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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 />Recipients Regarding Title VI Prohibition against National Origin 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 information regarding language access <br />obligations, please refer to the DHS Recipient Guidance at https://www.dhs.gov/guidance-published- <br />help-department-supported-organizations-provide-meaningful-access-people-limited and additional <br />resources on https://www.lep.gov. <br />B. SLCGP SPECIFIC REQUIREMENTS <br />1. The Subrecipient must use SLCGP funds only to perform tasks as described in the Work Plan <br />(Attachments D) and the Subrecipient's approved application for funding incorporated into this <br />Agreement. <br />2. Subrecipients are required to annually complete the Nationwide Cybersecurity Review (NCSR) <br />https://www.cisecurity.org/ms-isac/services/ncsr, a free, anonymous, annual self -assessment <br />designed to measure gaps and capabilities of a SLT's cybersecurity programs to benchmark and <br />measure progress of improvement in their cybersecurity posture. Due dates are included in the <br />Timeline (Attachment F). For more information, visit Nationwide Cybersecurity Review (NCSR) <br />(cisecurity.org). <br />3. Subrecipients are required to participate in free cyber hygiene services, specifically vulnerability <br />scanning and web application scanning. To register for these services, email <br />vulnerabilitvCa cisa.dhs.gov with the subject line "Requesting Cyber Hygiene Services — SLCGP" to <br />get started. Indicate in the body of your email that you are requesting this service as part of the <br />SLCGP. For more information, visit CISA's Cyber Hygiene Information Page. <br />DHS-FEMA-SLCGP-FY23 <br />Page 9 of 39 Everett, E24-268 <br />