Resolution 220-1989
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RESOLUTION NO.
220
-1989
A RESOLUTION BY THE BOARD OF COUNTY
COMMISSIONERS OF MONROE COUNTY, FLORIDA,
AUTHORIZING THE MAYOR TO EXECUTE AN
AGREEMENT BETWEEN MONROE COUNTY AND
THE NATIONAL COUNCIL ON THE AGING, INC.
CONCERNING THE SUBGRANT AGREEMENT FOR THE
PERIOD OF JULY 1, 1989, TO JUNE 30, 1990.
BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF
MONROE COUNTY, FLORIDA, that the Mayor/Chairman of the Board
is hereby authorized to execute an agreement by and between
Monroe County, Florida and The National Council on The Aging,
Inc., a copy of same being attached hereto, concerning the
subgrant agreement for the period of July 1, 1989, to June 30,
1990.
PASSED AND ADOPTED by the Board of County Commissioners of
Monroe County, Florida, at a regular meeting of said Board held
on this ..1ftl. day of -4r"'; I , 1989, A.D.
BOARD OF COUNTY COMMISSIONERS
OF MONROE COUNTY, FLORIDA
By //lI~~
Mayor alrman
(Seal)
Attest: DANNY L. KOLHAGE, Clerk
.L2~'~~AD.~
APPROVED AS TO FORM
AND LEGAL SUFFICIENCY.
ByJ&1~ J~ (tQt(hj
Attorney's Office
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S'UBGRAR'l' AGRBBIIENT
THIS AGREEMENT is entered into by the National Council on the
Aging, Inc. (NCOA), hereinafter referred to as GRANTEE, and (name
of SUBGRANTEE) BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA ,
hereinafter referred to as SUBGRANTEE. The SUBGRANTEE agrees to
operate a project under the GRANTEE'S Senior Community Service
Employmen t Program ( SCSEP) in the manner described in the
approved Subgrant Narrative, as governed by the Older Americans
Act (OAA) Title V regulations, including all clauses and exhibits
included herein. This entire AGREEMENT is contingent in its
entirety on SUBGRANTEE' S strict confoxmance wi th its terms and
applicable state and Federal laws.
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GRAN'l'BB
'nIB RATIONAL COUlfCIL ON
'nIB AGING, INC.
600 Maryland Avenue, S.W.
West Wing 100
Washington, D.C. 20024
(202) 479-1200
SUBGRAN'l'EB
BOARD OF COUNTY COMMISSIONERS
OF MONROE COUNTY, FLORIDA
c/o Monroe County Department
of Social Services
1315 Whitehead St.
Key West, FL 33040
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S'UBGRAR'l' PERIOD:
July 1, 1989 to June 30, 1990
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8DBGRAB'1' BOIIBER:
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I'DRDIRG, SLOT LBVBLS.
pr.aCRM'R1\1T GOALS:
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2
700
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Pederal Punds Awarded
DOL Authorized BnrolJ.ent
Positions
176,700
N/A
40
N/A
40
BCOA Approyed BDrolJ.ent
Positions
40
N/A
N/A
40
Unsubsidized PlacwBut Goal
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10
IIethod of ~t
xx
Cost Reimbursement
Advance Payments
Por official _, subgrant purposes, the total, subgrant agreement
consists of this document which details contractual obligations,
any special conditions or changes noted as Article X, a line item
budget (RYhfhit A), and a narrative/project workplan (RYhfhit B).
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WITRESSE'l'H
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WHEREAS, the GRANTEE has received a Grant from the United
Sta te s Department of Labor, Employment and Training
Administration, for use in providing employment and training
opportuni ties for eligible persons pursuant to Title V of the
Older Americans Act, as amended; and
WHEREAS, the SUBGRANTEE, an independent contractor, has
established a program to provide services for said eligible
persons residing wi thin its jurisdiction; The GRANTEE and the
SUBGRANTEE desire to enter into an agreement whereby said GRANTEE
will distribute funds received under its grant to SUBGRANTEE for
use in the operation of said program.
The GRANTEE requires the competent performance of the
SUBGRANTEE in providing employment and training services as
specified in this AGREEMENT.
That the GRANTEE and the SUBGRANTEE acting by and through
their representatives, have collectively agreed and by execution
hereof are bound to the mutual obligations and to the performance
and accomplishments of the tasks and provisions hereafter
described.
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I. PROGRAK PURPOSE
A. Pro1ect Ob1ect.ives
The SUBGRAN'1'EE understands and agrees that the purpose of the
Senior Community Service Employment Program (SCSEP) is to
provide, foster, and promote useful part-time opportuni ties in
community service employment for low income persons who are 55
years of age or older and, to the extent feasible, to assist and
promote the transition of program enrollees to private or other
unsubsidized employment.
The primary objectives are to:
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1)
2)
3)
Provide needed wages to eligible individuals through
employment in service to the community.
Provide needed service to the community.
Provide. opportunities for entry/transition of program
participants into private or other unsubsidized employment.
