Common use of Source Documentation Clause in Contracts

Source Documentation. Travel costs • Copy of the government unit travel policy • Receipts/documentation as required by travel policy • Justification and/or approval from government entity for overage in per diem rates, etc. Personnel costs • Time and Effort documentation with detailed activity reports reflecting allowable work signed by employee and supervisor Contract costs • Copy of draft contract for eligibility review prior to contract award • Procurement documentation, copy of awarded contract for grant file • Deliverables listed in contract • Terms of payment outlined in contract • For contracts to an individual, a signature of the “contractor” is required. • Invoice (personnel service contracts require signature of contractor) Equipment costs • Complete Procurement Documentation to include “request for quote”, quotes, and complete bid package. • Current Contract which includes service period • Documentation that equipment is received on site and installed as necessary Meeting costs • Agenda/Course Description – should include time and dates • Attendance roster • Invoices Changes‌ Per 2 CFR Part 200, sub-grantees must obtain the prior approval of the awarding agency (Ohio EMA) in any case where a change is to be made to the scope of the project, regardless of budget impact. Ohio EMA will require all sub-grantees to request a budget modification and approval, to include EHP approval, through EGMS prior to costs being incurred for the item(s) to be changed. Costs incurred prior to appropriate actions being taken to modify and approve the budget may result in costs being denied for reimbursement. Budget modifications will be reviewed promptly by Ohio EMA Preparedness Grants Staff with an expectation that properly documented and submitted budget modifications are approved within seven to ten business days of submission. Procurement‌ The procurement process is one of, if not the most, scrutinized aspect of the federal grant programs. The emphasis on how procurements are made is based from the 2 CFR200 requirements that “all procurement transactions be conducted in a manner providing full and open competition with the standards of this section (§200.319)”. Additionally, sub-grantees must ensure that they meet the procurement requirements of the Ohio Revised Code and local procurement regulations. All sub- grantees are strongly urged to seek out their procurement department/individual to seek guidance on implementing the grant requirements into the procurement of any grant funded item or service. In accordance with this requirement, sub-grantees will be required to document actions that demonstrate compliance with the “full and open” regulation. 2 CFR 200 (§200.320) offers the following guidance in an effort to help sub-grantees navigate the requirements of procurement: The non-Federal entity must use one of the following methods of procurement:

Source Documentation. • Travel costs • o Copy of the government unit travel policy. Please specify if employee is being reimbursed directly by Fiscal Agent Jurisdiction or another local agency and their policy • o Receipts/documentation as required by travel policy o Federal Per Diem Policy must be followed unless the jurisdiction reimbursing employee has outlined their own specific per diems. • Justification and/or approval from government entity for overage in per diem rates, etc. Personnel costs • o Current official jurisdiction approved position description o Time and Effort documentation with detailed activity reports reflecting allowable work signed by employee and supervisor accomplishments as it pertains to the program and outlined in 2 CFR 200. • Contract costs • o Procurement Documentation o Copy of draft contract for eligibility review prior to contract award • Procurement documentation, copy o Copy of awarded contract for grant file • o Deliverables and timeline listed in contract • o Terms of payment outlined in contract • o For contracts to an individual, a signature of the “contractor” is required. • Equipment costs o Procurement o Contracts o Invoice (personnel service contracts require signature of contractornot quote) Equipment costs • Complete Procurement Documentation to include “request for quote”, quotes, and complete bid package. • Current Contract which includes service period • equipment purchased o Documentation that equipment is received on site and installed as necessary Meeting • Meeting/Conference/Training costs • o Procurement Documentation o Invoices o Contracts o Agenda/Course Description – should include time and dates • o Attendance roster • Invoices Changes‌ or Certification (certificate required for training) Per 2 CFR Part 200, sub-grantees subrecipients must obtain the prior approval of the awarding agency (Ohio EMA) in any case where a change is to be made to the scope of the project, regardless of budget impact. Ohio EMA will require all sub-grantees subrecipients to request a budget modification and