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17 <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 maintainingcompliance with federal and <br /> state laws and regulations regarding the monitoring, documentation, and auditing 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 and the <br /> Subrecipient Monitoring Procedures (WMD Policy number 00-025-05.) <br /> b. The Sub-grantee shall perform under the terms of the Grant Agreement and the Department <br /> has responsibility for reasonable and necessary monitoring of the Sub-grantee's performance. <br /> The Department shall conduct Grant monitoring activities on a regular basis.- Monitoring is <br /> defined as any planned, ongoing, or periodic activity that measures and ensures. Sub-grantee <br /> compliance with the terms, conditions, and requirements of a Grant Agreement. • <br /> Monitoring involves prudent collection of information about Sub-grantee operations and is not <br /> limited to site visits or the completion of formal reviews. Monitoring may include periodic Sub- <br /> grantee reporting to the Department, Department review of audit reports, invoice reviews, onsite <br /> reviews and observations, and surveys. Adequate documentation is essential for effective <br /> Grant monitoring and will include copies of letters, meeting notes, and records of phone <br /> conversations as'evidence that conscientious monitoring has occurred during the period of the <br /> Grant Agreement. Subrecipient monitoring will occur throughout the year rather*than relying <br /> solely on a once-a-year audit. The Sub-grantee agrees to cooperate with all monitoring <br /> activities and to 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 Grant Agreement for "for-profit" subrecipients, since the-A-133 <br /> Single Audit does not apply to "for-profit" organizations. <br /> 3. RECORDS, MONITORING AND AUDIT ACCESS <br /> a. The Sub-grantee shall cooperate with and fully participate in all monitoring or evaluation <br /> activities that are pertinent to this Grant Agreement. <br /> b. Access to public records-The Sub-grantee 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 Sub-grantee shall maintain all books, records, documents, data and other evidence relating <br /> to this Grant Agreement and the provision of any materials, supplies, services and/or equipment <br /> under this Grant Agreement herein, including, but not limited to, records of accounting <br /> procedures and practices-that sufficiently and properly reflect all direct and indirect costs of any <br /> nature expended in the performance of this Grant Agreement. At no additional cost, these <br /> records, including materials generated under the Grant Agreement, shall be subject at all <br /> reasonable times to inspection', review and audit by personnel duly authorized by the <br /> Department, the Washington State Auditor's Office, and federal officials so authorized by law, <br /> rule, regulation, or contract. The Sub-grantee will retain all books, records, documents, and <br /> other materials relevant to this Grant Agreement and make them available for inspection, review <br /> or auditfor six (6) years from the end date of this Grant Agreement, date of final payment or <br /> conclusion of services performed under this Sub-grantee, whichever is later. If any litigation, <br /> claim or audit is started before the expiration of the six (6) year period, the records shall be <br /> • retained until final resolution of ail litigation, claims, or audit findings involving the records. <br /> BZPP 2010 1mge 7 of 19 Everett Police Department <br /> E12-215 <br />