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6. SUBRECIPIENT MONITORING <br /> 4 a. The County will monitor the activities of the Subrecipient from award to <br /> closeout. The goal of the County's monitoring activities will be to ensure <br /> that agencies receiving federal pass-through funds are in compliance with <br /> this Agreement, federal and state audit requirements, federal grant <br /> guidance, and applicable federal and state financial regulations, as well <br /> as 2 CFR Part 200 Subpart F. <br /> b. To document compliance with 2 CFR Part 200 Subpart F requirements, <br /> the Subrecipient shall complete and return to the County 2 CFR Part 200 <br /> Subpart F Audit Certification Form" located at <br /> http://mil.wa.gov/emergency-manaqement- <br /> division/grants/requiredgrantforms with the signed Agreement and each <br /> fiscal year thereafter until the Agreement is closed, which is incorporated <br /> by reference and made a part of this Agreement. <br /> 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 <br /> deliverables; <br /> iii. documentation of phone calls, meetings, e-mails, and <br /> correspondence; <br /> -iv. review of reimbursement requests and supporting documentation to <br /> • ensure allowability and consistency with Agreement work plan, <br /> budget, and federal requirements; <br /> v. observation and documentation of Agreement-related activities, such <br /> as exercises, training, funded events, and equipment demonstrations; <br /> vi. on-site visits to review equipment records and inventories, to verify <br /> source documentation for reimbursement requests and performance <br /> reports, and to verify completion of deliverables. <br /> d. The Subrecipient is required to meet or exceed the monitoring activities, <br /> as outlined above and in 2 CFR Part 200, for any non-federal entity to <br /> which the Subrecipient makes a subaward as a pass-through entity under <br /> this Agreement. <br /> e. Compliancy will be monitored throughout the performance period to <br /> assess risk. Concerns will be addressed through a Corrective Action <br /> Plan. <br /> 7. LIMITED ENGLISH PROFICIENCY(CIVIL RiGHTS ACT OF 1964 TITLE VI) <br /> All subrecipients must comply with the Title VI of the Civil Rights Act of 1964 <br /> (Title VI) prohibition against discrimination on the basis of national origin, which <br /> requires that subrecipients of federal financial assistance take reasonable steps <br /> to provide meaningful access to persons with limited English proficiency (LEP) to <br /> their programs and services. Providing meaningful access for persons with LEP <br /> may entail providing language assistance services, including oral interpretation <br /> and written translation. Executive Order 13166, Improving Access to Services for <br /> Persons with Limited English Proficiency (August 11, 2000), requires federal <br /> agencies to issue guidance to recipients, assisting such organizations and <br /> entities in understanding their language access obligations. DHS published the <br /> required reecipieent guidance in April 2011, DHS Guidance to Federal Financial <br /> Assistance Recipients Regarding Title VI Prohibition Against National Origin <br /> Discrimination Affecting Limited English Proficient Persons, 76 Fed. Reg. 21755- <br /> 21768, (April 18, 2011). The Guidance provides helpful information such as how <br /> a recipient can determine the extent of its obligation to provide language <br /> services; selecting language services; and elements of an effective plan on <br /> language assistance for LEP persons. For additional assistance and information <br /> regarding language access obligations, please refer to the DHS Recipient <br /> DHS-EMD—Snohomish Co. SHSP-15 Pag64of 37 City of Everett, E16-053 <br />