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completed and FEMA approval received by the Subrecipient before any work is started for <br />which reimbursement will be later requested. Expenditures for projects started before completion <br />of the EHP review process and receipt of approval by the Subrecipient may not be reimbursed. <br />6.PROCUREMENT <br />a. The Subrecipient shall comply with all procurement requirements of 2 CFR Part 200.318 through <br />200.326 and as specified in the General Terms and Conditions, Attachment B, A.10. <br />b. For all sole source contracts expected to exceed $250,000, the Subrecipient must submit to the <br />Department for pre -procurement review and approval the procurement documents, such as <br />requests for proposals, invitations for bids and independent cost estimates. This requirement must <br />be passed on to any non-federal entity to which the Subrecipient makes a subaward, at which <br />point the Subrecipient will be responsible for reviewing and approving sole source justifications of <br />any non-federal entity to which the Subrecipient makes a subaward. <br />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 />DHS-FEMA-HSGP-SHSP-FFY20 Page 7 of 40 Kittitas, County of, E24-059 <br />