiation. Modification of existing buildings, including minimally invasive improvements such as attaching monitors to interior walls, and training or exercises occurring outside in areas not considered previously disturbed also require a DHS/FEMA EHP review before project initiation. c. The EHP review process involves the submission of a detailed project description that includes the entire scope of work, including any alternatives that may be under consideration, atong with supporting documentation so FEMA may determine whether the proposed project has the potential to impact environmental resources and/or historic properties. d. The Subrecipient agrees that, to receive any federal preparedness funding, all EHP compliance requirements outlined in applicable guidance must be met. The EHP review process must be completed and approval received by the Subrecipient before any work is started for which reimbursement will be later requested. Expenditures for projects started before comptetion of the EHP review process and receipt of approval by the Subrecipient may not be reimbursed. 6. PROCUREMENT a, The Subrecipient shall comply with all procurement reguirements of 2 CFR Part 200.318 through 200.326 and as specified in the General Terms and Conditions, Exhibit B, A.10. b. For all sole source contracts expected to exceed $250,000, the $ubrecipbnt 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 requiremeni must be passed on to any non-federal entity to which the Subrecipient makes a subaward, at which point lhe $ubrecipient will be responsible for reviewing and approving sole source justifications of any non-Gderal entity to which the Subrecipient makes a subaward. 7, SUBRECIPIENTMONITORING 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 federal pas+ through funds are in compliance with this Agreement, federal and state audit 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 retum to the Department the "2 CFR Part 200 Subpart F Audit Certification Form" located at http://mil.wa.qov/emerqencv-management:division/qrants/requiredqrantforms with the signed Agreement and each fiscal year thereafter until the Agreement is closed, which is incorporated by reference and made a part of this Agreement. c. Monitofing 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.9. 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 and Budget (Attachment 2), and federal requirements; v. Observation and documentation of Agreement-related activities, such as exercises, training, funded 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 veriff completion of deliverables. 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 throughout the performance period to assess risk. Concerns will be addressed through a Corective Action Plan. DHS-FEMA-HSGP-SHSP-FFY19 Page 7 of 37 Kittitas County , E22-260