approval, to include EHP approval, through EGMS prior to costs being incurred for the item(s) to be changed. Costs incurred prior to appropriate actions being taken to modify and approve the budget may result in costs being denied for reimbursement. Budget modifications will be reviewed promptly by Ohio EMA Preparedness Grants Staff Utilization of SHSP funds for equipment purchases requires that subrecipients maintain specific documentation on each item through its useful life until final disposition occurs. Per 2 CFR 200, procedures for managing equipment (including replacement equipment), whether acquired in whole or in part with an expectation that properly documented and submitted budget modifications are approved within seven to ten business days of submission. Procurement‌ The procurement process is one ofgrant funds, if not the mostuntil disposition takes place will, scrutinized aspect of the federal grant programs. The emphasis on how procurements are made is based from the 2 CFR200 requirements that “all procurement transactions be conducted in as a manner providing full and open competition with the standards of this section (§200.319)”. Additionallyminimum, sub-grantees must ensure that they meet the procurement requirements of the Ohio Revised Code and local procurement regulations. All sub- grantees are strongly urged to seek out their procurement department/individual to seek guidance on implementing the grant requirements into the procurement of any grant funded item or service. In accordance with this requirement, sub-grantees will following requirements: • Property records must be required to document actions maintained that demonstrate compliance with the “full and open” regulation. include (2 CFR 200 §200.313(d) Management requirements): o A description of the property, o A serial number or other identification number, o Source of funding for the property (including CFDA and XXXX) o Who holds title, o The acquisition date o Cost of the property, o The source of property, o Percentage of Federal participation in the cost of the property, o The location of the property, o Use and condition of the property, and o Any ultimate disposition data including the date of disposal and sale price of the property. • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. • A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft shall be investigated. • Adequate maintenance procedures must be developed to keep the property in good condition. • If the subrecipient is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. • Subrecipients who have purchased equipment with Federal funds must submit an annual inventory certification along with a current Master Asset Listing to the Grants Branch no later than January 31 of each year. The Master Asset Listing must be submitted in electronic format (Excel or .csv). The form is located on the Ohio EMA Grants Toolkit website. When the equipment is no longer needed for the original project and/or has outlasted its useful life, 2 CFR 200 §200.320200.313(e) offers prescribes the following guidance requirements for final disposition: • Items of equipment with a current per-unit fair market value of less than $5,000 may be retained, sold or otherwise disposed of with no further obligation to the awarding agency. • Items of equipment with a current per unit fair market value in an effort to help subexcess of $5,000 may be retained or sold. Approval from Ohio EMA must be secured before any disposition for items with a fair-grantees navigate the requirements market value in excess of procurement: $5,000. • The non-Federal entity may transfer title to the property to the Federal Government or to an eligible third party provided that, in such cases, the non-Federal entity must use one be entitled to compensation for its attributable percentage of the following methods fair market value of procurement:the property. • In cases where a recipient or subrecipient fails to take appropriate disposition actions, the awarding agency may direct the recipient or subrecipient to take excess and disposition actions. No subrecipient receiving FY2020 SHSP funding may sub-grant funding to another entity without prior coordination and approval from Ohio EMA. In order to be granted permission to sub-grant, the managing fiscal agent will have to demonstrate an ability to ensure compliance with all terms, conditions and requirements of the federal grant guidance and this guidance. Subrecipients are responsible for obtaining audits in accordance with the Single Audit Act Amendments of 1996 (31 U.S.C. 7501–7507); 31 U.S.C. 503, 1111; Executive Order 8248; Executive Order 11541; and 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” The audits shall be made by an independent auditor in accordance with generally accepted government auditing standards covering financial audits. Subrecipients must ensure that funds received and expended under this grant program are coordinated with the county’s fiscal office (treasurer, auditor, etc.).