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B. 80ecial Assurances
The project conducted under the Subgrant will:
1)
Provide employment only for eligible individuals, except for
necessary technical, administrative, and supervisory
personnel, but such personnel shall, to the fullest extent
possible, be recruited from among eligible individuals;
Provide employment for eligible individuals in the community
in which such individuals reside, or in nearby communities;
Employ eligible individuals in services related to publicly
owned and operated facilities and projects or in projects
sponsored by organizations, other than political parties,
exempt from taxation under the provisions of Section
501(c)(3) of the Internal Revenue Code of 1954, as amended,
except projects involving the construction, operation, or
maintenance of any facility used or to be used as a place
for sectarian religious instruction or worship.
Documentation of the 501 (c) (3) status of non-governmental
worksites must be retained on file;
Contribute to the general welfare of the community;
Provide employment for eligible individuals.
Result in an increase in employment opportunities over those
which would otherwise be available, but (i) not result in
the displacement of currently employed workers (including
partial displacement, such as reduction in the hours of non-
overtime work or wages or employment benefits), and (ii) not
impair existing contracts or result in the substitution of
Pederal funds for other funds in connection with work that
would otherwise be perfor.med;
Not employ or continue to employ any eligible individual to
perfor.m work the same or substantially the same as that
perfor.med by any other person who is on layoff;
Utilize methods of recruitment and selection (including
listing of job vacancies with the employment agency operated
by any State or political subdivision thereof) which assure
that the maximum number of eligible individuals have an
opportunity to participate in the project;
Include such training as may be necessary to make the most
effective use of the skills and talents of those individuals
who are participating, as well aa provide f.or the reasonable
expenses of individuals being trained, including reasonable
compensation for time spent in training;
Assure that safe and healthful conditions of work will be
provided and assure that persons employed in community
service jobs assisted under this Subgrant shall be paid
wages which shall not be lower than whichever is highest of
(i) the Ddnimum wage which would be applicable to the
employee under the Pair Labor Standards Act of 1938, if ,
Section 6(a)(1) of such Act applied to the participant and
2)
3)
4)
5)
6)
7)
8)
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if he/she were not exempt under Section 13 thereof, (ii) the
State or local minimum wage for the most nearly comparable
covered employment, or (iii) the prevailing rates of pay for
persons employed in similar public occupations by the same
employer, as well as, assure that the minimum wage and
maximum hours provisions of the Federal Fair Labor Standards
Act, as they apply to hospital and education institution
employees of state and local governments are followed,
Be established or administered with the advice of persons
who are competent in the field of service in which
employment is being provided and who are knowledgeable with
regard to the needs of older persons,
Authorize pay for necessary transportation costs of eligible
individuals which may be incurred in project-related
activities under this Subgrant in accordance with the
Federal regulations governing OAA Title V activities,
To the extent feasible, serve the needs of minorities,
handicapped individuals, individuals who are members of
Indian or Alaskan entities, Hawaiian natives, and l~ited
English-speaking individuals in proportion to their numbers
in the SUBGRANTEE'S geographic jurisdiction and take into
consideration their rates of poverty and unemployment.
Authorize funds to be used, to the extent feasible, to
include individuals participating in the project under a
State unemployment insurance plan,
Make available to each enrollee a written explanation of
allowable and unallowable political activities under Chapter
15 of Title V of the u.S. Code. The project shall post such
a notice,
Assure that SCSEP positions are distributed in an equitable
manner taking into consideration (1) the proportion which
eligible individuals bears to the total number of such
individuals in the geographic area(s) served, and (2) the
relative distribution of such individuals residing in rural
and urban areas. The equitable distribution of slots shall
be accomplished in concert with other Sponsors of SCSEP
activities,
In accord with congressional intent, take steps to
strengthen the coordination of program activities with the
private sector and with organizations charged with the
operation of employment projects, particularly with the Job
Corps and those programs funded under the authority of the
Job Tra:lning Partnership Act (~lTPA):
Make available to each enrollee materials regarding the Age
Discrimdnation in ~ployment Act. Said materials are to be
provided to the SUBGRANTEE by the GRANTEE, upon receipt of
same from the u.S. Department of Labor.
Assure, that all SCSEP activities are conducted in accord
with the provisions of the Drug-Free Workplace Act of 1988.
Assure compliance, as appropriate, with the provisions of,
Section 89 of the Internal Revenue Code.
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II. GRAN'TEE/SUBGRANTEE RELATIONSHIP
Leaal Authoritv
The SUBGRANTEE warrants that it is in compliance with all
applicable state and Federal requirements and standards and
that it possesses the legal authority pursuant to any
proper, appropriate and official motion, resolution or
action passed or taken, giving the SUBGRANTEE authority to
enter into this Subqrant, receive the funds authorized by
this Subgrant, and to perform the services the SUBGRANTEE
has obligated itself to perform under this Subgrant.
The person or persons signing and executing this Subgrant on
behalf of the SUBGRANTEE, or representing themselves as
persons authorized to sign and execute this Subgrant on
behalf of the SUBGRANTEE, do hereby warrant and guarantee
that they have been fully authorized by the SUBGRANTEE to
execute this Subgrant on behalf of the SUBGRANTEE and to
validly and legally bind the SUBGRANTEE to all the terms,
conditions, performances and provisions herein set forth.
