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E
<br />2. SUBRECIPIENT MONITORING
<br />a. The Department, as a Recipient and/or Pass -Through Entity, receives federal financial
<br />assistance under federal programs and is charged with maintaining compliance with federal
<br />and state laws and regulations regarding the monitoring, documentation, and monitoring of
<br />subrecipient grant activities using federal financial assistance. Management and
<br />implementation guidelines for the federal programs ensure compliance with statutes, grant
<br />guidelines, the sub -award agreement, Office of Management and Budget (OMB) circulars
<br />(including OMB Circular A-133), subrecipient audits, and other guidance found in the Federal
<br />Register. The Department shall adhere to its Subrecipient Monitoring Policy (Finance Policy
<br />02-006-06) and the Subrecipient Monitoring Procedures (Finance Procedure 02-006-06).
<br />b. The Contractor shall perform under the terms of the contract and the Department has
<br />responsibility for reasonable and necessary monitoring of the Contractor's performance. The
<br />Department shall conduct contract monitoring activities on a regular basis. Monitoring is defined
<br />as any planned, ongoing, or periodic activity that measures and reasonable assurance of
<br />contractor compliance with the terms, conditions, and requirements of a contract.
<br />Monitoring involves prudent collection of information about Contractor operations and is not
<br />limited to site visits or the completion of formal reviews. Monitoring may include periodic
<br />contractor reporting to the Department, Department review of audit reports, invoice reviews,
<br />onsite reviews and observations, and surveys. Adequate documentation is essential for
<br />effective contract monitoring and will include copies of letters, meeting notes, and records of
<br />phone conversations as evidence that conscientious monitoring has occurred during the period
<br />of the contract. Subrecipient monitoring will occur throughout the year rather than relying solely
<br />on a once -a -year audit. The Contractor agrees to cooperate with all monitoring activities and to
<br />comply with reporting requirements.
<br />The Department as the Recipient and/or Pass -Through Entity will conduct on-site visits as
<br />appropriate and required by contract for "for-profit" subrecipients, since the A-133 Single
<br />Audit does not apply to "for-profit" organizations.
<br />3. RECORDS, MONITORING AND AUDIT ACCESS
<br />a. The Contractor shall cooperate with and fully participate in all monitoring or evaluation activities
<br />that are pertinent to this contract.
<br />b. Access to public records -The Contractor acknowledges that the Department is subject to the
<br />Public Records Act, Chapter 42.56 RCW, and that records prepared, owned, used or retained
<br />by the Department relating to the conduct of government or the performance of any
<br />governmental or proprietary function are available for public inspection and copying, except as
<br />exempt under RCW 42.56 or other statute which exempts or prohibits disclosure of specific
<br />information or records.
<br />C. The Contractor shall maintain all books, records, documents, data, and other evidence relating
<br />to this contract and the provision of any materials, supplies, services and/or equipment under
<br />this contract herein, including, but not limited to, records of accounting procedures and practices
<br />that sufficiently and properly reflect all direct and indirect costs of any nature expended in the
<br />performance of this contract. At no additional cost, these records, including materials generated
<br />under the contract, shall be subject at all reasonable times to inspection, review and audit by
<br />personnel duly authorized by the Department, the Washington State Auditor's Office, and
<br />federal officials so authorized by law, rule, regulation, or contract. The Contractor will retain all
<br />books, records, documents, and other materials relevant to this contract and make them
<br />available for inspection, review or audit for six (6) years from the end date of this contract, date
<br />of final payment or conclusion of services performed under this contractor, whichever is later. If
<br />any litigation, claim or audit is started before the expiration of the six (6) year period, the records
<br />shall be retained until final resolution of all litigation, claims, or audit findings involving the
<br />records.
<br />DHS-FEMA-EMPG-FFY 10 Page 7 of 21 City of Everett Emergency Management
<br />72 E10-249
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