Source Documentation. • Travel costs • o Copy of the government unit travel policy. Please specify if employee is being reimbursed directly by Fiscal Agent Jurisdiction or another local agency and their policy • o Receipts/documentation as required by travel policy o Federal Per Diem Policy must be followed unless the jurisdiction reimbursing employee has outlined their own specific per diems. • Justification and/or approval from government entity for overage in per diem rates, etc. Personnel costs • o Current official jurisdiction approved position description o Time and Effort documentation with detailed activity reports reflecting allowable work signed by employee and supervisor accomplishments as it pertains to the program and outlined in 2 CFR 200. • Contract costs • o Procurement Documentation o Copy of draft contract for eligibility review prior to contract award • Procurement documentation, copy o Copy of awarded contract for grant file • o Deliverables and timeline listed in contract • o Terms of payment outlined in contract • o For contracts to an individual, a signature of the “contractor” is required. • Equipment costs o Procurement o Contracts o Invoice (personnel service contracts require signature of contractornot quote) Equipment costs • Complete Procurement Documentation to include “request for quote”, quotes, and complete bid package. • Current Contract which includes service period • equipment purchased o Documentation that equipment is received on site and installed as necessary Meeting • Meeting/Conference/Training costs • o Procurement Documentation o Invoices o Contracts o Agenda/Course Description – should include time and dates • o Attendance roster • Invoices Changes‌ or Certification (certificate required for training) Per 2 CFR Part 200, sub-grantees subrecipients must obtain the prior approval of the awarding agency (Ohio EMA) in any case where a change is to be made to the scope of the project, regardless of budget impact. Ohio EMA will require all sub-grantees subrecipients to request a budget modification and approval, to include EHP approval, through EGMS prior to costs being incurred for the item(s) to be changed. Costs incurred prior to appropriate actions being taken to modify and approve the budget may result in costs being denied for reimbursement. Budget modifications will be reviewed promptly by Ohio EMA Preparedness Grants Staff Utilization of SHSP funds for equipment purchases requires that subrecipients maintain specific documentation on each item through its useful life until final disposition occurs. Per 2 CFR 200, procedures for managing equipment (including replacement equipment), whether acquired in whole or in part with an expectation that properly documented and submitted budget modifications are approved within seven to ten business days of submission. Procurement‌ The procurement process is one ofgrant funds, if not the mostuntil disposition takes place will, scrutinized aspect of the federal grant programs. The emphasis on how procurements are made is based from the 2 CFR200 requirements that “all procurement transactions be conducted in as a manner providing full and open competition with the standards of this section (§200.319)”. Additionallyminimum, sub-grantees must ensure that they meet the procurement requirements of the Ohio Revised Code and local procurement regulations. All sub- grantees are strongly urged to seek out their procurement department/individual to seek guidance on implementing the grant requirements into the procurement of any grant funded item or service. In accordance with this requirement, sub-grantees will following requirements: • Property records must be required to document actions maintained that demonstrate compliance with the “full and open” regulation. include (2 CFR 200 §200.313(d) Management requirements): o A description of the property, o A serial number or other identification number, o Source of funding for the property (including CFDA and XXXX) o Who holds title, o The acquisition date o Cost of the property, o The source of property, o Percentage of Federal participation in the cost of the property, o The location of the property, o Use and condition of the property, and o Any ultimate disposition data including the date of disposal and sale price of the property. • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. • A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft shall be investigated. • Adequate maintenance procedures must be developed to keep the property in good condition. • If the subrecipient is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. • Subrecipients who have purchased equipment with Federal funds must submit an annual inventory certification along with a current Master Asset Listing to the Grants Branch no later than January 31 of each year. The Master Asset Listing must be submitted in electronic format (Excel or .csv). The form is located on the Ohio EMA Grants Toolkit website. When the equipment is no longer needed for the original project and/or has outlasted its useful life, 2 CFR 200 §200.320200.313(e) offers prescribes the following guidance requirements for final disposition: • Items of equipment with a current per-unit fair market value of less than $5,000 may be retained, sold or otherwise disposed of with no further obligation to the awarding agency. • Items of equipment with a current per unit fair market value in an effort to help subexcess of $5,000 may be retained or sold. Approval from Ohio EMA must be secured before any