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c. Monitoring activities may Include, but are not limited to: <br />1. Review of financial and performance reports; <br />11. Monitoring and documenting the completion of Agreement deliverables; <br />III. Documentation of phone calls, meetings (e.g., agendas, sign -in sheets, meeting minutes), 0- <br />malls and correspondence; <br />iv. Review of reimbursement requests and Supporting documentation to ensure allowabillity and <br />consistency with Agreement Work Plan (Attachments 0-1, D-2), Budget (Attachment E), and <br />federal requirements; <br />v. Observation and documentation of Agreement -related activities, such as exercises, training, <br />events, and equipment dernonstrations; 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 Subreciplent is required to meet or exceed the monitoring activities, as outlined above, for <br />any non-federal entity to which tile Subreciplent 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 />a, The Subreciplent 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 subreciplents 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, FEMA Policy EP-25 <br />__Q_01 <br />this reauirementapplies to anyong,pwarded FEMAfundj_nq.—Providing meaningful access for persons <br />with LEP may entail providing language assistance services, including oral interpretation and written <br />-translation. —Exectitive-Order-1-3-166,—Improviilg-Accoos-to-Services-for-Persons-with-Limited-English-- <br />Proficiency (August 1 11, 2000), requires federal agencies to Issue guidance to recipients, assisting <br />Such organizations and entities in understanding their language access obligations. DH8 published <br />the required recipient guidance In April 2011, DH8 Guidance to Federal Financial Assistance <br />Recipients Regarding Title VI Prohibition against National Orig 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 Inforimtion regarding language access <br />obligations, please refer to the DHS Recipient Guidance at <br />b. Subreciplents are encouraged to perform and document their analysis of the most appropriate <br />language assistance services necessary to ensure a LEP individual has meaningful access to the <br />SUbreciplent's programs and activities. The analysis should consider <br />I. The number or proportion of LEP individuals eligible to be served or likely <br />encountered by the program <br />ii. The frequency with which LEP Individuals come In contact with the program <br />III. The nature and Importance of the program, activity, or service provided by the <br />program to people's lives <br />iv. The resources available to the program and costs <br />B. HSGP SPECIFIC REQUIREMENTS <br />The objectives of the HSGP are to (1) build and sustain core capabilities, including Law Enforcement and <br />Terrorism Prevention Activities and the National Priority Areas; (2) address capability gaps Identified in <br />DHS+EMA-HSGP-SHSP-FY24 Page 10 of 48 Kittitas County, E25.224 <br />