The GRANTEE shall have the right to temporarily suspend or
terminate this Subgrant if there is a dispute as to the
legal authority of either the SUBGRANTEE or the person
executing this Subgrant. The SUBGRANTEE shall be totally
liable for return or reimbursement to the GRANTEE for all
monies received if the Subgrant is suspended or terminated.
1I'nfttt AvaJ.labili tv
That it is expressly understood and agreed by and between
the parties hereto that this agreement is wholly conditioned
upon the actual receipt by GRANTEE of Federal funds granted
by the Uni tad States Department of Labor, Employment and
Training Administration; that all monies distributed to
SUBGRANTEE hereunder shall be exclusively from Federal
monies received under said Grant, and not from any monies of
GRANTEE, and that if such funds are not timely forthcoming,
GRANTEE may, at its sole discretion, terminate this
agr....nt. The GRANTEE shall not be liable for p.yment for
any work or services performed by SUBGRANTE~ under or in
connection with this Subgrant beyond the effective date of
said termination.
If the funds anticipated to be received by GRANTEE, under
which this Subgrant is funded, are suspended or terminated,
in whole - or in part, funding for this Subgrant may cease.
GRANTEE will within a reasonable time from receipt of such
notice provide written notification to SUBGRANTEE.
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Payments under this Subgrant may be suspended or terminated
upon refusal of the SUBGRANTEE to accept any addi tional
conditions that may be imposed by the United States
Department of Labor and/or the GRANTEE at any time.
C. Indenendent Contractor
SUBGRANTEE shall operate hereunder as an independent
contractor, and not as an officer, agent, or employee of
GRANTEE. It is expressly agreed and understood between the
parties hereto, in entering into this agreement, that the
GRANTEE shall not be liable to the SUBGRANTEE for any
benefi ts or coverage as provided by Workers Compensation
Laws, and further anyone employed by the SUBGRANTEE shall
not be considered an employee of the GRANTEE for the purpose
of Workers Compensation coverage. SUBGRANTEE shall have
exclusive control of and the exclusive right to control the
details of the work and services performed hereunder, and
all persons performing same, and shall be solely responsible
for the acts and omissions of its officers, agents,
employees, subcontractors and program participants.
It is expressly understood and agreed that no officer,
agent, employee, or subcontractor of the SUBGRANTEE, is in
the paid service of GRANTEE; and that GRANTEE does have the
legal right to insure compliance with the tasks performed
hereunder by SUBGRANTEE, its officers, agents, employees,
subcontractors, or program participants. In no event shall
any person employed by the SUBGRANTEE be considered an
employee of the GRANTEE.
D. THIRD PARTY AGRBRII'RII'I'S
The SUBGRANTEE shall give advance notification to the
GRANTEE of any proposed third party agreements, including
but not limited to consultant contracts, agreements for
personal services, or any subcontract hereunder. The
SUBGRANTEE shall obtain the written consent of the GRANTEE'S
SCSEP National Director prior to subcontrac.ting. The
GRANTEE may, at its discretion, specific~lJ,y'approve in
writing any of the provisions of a third party agreement or
subcontract; however, such approval obtained as required by
thij clause shall not be construed to be a determination of
the allowabili ty of any cost under the subcontract.
Individual training courses for enrollees are subject to the
provisions of the SCSEP Procedures Manual, regarding approval
of enrollee training.
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E. Ind-.nification
SUBGRANTEE covenants and agrees to and does hereby indemnify
and hold harmless GRANTEE from and against any and all
injury, damage or destruction of property of GRANTEE arising
out of or in connection wi th all acts or omissions of
SUBGRANTEE, its officers, agents, employees, subcontractors,
invitees, licensees, or program participants, or caused in
whole or in part, by presumed negligence of officers,
agents, or employees of SUBGRANTEE.
In the event it is determined that SUBGRANTEE has misused,
misapplied or misappropriated all or any part of these grant
funds described herein, SUBGRANTEE agrees to indemnify, hold
harmless and defend GRANTEE and its officers, agents, and
employees, from and against any and all claims or sui ts
resulting from such misuse, misapplication or
misappropriation of such funds.
SUBGRANTEE shall be responsible for indemnifying GRANTEE for
any awards, costs, or penalties, including legal expenses,
arising out of SUBGRANTEE'S activities.
P.
tiscellaneous Provisions
(1 ) Personnel and Records Availabili tv
Personnel and records must be available to Authorized
Representatives of GRANTEE, the United States
Department of Labor, and the Comptroller General of the
United States.
Such authorized representatives shall, during business
hours, have access to, for inspection and copying:
books, records, memoranda, correspondence, personnel
staffing records, tapes or electronic transcriptions,
and any other documents. Authorized representatives
have the right to inspect the SUBGRANTEE'S facilities,
monitor and review, through on-site visits, all program
activities, personnel, staff, services, and
programmatic and administrative practices, supported
with funds under this Subgrant to ensure compliance
with the terms of this Subgrant.
GRANTEE'S staff shall monitor SUBGRANTEE, through on-
site visits and program data, all Subgrant activities, .
services, administrative and management practices,
funded in whole or in part through this Subgrant. Such
monitoring shall be announced and shall be accomplished
by data collection through comprehensive on-site review
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. of SUBGRANTEE' S records, interviews with
administrative/program'staff and participants, and by
the examination of worksites and work conditions.