disposition for items with a fair-grantees navigate the requirements market value in excess of procurement: $5,000. • The non-Federal entity may transfer title to the property to the Federal Government or to an eligible third party provided that, in such cases, the non-Federal entity must use one be entitled to compensation for its attributable percentage of the following methods fair market value of procurement:the property. • In cases where a recipient or subrecipient fails to take appropriate disposition actions, the awarding agency may direct the recipient or subrecipient to take excess and disposition actions. No subrecipient receiving FY2021 SHSP funding may sub-grant funding to another entity without prior coordination and approval from Ohio EMA. In order to be granted permission to sub-grant, the managing fiscal agent will have to demonstrate an ability to ensure compliance with all terms, conditions and requirements of the federal grant guidance and this guidance. Subrecipients are responsible for obtaining audits in accordance with the Single Audit Act Amendments of 1996 (31 U.S.C. 7501–7507); 31 U.S.C. 503, 1111; Executive Order 8248; Executive Order 11541; and 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” The audits shall be made by an independent auditor in accordance with generally accepted government auditing standards covering financial audits. Subrecipients must ensure that funds received and expended under this grant program are coordinated with the county’s fiscal office (treasurer, auditor, etc.).

Source Documentation. Part 200 also requires that accounting records be supported by such source documentation as cancelled checks, paid bills, auditor payroll journals, signed (by employee and supervisor) time and attendance records, contract and sub-grant award documents, etc. As such, Ohio EMA requires that sub-recipients have source documentation available prior to requesting cash reimbursement. Proper documentation for select items is as follows but not all inclusive but can be used as a minimum guideline:  Travel costs • o Copy of the government unit travel policy. Please specify if employee is being reimbursed directly by Fiscal Agent Jurisdiction or another local agency and their policy • o Receipts/documentation as required by travel policy • Justification and/or approval from government entity for overage in o Federal Per Diem Policy must be followed unless the jurisdiction reimbursing employee has outlined their own specific per diem rates, etcdiems.  Personnel costs • o Current official jurisdiction approved position description o Time and Effort documentation with detailed activity reports reflecting allowable work signed by employee and supervisor accomplishments as it pertains to the program and outlined in 2 CFR 200.  Contract costs • o Procurement Documentation o Copy of draft contract for eligibility review prior to contract award • Procurement documentation, copy o Copy of awarded contract for grant file • o Deliverables and timeline listed in contract • o Terms of payment outlined in contract • o For contracts to an individual, a signature of the “contractor” is required. •  Equipment costs o Procurement o Contracts o Invoice (personnel service contracts require signature of contractornot quote) Equipment costs • Complete Procurement Documentation to include “request for quote”, quotes, and complete bid package. • Current Contract which includes service period • equipment purchased o Documentation that equipment is received on site and installed as necessary  Meeting costs • o Procurement Documentation o Invoices o Contracts o Agenda/Course Description – should include time and dates • o Attendance roster • Invoices Changes‌ or Certification Per 2 CFR Part 200, sub-grantees recipients must obtain the prior approval of the awarding agency (Ohio EMA) in any case where a change is to be made to the scope of the project, regardless of budget impact. Ohio EMA will require all sub-grantees recipients to request a budget modification and approval, to include EHP approval, through EGMS prior to costs being incurred for the item(s) to be changed. Costs incurred prior to appropriate actions being taken to modify and approve the budget may result in costs being denied for reimbursement. Budget modifications will be reviewed promptly by Ohio EMA Preparedness Grants Staff with an expectation that properly documented and submitted budget modifications are approved within seven to ten business days of submission. Procurement‌ The procurement process is one of, if not the most, scrutinized aspect of the federal grant programs. The emphasis on how procurements are made is based from the 2 CFR200 requirements that “all procurement transactions be conducted in a manner providing full and open competition with the standards of this section (§200.319)”. Additionally, sub-grantees must ensure that they meet the procurement requirements of the Ohio Revised Code and local procurement regulations. All sub- grantees are strongly urged to seek out their procurement department/individual to seek guidance on implementing the grant requirements into the procurement of any grant funded item or service. In accordance with this requirement, sub-grantees will be required to document actions that demonstrate compliance with the “full and open” regulation. 2 CFR 200 (§200.320) offers the following guidance in an effort to help sub-grantees navigate the requirements of procurement: The non-Federal entity must use one of the following methods of procurement:.

