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proposed project has the potential to impact environmental resources and/or historic <br />properties. <br />d. The Subrecipient agrees that to receive any federal preparedness funding, all EHP <br />compliance requirements outlined in applicable guidance must be met. The EHP review <br />process must be completed and FEMA approval received by the Subrecipient before <br />any work is started for which reimbursement will be later requested. Expenditures for <br />projects started before completion of the EHP review process and receipt of approval by <br />the Subrecipient will not be reimbursed. <br />6. PROCUREMENT <br />a. The Subrecipient shall comply with all procurement requirements of 2 CFR Part 200.317 <br />through 200.327 and as specified in the General Terms and Conditions (Attachment B, <br />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 an Audit Certification/FFATA form. This form <br />is required to be completed once per calendar year, per Subrecipient, and not per <br />agreement. The Department's Contracts Office will request the Subrecipient submit an <br />updated form at the beginning of each calendar year in which the Subrecipient has an <br />active agreement. <br />c. Monitoring activities may include, but are not limited to: <br />viii. Review of financial and performance reports <br />ix. Monitoring and documenting the completion of Agreement deliverables <br />x. Documentation of phone calls, meetings (e.g. agendas, sign -in sheets, meeting <br />minutes), e-mails and correspondence <br />xi. Review of reimbursement requests and supporting documentation to ensure <br />allowability and consistency with Agreement work plan, budget, and federal <br />requirements <br />xii. Observation and documentation of Agreement related activities, such as <br />exercises, training, events, and equipment demonstrations <br />xiii. 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. Concerns <br />will be addressed through a Corrective Action Plan. <br />DHS-FEMA-EMPG-FY22 <br />Page 8 of 39 City of Everett, E23-372 <br />