SUBGRANTEE must make available for review and
duplication, at SUBGRANTEE's cost, all records required
for this monitoring process.
(2) Conflict of Interest
SUBGRANTEE shall establish safeguards to prohibit
persons funded in whole or in part by this agreement
from using their positions for a purpose th~t is, or
gives the appearance of being motivated by a desire for
private gain for themselves or others, particularly
those with whom they have family, business, or other
ties.
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(3) Lobbvina
SUBGRANTEE will not attempt to influence any member of
Congress, State or local legislator to favor or oppose
any legislation or appropriation with respect to this
agreement.
(4 ) SCODe of Aare-,ent
That this written instrument, including all Exhibits
attached to and incorporated herein, constitutes the
entire agreement by the parties hereto concerning the
work and services to be performed hereunder, and any
prior or contemporaneous, oral or wri tten agreement
which varies from the terms hereof shall be void.
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That the provisions of this agreement are severable and
if for any reason a clause, sentence, paragraph or
other Part of this agreement shall be" determined to be
invalid by a court, federal agency, board or commission
having jurisdiction over the subject matter thereof,
such invalidity shall not affect other provisions which
c8:n be given effect without the invalid provision.
Provided, however, that GRANTEE retains the right to
'revoke this AGREEMENT in its enti~ety, at GRANTEE'S
discretion, in the event of non~'compliance by
SUBGRANTEE or if GRANTEE has a reasonable basis for
believing the SUBGRANTEE is not or will not be carrying
out the project as specified herein and according to
GRANTEE's Program directives and' applicable state and
Pederal law. .
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III. GENERAL ADJIINISTRATIVE PROVISIONS
A. Period of Perforamce
That the term of this Subgrant shall be for the dates
specified on page 1 of this agreement, unless amended as
described in Article III, Clause I.
B. ~tal Funds Awarded
That it is understodd and agreed that in no event shall the
total distribution of federal grant funds made by GRANTEE to
SUBGRANTEE during the term of the Subgrant exceed the
specific amount agreed upon and set forth on page 1 of this
aqreement, unless amended as described in Article III,
Clause I.
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That it is further understood and agreed that the GRANTEE
will pay not more than 90 percent of the cost of any
project, and that the non-federal share may be cash and/or
in-kind contributions.
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c.
Subarant Identification
The SUBGRANTEE agrees to utilize the Subgrant Number on all
correspondence, communication, reports, vouchers, invoices,
publications, and all data concerning this Subgrant as
delivered hereunder.
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In the event the SUBGRANTEE makes any public announcements,
written or oral, publicizes or furnishes information on/or
concerning acti vi ties under this Subgrant, such i tam or
activity shall include information that the project is
funded by a Subgrant with The National Council on the Aging,
Inc.
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D.
rftlBnlJ.ance with ADDlicable Laws. Reaulat1cms and Guidelines
( 1 ) General Crwllnliance
That the SUBGRANTEE, its officers, agents, employees
and Bubcon'tractors:, shall, abide by and comply with all
laws, federal, state and local, and all rules and
regulations of GRANTEE. It is further agreed and
understood that as GRANTEE calls to the attention of
SUBGRANTEE any such violation on the part of SUBGRANTEE
or program participants, the SUBGRANTEE shall
immediately desist from and correct 'such violation.
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(2 ) Laws and Reaulations Incoroorated by Reference
The provisions of the following Acts, and applicable
regulations made pursuant to said Acts, and other
listed directives, are hereby incorporated by
reference.
Equal Employment Opportunity Directives.
Civil Rights Act of 1964 (PL 88-352).
Uniform Relocation and Assistance and Real
Property Acquisitions Act of 1970 (PL 91-646).
(3 ) Rnrollee Benefits
The SUBGRANTEE agrees to provide all program enrollees
with employee benefits as required by state and Federal
law and, in addi tion, as directed by the GRANTEE.
Pailure to comply with this paragraph shall constitute
grounds for revocation of this AGREEMENT. SUBGRANTEE
agrees to indemnify GRANTEE for any costs, awards,
penalties or associated expenses, including legal fees,
incurred. by the GRANTEE, arising out of SUBGRANTEE' S
enrollee benefit policies.
'P'InvI f "'q Obliaat.i,ons and Pavmen.ts
That in consideration of full and satisfa~tory performance
hereunder, GRANTEE shall be liable to SUBGRANTEE for the
actual costs incurred by SUBGRANTEE for performance
rendered, subject to the following limitations:
All
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B.
changes in said Acts, regulations, and directives
automatically incorporated into this Subgrant.
Title V of the Older Americans Act, as amended.
Ti tle V regulations found at 20 CFR Part 674,
including subsequent revisions or amendmen~s.
Contract Work Hours and Safety Standards Act (40
USC 327-332).
Office of Management and Budget (OMB) Circulars A-
87 and/or A-122.
U. S. Department of Labor Administrative
Regulations, at 41 CFR 29-70 and 29 CFR Part 96.