Source Documentation.  Travel costs • o Copy of the government unit travel policy. Please specify if employee is being reimbursed directly by Fiscal Agent Jurisdiction or another local agency and their policy • o Receipts/documentation as required by travel policy • Justification and/or approval from government entity for overage in o Federal Per Diem Policy must be followed unless the jurisdiction reimbursing employee has outlined their own specific per diem rates, etcdiems.  Personnel costs • o Current official jurisdiction approved position description o Time and Effort documentation with detailed activity reports reflecting allowable work signed by employee and supervisor accomplishments as it pertains to the program and outlined in 2 CFR 200.  Contract costs • o Procurement Documentation o Copy of draft contract for eligibility review prior to contract award • Procurement documentation, copy o Copy of awarded contract for grant file • o Deliverables and timeline listed in contract • o Terms of payment outlined in contract • o For contracts to an individual, a signature of the “contractor” is required. •  Equipment costs o Procurement o Contracts o Invoice (personnel service contracts require signature of contractornot quote) Equipment costs • Complete Procurement Documentation to include “request for quote”, quotes, and complete bid package. • Current Contract which includes service period • equipment purchased o Documentation that equipment is received on site and installed as necessary Meeting  Meeting/Conference/Training costs • o Procurement Documentation o Invoices o Contracts o Agenda/Course Description – should include time and dates • o Attendance roster • Invoices Changes‌ or Certification (certificate required for training) Per 2 CFR Part 200, sub-grantees subrecipients must obtain the prior approval of the awarding agency (Ohio EMA) in any case where a change is to be made to the scope of the project, regardless of budget impact. Ohio EMA will require all sub-grantees subrecipients to request a budget modification and approval, to include EHP approval, through EGMS prior to costs being incurred for the item(s) to be changed. Costs incurred prior to appropriate actions being taken to modify and approve the budget may result in costs being denied for reimbursement. Budget modifications will be reviewed promptly by Ohio EMA Preparedness Grants Staff Utilization of SHSP-LE funds for equipment purchases requires that subrecipients maintain specific documentation on each item through its useful life until final disposition occurs. Per 2 CFR 200, procedures for managing equipment (including replacement equipment), whether acquired in whole or in part with an expectation that properly documented and submitted budget modifications are approved within seven to ten business days of submission. Procurement‌ The procurement process is one ofgrant funds, if not the mostuntil disposition takes place will, scrutinized aspect of the federal grant programs. The emphasis on how procurements are made is based from the 2 CFR200 requirements that “all procurement transactions be conducted in as a manner providing full and open competition with the standards of this section (§200.319)”. Additionallyminimum, sub-grantees must ensure that they meet the procurement requirements of the Ohio Revised Code and local procurement regulations. All sub- grantees are strongly urged to seek out their procurement department/individual to seek guidance on implementing the grant requirements into the procurement of any grant funded item or service. In accordance with this requirement, sub-grantees will following requirements:  Property records must be required to document actions maintained that demonstrate compliance with the “full and open” regulation. include (2 CFR 200 §200.313(d) Management requirements): o A description of the property, o A serial number or other identification number, o Source of funding for the property (including CFDA and XXXX) o Who holds title, o The acquisition date o Cost of the property, o The source of property, o Percentage of Federal participation in the cost of the property, o The location of the property, o Use and condition of the property, and o Any ultimate disposition data including the date of disposal and sale price of the property.  A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.  A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft shall be investigated.  Adequate maintenance procedures must be developed to keep the property in good condition.  If the subrecipient is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return.  