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e. Monitoring aetivities nay include, but are nol 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.9., agendas, sign-in sheets, meeting mlnutes}, e- <br />mails and correspondence; <br />iv. Review of reimbursement requests and supporting documentation to enslre allowability and <br />consistency with Agreement Work Plan (Attachments D-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 demonstrations, and <br />vi. On-site visits to review equipment records and inventories, to verify source documentation ior <br />reimbursement requests and performance reports, and to verify completion of deliverables. <br />d. The Subrecipient is required to meet cr exceed lhe monitoring activities, as outlined above, for <br />any non-federal entity to which the $ubrecipient makes a subaward as a pass{hrough entity <br />under thi$ Agreement. <br />e. Compliance will be monitored throughout the performance period to assess risk. Concerns will be <br />addressed through a Correetive Action Plan. <br />s. LIMITED ENGLTSH PROFTCTENCY {Crvrr R|GHT$ ACT OF 1964 TITLE VU <br />a. The $ubrecipient must comply with the Title Vl cf the Civil Rights Act of 1964 (Title Vl) prohibition <br />against discriminalion on the basis of national origin, whioh requires that subrecipients of federal <br />financial assistance take reassnable steps to provide meaningful access to persons with limited <br />English proficiency (LEP) to their programs and services. FEMA Policv FP-256-23:001 <br />(www.fema.sov/sites/default/files/documentslfema loolicv-lanquaqe-access,ndfl further stresses <br />this reouiremenl apnlies to anvone awFrded FEMA-fundina" P:oviding meaningful access for persons <br />with LEP may entail providing language assistance serviees, including oral interpretation and written <br />translation. Executive Order 13166, lmproving Access to $ervices for Persons with Limited English <br />Proficiency {August 11, 2000), requires federal agencies to issue guidance to recipients, assisting <br />such organizations and entities in understanding their language access obligations. DHS published <br />the required recipient guidance in April 2011, nHS Guidance to Federal Financial Assistance <br />Recipients Regarding Title Vl Prohibition agaiast National Orig Discrimination Affecting Limited <br />English Proficient Persons, 76 Fed. Reg. 21755-21768, (April '18, 2011). The Guidance provides <br />helpful information such as how a recipient ean determine the extent of its obligation to provide <br />language services, selecting language services, and elements of an effective plan on language <br />assistance for LEP persons. For additional assistance and information regarding language acce$s <br />obligations, please refer to the DH$ Recipient Guidance at Lttps:llwww.dhs.qovlquidance-published- <br />help-department-supnorted-orsanizations-provide-meaninqful:access-peoole-lirnited and additional <br />resources on https:l/www. lep.qov. <br />b, $ubrecipients are encouraged to perform and document their analysis of the most appropriate <br />language assistance services necessary to ensure a LFP individual has meaningful access to the <br />$ubrecipient's programs and activities. The analysis should consider <br />1. 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 conlact with the program <br />i:i. The nature and impo(ance 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 REQUIREMENT$ <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 />nHS-FEMA-I-ISGP-SHSP-FY24 Page 10 of 48 Kittitas county.825-224