NCOA-SCSEP Procedures Manual.
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GRANTEE shall not be liable to the SUBGRANTEE for any costs
in excess of the budgeted amount.
GRANTEE shall not be liable to the SUBGRANTEE for
expenditures made in violation of regulations promulgated
under the Older Americans Act, violation of the regulations
found at 41 CFR 29-70 and Office of Management and Budget
Circulars A-87 or A-122, or in violation of any other
regulations and/or management circulars promulgated under
the Act or other statute or regulation.
GRANTEE may, at its sole discretion, make an initial advance
to SUBGRANTEE before insured or collateralized bank
account(s) have been established. No further advances shall
be made until GRANTEE has received proof from SUBGRANTEE
that such bank accounts have been insured or collateralized
in accordance with 12 U.S.C. 1821 (Supplement 176-1977).
SUBGRANTEE shall minimize the time period between the
transfer of cash from GRANTEE to SUBGRANTEE and the
disbursement of funds in. accordance with the Act,
regulations, management circulars and GRANTEE directives.
Advance funds requests are required to be limi ted to the
minimum amounts necessary for immediate disbursement needs
by the SUBGRANTEE for project expenditures. Maximum cash on
hand, at any given time, shall not exceed three (3) calendar
days of planned expenditures.
Payments under this Subgrant are conditioned in their
entirety upon SUBGRANTEE'S full and satisfactory performance
of its obligations under this Subgrant.
It is expressly understood and agreed by the parties hereto
that if SUBGRANTEE fails to submit to the GRANTEE in a
timely and satisfactory manner any report required by this
Subgrant, GRANTEE may, at its option and in its discretion,
withhold any or all payments otherwise due SUBGRANTEE
hereunder. GRANTEE may withhold payments until such time as
delinquent obligations are fulfilled by SUBGRANTEE.
The GRANTEE may withhold from payment to the, :~UBGRANTEE,
direct administrative costs and the indirect costs invoiced
for under this Subgrant for failure to submit required
reports accurately and timely. Amounts withheld will be
released upon submission of satisfactory reports.
If pr.1or approval has been provided by the GRANTEE, an
advance .' payment to the SUBGRANTEE may be made for
exceptional circumstances.
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G.
Interest-Bearing Bank Account
SUBGRANTEES (except for States) that are on an advance
payment system are required to maintain the advances
recei ved from the GRANTEE in an Interest-Bearing Bank
Account.
Interest earned in excess of $100 during the subgrant period
is required to be remitted to the GRANTEE.
The funds in the Interest-Bearing Bank Account may be
wi thdrawn by the SUBGRANTEE solely for the purposes of
making payments for items of allowable costs wi thin the
terms of this Subgrant, or to reimburse the GRANTEE in
accordance with closeout procedures.
Authorized representatives of the GRANTEE shall have access
to the books and records maintained by the Bank with respect
to such Interest-Bearing Bank Account at all reasonable
times and for all reasonable purposes, including, but not
limi ted to, the inspection or copying of such books and
records and any and all memoranda, checks, correspondence,
or other documents pertaining thereto.
Proaraa Income
All records and accounts of program income are to be
maintained and reported in accordance with the financial
management requirements contained in 41 CFR 29-70.205.
Money generated by any income-producing activity under this
Subgrant shall be applied to the cost of the activity, and
reimbursement under this Subgrant reduced accordingly by the
GRANTEE. Use of program income for other allowable Title V
acti vi ties requires the wri tten approval of the GRANTEE'S
SCSEP National Director.
B. Use of Pederal P1mds
Federal Funds received as a result of this Subgrant may be
expended only for purposes permitted under the provisions of
the Act, and within the authorized amount and time frame
prescribed in writing by the GRANTEE. .
12
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I. Subarant JIodifications and Chanoes
( 1 ) '.rille L1ai tations
That except as otherwise provided herein, any
alterations, additions, or deletions to the terms of
this Subgrant shall be by modification hereto in
writing and executed by both parties to this Subgrant.
Any modification pursuant to this Clause must be signed
by the duly authorized representative of the GRANTEE,
and an authorized agent of the SUBGRANTEE as specified
in Subgrant Article II.
If the SUBGRANTEE is directed to make any changes
whatsoever by any person other than the GRANTEE'S SCSEP
National Director, or his duly authorized
representatives, which they feel will change the period
of performance, require additional effort, affect the
cost of the Subgrant or change any other terms and
condi tions , the SUBGRANTEE shall immediately make a
written request to the GRANTEE'S SCSEP National
Director for official approval to proceed. The
SUBGRANTEE is cautioned that any changes prior to
official GRANTEE SCSEP National Director's written
approval shall be at SUBGRANTEE'S own risk.
(2) T.f"'e Itea '.rransfers
Flexibility of cost within the Subgrant budget will be
allowed provided that.
(a) The total cost of this Subgrant is not exceeded;
(b) The administrative portion of the budget is not
increased; and
(c) No single cost category is increased or decreased
by more than 5 percent.
(3 ) Other IIodifications
Prior approval is required for:
(a) A net increase or decrease from the approved
enrollment level exceeding 10 percent.
(b) Any significant changes in the scope of the
. _. project.