Subrecipients who have purchased equipment with Federal funds must submit an annual inventory certification along with a current Master Asset Listing to the Grants Branch no later than January 31 of each year. The Master Asset Listing must be submitted in electronic format (Excel or .csv). The form is located on the Ohio EMA Grants Toolkit website. When the equipment is no longer needed for the original project and/or has outlasted its useful life, 2 CFR 200 §200.320200.313(e) offers prescribes the following guidance requirements for final disposition:  Items of equipment with a current per-unit fair market value of less than $5,000 may be retained, sold or otherwise disposed of with no further obligation to the awarding agency.  Except in limited circumstances, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold and the awarding agency (FEMA through Ohio EMA) shall have a right to an effort to help sub-grantees navigate amount calculated by multiplying the requirements current market value or proceeds from sale by the awarding agency's share of procurement: the equipment.  The non-Federal entity may transfer title to the property to the Federal Government or to an eligible third party provided that, in such cases, the non-Federal entity must use one be entitled to compensation for its attributable percentage of the following methods fair market value of procurement:the property.  In cases where a recipient or subrecipient fails to take appropriate disposition actions, the awarding agency may direct the recipient or subrecipient to take excess and disposition actions. No subrecipient receiving FY2019 SHSP-LE funding may sub-grant funding to another entity without prior coordination and approval from Ohio EMA. In order to be granted permission to sub-grant, the managing fiscal agent will have to demonstrate an ability to ensure compliance with all terms, conditions and requirements of the federal grant guidance and this guidance. Subrecipients are responsible for obtaining audits in accordance with the Single Audit Act Amendments of 1996 (31 U.S.C. 7501–7507); 31 U.S.C. 503, 1111; Executive Order 8248; Executive Order 11541; and 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” The audits shall be made by an independent auditor in accordance with generally accepted government auditing standards covering financial audits. Subrecipients must ensure that funds received and expended under this grant program are coordinated with the county’s fiscal office (treasurer, auditor, etc.).

Source Documentation. • Travel costs • o Copy of the government unit travel policy. Please specify if employee is being reimbursed directly by Fiscal Agent Jurisdiction or another local agency and their policy • o Receipts/documentation as required by travel policy o Federal Per Diem Policy must be followed unless the jurisdiction reimbursing employee has outlined their own specific per diems. • Justification and/or approval from government entity for overage in per diem rates, etc. Personnel costs • o Current official jurisdiction approved position description o Time and Effort documentation with detailed activity reports reflecting allowable work signed by employee and supervisor accomplishments as it pertains to the program and outlined in 2 CFR 200. • Contract costs • o Procurement Documentation o Copy of draft contract for eligibility review prior to contract award • Procurement documentation, copy o Copy of awarded contract for grant file • o Deliverables and timeline listed in contract • o Terms of payment outlined in contract • o For contracts to an individual, a signature of the “contractor” is required. • Equipment costs o Procurement o Contracts o Invoice (personnel service contracts require signature of contractornot quote) Equipment costs • Complete Procurement Documentation to include “request for quote”, quotes, and complete bid package. • Current Contract which includes service period • equipment purchased o Documentation that equipment is received on site and installed as necessary Meeting • Meeting/Conference/Training costs • o Procurement Documentation o Invoices o Contracts o Agenda/Course Description – should include time and dates • o Attendance roster • Invoices Changes‌ or Certification (certificate required for training) Per 2 CFR Part 200, sub-grantees subrecipients must obtain the prior approval of the awarding agency (Ohio EMA) in any case where a change is to be made to the scope of the project, regardless of budget impact. Ohio EMA will require all sub-grantees subrecipients to request a budget modification and approval, to include EHP approval, through EGMS prior to costs being incurred for the item(s) to be changed. Costs incurred prior to appropriate actions being taken to modify and approve the budget may result in costs being denied for reimbursement. Budget modifications will be reviewed promptly by Ohio EMA Preparedness