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process must be completed and approval received by the Subrecipient before any <br /> work is started for which reimbursement will be later requested. Expenditures for projects <br /> started before completion of the EHP review process and receipt of approval by the <br /> Subrecipient will not be reimbursed. <br /> 6. PROCUREMENT <br /> a. The Subrecipient shall comply with all procurement requirements of 2 CFR Part 200.318 <br /> through 200.326 and as specified in the General Terms and Conditions, Exhibit B, A.10. <br /> b. For all sole source contracts expected to exceed $250,000, the Subrecipient must submit <br /> to the Department for pre-procurement review and approval the procurement documents, <br /> such as requests for proposals, invitations for bids and independent cost estimates. This <br /> requirement must be passed on to any non-federal entity to which the Subrecipient makes <br /> a subaward, at which point the Subrecipient will be responsible for reviewing and <br /> approving sole source justifications of any non-federal entity to which the Subrecipient <br /> makes a subaward. <br /> 7. SUBRECIPIENT MONITORING <br /> a. The Department will monitor the activities of the Subrecipient from award to closeout. The <br /> goal of the Department's monitoring activities will be to ensure that agencies receiving <br /> federal pass-through funds are in compliance with this Agreement, federal and state audit <br /> requirements, federal grant guidance, and applicable federal and state financial <br /> regulations, as well as 2 CFR Part 200 Subpart F. <br /> b. To document compliance with 2 CFR Part 200 Subpart F requirements, the Subrecipient <br /> shall complete and return to the Department the "2 CFR Part 200 Subpart F Audit <br /> Certification Form" located at http://mil.wa.gov/emergency-management- <br /> division/grants/requiredgrantforms with the signed Agreement and each fiscal year <br /> thereafter until the Agreement is closed, which is incorporated by reference and made a <br /> part of this Agreement. <br /> c. Monitoring activities may include, but are not limited to: <br /> 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 <br /> minutes), e-mails and correspondence <br /> iv. Review of reimbursement requests and supporting documentation to ensure <br /> allowability and consistency with Agreement work plan, budget, and federal <br /> requirements <br /> v. Observation and documentation of Agreement related activities, such as <br /> exercises, training, funded events, and equipment demonstrations <br /> vi. On-site visits to review equipment records and inventories, to verify source <br /> documentation for reimbursement requests and performance reports, and to verify <br /> completion of deliverables. <br /> d. The Subrecipient is required to meet or exceed the monitoring activities, as outlined <br /> above, for any non-federal entity to which the Subrecipient makes a subaward as a pass- <br /> through entity under this Agreement. <br /> e. Compliance will be monitored throughout the performance period to assess risk. <br /> Concerns will be addressed through a Corrective Action Plan. <br /> 8. LIMITED ENGLISH PROFIENCY (CIVIL RIGHTS ACT OF 1964 TITLE VI) <br /> a. The Subrecipient must comply with the Title VI of the Civil Rights Act of 1964 (Title VI) <br /> prohibition against discrimination on the basis of national origin, which requires that <br /> Subrecipients of federal financial assistance take reasonable steps to provide meaningful <br /> access to persons with limited English proficiency (LEP) to their programs and services. <br /> Providing meaningful access for persons with LEP may entail providing language <br /> DHS-FEMA-EMPG-FY 19 Page 7 of 35 City of Everett OEM, E20-142 <br />