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The transfer of Federal funds allocated for
enrollee wages and fringe benefits to other
categories of expense.
The addition of any cost items requiring approval
in accordance with the provisions of Office of
Management and Budget Circulars A-87 and A-122.
(d)
l!hlllnaes
That any alterations, additions, or deletions to the
terms of this Subgrant which are required by changes in
Federal laws, and by Federal Regulations promulgated
pursuant thereto are automatically incorporated into
this agreement on the date designated by law or
regulation.
The parties hereto expressly agree that GRANTEE shall
have the right to make unilateral amendments to this
Subgrant necessary to assure conformity to federal law,
availability of funds, and regulations by the issuance
of written Notification of Change duly signed by the
GRANTEE'S SCSEP National Director. If such changes
cause an increase or decrease in the cost of
performance of this Subgrant or in the time required
for performance, an equitable adjustment shall be made
in the amount of funds obligated and the Subgrant shall
be modified in writing accordingly. If SUBGRANTEE
cannot conform to a Notification of Change, it shall
notify GRANTEE of same, in writing, within five (5)
working days of receipt of such Notification of Change.
Failure to agree on any adjustment shall be a -Dispute"
concerning a fact within the meaning of this Subgrant
and shall be submitted through GRANTEE'S normal
channels for resolution. However, nothing in this
clause shall excuse the SUBGRANTEE from proceeding with
the agreement as changed, until final resolution.
If SUBGRANTEE cannot conform to the changes required by
Laws, Federal Regulations promulgated pursuant thereto,
GRANTEE Directives or Management Circulars, then
SUBGRANTEE shall notify the GRANTEE in writing within
30 days of promulgation. GRANTEE may then establish
procedurep for the suspension or termination of
SUBGRANTEE'S programs, if appropriate, until such time
as the "Dispute" is finally resolved.
14
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Subarant TeDdnation
That the performance of work under the Subgrant may be
terminated by the GRANTEE in accordance with this Clause in
whole or in part:
(1)
TerminRtion for Cause
The GRANTEE or the StTBGRANTEE may terminate this
Subgrant when it has been determined that the other
party has failed to provide any of the services
specified, or failed to comply with any Federal
requirement or provisions contained within this
Subgrant. If the SUBGRANTEE fails to perform in whole
or in part the terms of this Subgrant or fails to make
sufficient progress so as to endanger performance, the
GRANTEE will notify the SUBGRANTEE of such
unsatisfactory performance in writing. The SUBGRANTEE
has ten ( 10) working days in which to respond with a
written plan acceptable to the GRANTEE for correction
of deficiencies. If the SUBGRANTEE does not respond
wi thin the appointed time with appropriate plans, the
GRANTEE shall serve a Notice of Termination on the
SUBGRANTEE which will become effective within thirty
(30) days after receipt. In the event of termination,
the GRANTEE shall be liable for payment only for
services prior to the effective date of the
termination, provided that such services are in
accordance with the provisions of this Subgrant and are
allowable costs as specified in the regulations.
(2)
....,......i nation for Convenience
Either the GRANTEE or SUBGRANTEE may request a
termination for convenience. Either party shall give a
thirty (30) day advance notice, in writing, of the
effective date of such a termination. The SUBGRAHTEE
shall be entitled to receive just and equitable
compensation for any allowable services satisfactorily
performed hereunder through the date of termination.
( 3 ) Rotice of Te.....i nlltion
Whenever for any reason the. GRANTEE shall determine
tha~ such termination is necessary for the GRANTEE, any
such termination shall be effective by delivery to the .
SUBGRANTEE of a Notice of Terminat.lon specifying
whether termination is for cause or for the convenience
of the GRANTEE, the extent to which performance of work
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under the Subgrant is terminated, and the date upon
which such termination becomes effective. Upon such
termina tion of this Subgrant, the GRANTEE will
determine the amount due the SUBGRANTEE, or otherwise,
such sum will in no event exceed the face value of this
Subgrant.
In the event of a partial termination, the portion of
the fee which is payable with respect to the work under
the continued portion of the Subgrant shall be
equitably adjusted by agreement between the SUBGRANTEE
and the GRANTEE, and such adjustment shall be evidenced
by a modification to this AGREEMENT.
CLOSEOUT PROCEDURES
The SUBGRANTEE will submit subgrant closeout data no later
than 45 days after the expiration of this agreement.
Guidelines for completion of the closeout package are
contained in the NCOA-SCSEP Procedures Manual. A SUBGRANTEE
who is delinquent in submitting a refund check may be
prohibited from entering into a Subgrant for the fiscal year
following the Subgrant closeout period, and/or payments
under an existing subgrant may be suspended.
IV. PINANCIAL JlAHAGBIIENT PROVISIONS
Accountina Svstem
The SUBGRANTEE will maintain complete and accurate records
justifying all actual and accrued expenditures, leaving a
clear audit trail to the point of origin. Costs shall be
segregated, as directed within the framework of this
Subgrant. Also, an accrual reporting system shall be
implemented and maintained, and utilized for monthly
reporting of program expenditures.