Grants Staff Utilization of SHSP-LE funds for equipment purchases requires that subrecipients maintain specific documentation on each item through its useful life until final disposition occurs. Per 2 CFR 200, procedures for managing equipment (including replacement equipment), whether acquired in whole or in part with an expectation that properly documented and submitted budget modifications are approved within seven to ten business days of submission. Procurement‌ The procurement process is one ofgrant funds, if not the mostuntil disposition takes place will, scrutinized aspect of the federal grant programs. The emphasis on how procurements are made is based from the 2 CFR200 requirements that “all procurement transactions be conducted in as a manner providing full and open competition with the standards of this section (§200.319)”. Additionallyminimum, sub-grantees must ensure that they meet the procurement requirements of the Ohio Revised Code and local procurement regulations. All sub- grantees are strongly urged to seek out their procurement department/individual to seek guidance on implementing the grant requirements into the procurement of any grant funded item or service. In accordance with this requirement, sub-grantees will following requirements: • Property records must be required to document actions maintained that demonstrate compliance with the “full and open” regulation. include (2 CFR 200 §200.313(d) Management requirements): o A description of the property, o A serial number or other identification number, o Source of funding for the property (including CFDA and XXXX) o Who holds title, o The acquisition date o Cost of the property, o The source of property, o Percentage of Federal participation in the cost of the property, o The location of the property, o Use and condition of the property, and o Any ultimate disposition data including the date of disposal and sale price of the property. • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. • A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft shall be investigated. • Adequate maintenance procedures must be developed to keep the property in good condition. • If the subrecipient is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. • Subrecipients who have purchased equipment with Federal funds must submit an annual inventory certification along with a current Master Asset Listing to the Grants Branch no later than January 31 of each year. The Master Asset Listing must be submitted in electronic format (Excel or .csv). The form is located on the Ohio EMA Grants Toolkit website. When the equipment is no longer needed for the original project and/or has outlasted its useful life, 2 CFR 200 §200.320200.313(e) offers prescribes the following guidance requirements for final disposition: • Items of equipment with a current per-unit fair market value of less than $5,000 may be retained, sold or otherwise disposed of with no further obligation to the awarding agency. • Except in limited circumstances, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold and the awarding agency (FEMA through Ohio EMA) shall have a right to an effort to help sub-grantees navigate amount calculated by multiplying the requirements current market value or proceeds from sale by the awarding agency's share of procurement: the equipment. • The non-Federal entity may transfer title to the property to the Federal Government or to an eligible third party provided that, in such cases, the non-Federal entity must use one be entitled to compensation for its attributable percentage of the following methods fair market value of procurement:the property. • In cases where a recipient or subrecipient fails to take appropriate disposition actions, the awarding agency may direct the recipient or subrecipient to take excess and disposition actions. No subrecipient receiving FY2019 SHSP-LE funding may sub-grant funding to another entity without prior coordination and approval from Ohio EMA. In order to be granted permission to sub-grant, the managing fiscal agent will have to demonstrate an ability to ensure compliance with all terms, conditions and requirements of the federal grant guidance and this guidance. Subrecipients are responsible for obtaining audits in accordance with the Single Audit Act Amendments of 1996 (31 U.S.C. 7501–7507); 31 U.S.C. 503, 1111; Executive Order 8248; Executive Order 11541; and 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” The audits shall be made by an independent auditor in accordance with generally accepted government auditing standards covering financial audits. Subrecipients must ensure that funds received and expended under this grant program are coordinated with the county’s fiscal office (treasurer, auditor, etc.).