That in the event that GRANTEE determines that the record-
keeping system of SUBGRANTEE does not comply with Federal
guidelines, financial accounting may be done by an
accounting firm approved. by GRANTEE. Tbe Cost shall be
deducted monthly from the funds allocated to SUBGRANTEE.
SUBGRANTEE shall retain on file written evidence to support
all expendi tures accrued, on a monthly basis, and report
such expenditures to GRANTEE. SUBGRANTEE shall maintain
accounts "in such a way that they are traceable to source
documentation of unit transactions. Source documents will
be maintained for all transactions.
SUBGRANTEE shall insure that GRANTEE, the Comptroller
General of the United States, the U.S. Department of Labor,
16
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or any of their authorized agents have the right of access
for examination and reproduction of any books, accounts or
records of SUBGRANTEE and its subcontractor (s ) '. and shall
maintain such right of access as a condition of any
suboontract award. This access shall include records of
program income, and cost allocation plans.
The SUBGRANTEE assures and certifies that it has complied
with the requirements of Federal, state and local laws
regarding the obtaining of employer identification/account
numbers and the collection, payment, deposit, and reporting
of federal, state and local taxes. In addition to
certifying compliance for all prior subgrants with the
GRANTEE, if appliC'able, the SUBGRANTEE further assures
continuing compliance throughout the period covered by this
Subgrant.
Bondina
That SUBGRANTEE shall, before an advance or any payment or
compensation is made under this Subgrant, furnish proof to
the GRANTEE that it has a fideli ty bond covering all
officers and employees of the SUBGRANTEE who are responsible
for the receipt, custody and disbursement of program assets.
Such a fidelity bond shall be conditioned that the surety
executing such bond agrees to indemnify the SUBGRANTEE and
ultimately the GRANTEE as appropriate, against any direct
loss of money or other personal property, for which the
SUBGRANTEE is legally responsible under the terms of this
Subgrant. Such bond shall be in the amount of TWENTY-FIVE
THOUSAND DOLLARS ($25,000). Advance written notice of
thirty (30) days shall be given to GRANTEE of the intention
to cancel such fidelity bond by SUBGRANTEE.
c. lIaai-ent
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Purchase and Jlaintenance of Bauiaaent
The purchase of all nonexpendable personal property
requires prior written approval by the GRANTEE. The
execution of this Subgrant, inclusive of all exhibits,
does not constitute prior approva;i. No DU:hases of
eauiDment shall be allowed durinG' the last _arter of
the Subarant Deriod.
SUBGRANTEE shall follow the provisions of 41 CPR 29-
70.215 for all purchases of property with Subgrant
funds. However, should the SUBGRANTEE have, or the
GRANTEE issue, a more restrictive policy, then the most
restrictive policy shall apply.
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The titles to all property purchased with Subgrant
funds remain vested in the GRANTEE. The GRANTEE may
take possession of all such property upon termination
of the Subgrant, or on evidence that property's
utilization is not consistent with the Subgrant.
SUBGRANTEE shall maintain an up-to-date inventory of
all Subgrant property in its custody, and shall
maintain the property in good condition. This includes
property currently on hand from previous
subgrants/contracts with :the GRANTEE, surplus
government property utilized for the Subgrant, and all
new purchases under this Subgrant.
This clause is applicable to all office furnishings and
equipment, tools, and materials used in training and
services activities.
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D.
(2) Lease. Rental and Lease-Purchase
The GRANTEE reserves the right of reviewing and
approving all applicable lease, rental and
lease/purchase agreements of the SUBGRANTEE.
SUBGRANTEE shall maintain and make available to the
GRANTEE copies of all documents relative to bids,
quotations and offers related to the agreements.
Lease, rental and lease/purchase agreements may be
reviewed for a fair and reasonable cost analysis prior
to approval.
Any remodeling and rehabilitation must be reviewed by
the GRANTEE and written approval provided by the
GRANTEE prior to the SUBGRANTEE expending funds from
this Subgrant.
Funds from this Subgrant are prohibited from use for
capital improvements on privately-owned property.
IDdi rect Costs
That SUBGRANTEE will not be reimbursed for any indirect cost
incurred in performance under this Subgrant unless
SUBGRANTEE has a current Indirect Cost Negotiated Agreement,
fully executed by a cognizant Federal Agency, and been given
prior written approval by GRAH'l'EE.
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That SUBGRANTEE shall procure and thereafter maintain all
private and public insurance coverage required by Federal,
State and local law, and as detailed in the NCOA-SCSEP
Procedures Manual.
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ADd! ts
As required by Department of Labor regulations (20 CFR Part
96), recipients of Department of Labor grants are required
to obtain annual organization-wide audits. SUBGRANTEES who
are States, Local Governments, or Indian Tribes are required
to have the audits performed in accordance with Office of
Management and Budget (OMB) Circular A-128, "Uniform Audit
Requirements for State and Local Governments."
SUBGRANTEES who are colleges and universities, and other
non-profit organizations are required to have the audit
performed in accordance with the requirements contained in
OMS Circular A-l10, attachment Fl.
The audits should be made annually, but must be made at
least biennially. Audits conducted biennially shall cover
both years within the biennial period. OMS Circular A-l28
provides detailed guidance on the conduct of organization-
wide audits. Colleges and universities, and other nonprofit
organizations are required to follow this quidance in the
conduct of the audits.
Costs of organization-wide audits may be reimbursed if funds
are provided for the audit in the administrative expense
category of the approved subgrant budget.
The SUBGRANTEE is required to submit copies of the audit
reports when they are completed along with the SUBGRANTEE's
responses to recommendations or findings that pertain to the
subgrant and the repayment of any audit exceptions for
improperly spent subgrant funds.
Audi ts of this Subgrant will be performed by the GRANTEE
(including a representative of the u.s. Department of Labor
or others, if applicable), and findings of such audi ts
thereof will be provided to the SUBGRANTEE.
All books of accounts, ledgers, supporting records and
worksheets pertaining to the financial records of the
subgrant shall be retai'nedfor a period of three (3) years
from the final closeout date of the GRANTEE'S prime grant.
Records shall be retained beyond the 3 year period if audit
findings have not been resolved, or if requested by GRANTEE.
In the event of disallowance or audit exception by the
GRANTEE, including any exception resulting from aU. S.
Department of Labor audit, of any expendi ture which it
considers to be an item not properly allocable to the work,
or reimbursable under this Subgrant, the GRANTEE shall
notify the SUBGRANTEE in writing of the disallowance, giving
full particulars and reasons for disallowance. In the event
the SUBGRANTEE concurs, the amount disallowed may be
19
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withheld by the GRANTEE from the next advance, if any; or if
there is no next advance, the SUBGRANTEE shall make payment
to the GRANTEE. In the event the SUBGRANTEE does not concur
with a disallowance or audit exception, the matter may be
referred to the appropriate official of the u.s. Department
of Labor for review, after the GRANTEE'S Audit Resolution
procedures have been exhausted. Notwithstanding any other
provision of law or this AGREEMENT, the SUBGRANTEE shall
indemnify and/or reimburse GRANTEE for any disallowances or
exceptions, and for any associated or consequential costs
thereof, resulting from a DOL audit or otherwise.
V. PROORAH HANAGEIIENT PROVISIONS
Policies and Records
(1) Personnel Policies
The SUBGRANTEE shall provide, prior to the execution of
this agreement, a copy of its approved personnel
policies, for both staff and enrollees.
(2) Travel
The SUBGRANTEE shall provide, prior to the execution of
this agreement, a copy of its approved travel policies.
All travel outside of the SUBGRANTEE' S jurisdiction
must be approved, in writing, by the GRANTEE. The
reimbursement rate for local travel shall not exceed
the Federally authorized rate.
(3 ) Accessibili tv to Personnel and Records
In addition to the requirements imposed elsewhere in
this Subgrant, SUBGRANTEE shall insure that sufficient,
auditable, and otherwise adequate records are
maintained which support the expenditure of all funds
received through this Subgrant. Such records shall be
sufficient to allow the U. S. Department of Labor and
GRANTEE to audi t and moni tor SUBGRANTEE, and shall
include the maintenance of management information
system records in8ccordance with the required GRANTEE
HIS system.
The SUBGRANTEE shall comply wi th all requirements
imposed by law and the GRANTEE regarding the.
maintenance of a record of each participant's
participation in the SCSEP, including dates of entry
and termination, and services provided. All
participant, financial and program records shall be
maintained for a minimum three (3) year period
following closeout of the GRANTEE'S OAA Title V prime
grant. If, prior to the expiration of the three (3 )
20
year retention period, 'any litigation or audit is begun
or a claim is instituted involving the agreement
covered by the records, the SUBGRANTEE shall retain the
records beyond the three ( 3 ) year period until the
litigation, audit finding, or claim has been finally
resolved. GRANTEE will formally notify the SUBGRANTEE
of the expiration of each subgrant retention period.
Disposal of records, without GRANTEE approval, is at
the SUBGRANTEE'S risk.
B. Proaram Staff
The SUBGRANTEE shall designate a Project Director to be
responsible for administration of the SCSEP. Appointment
shall be subject to consultation with GRANTEE. Other staff
necessary to administer, manage and/or operate this subgrant
shall be program enrollees whenever feasible, and project
staffing arrangements shall be subject to approval by the
GRANTEE.
GRANTEE shall be provided advance notification, of at least
10 days, of any proposed changes in project administrative
personnel and/or staffing arrangements.
c. Advisorv Council
SUBGRANTEE agrees to develop a mechanism for securing the
largest and broadest possible community support for the
project, such as an Advisory Council. The Advisory Council
is to provide advice, assistance and support, while not
functioning as a program policy-making body. The Advisory
Council may be a conuni ttee or sub-commi ttee of a larger
aging, employment, or human services program council._
Kembership should include, but not be limited to, enrollees,
professional persons who are specialists in the field of
aging, employment and human services programs, local labor
leadership and representatives of private industry. A
listing of the membership shall be submitted to the GRANTEE
within ninety (90) days after execution of this agreement.
Vl: . REPORTING RBOUIlnnl'RlI'1'S
A. pi """""chI ReDOrts
The SUBGRANTEE shall deliver to GRANTEE'S Finance
Department, a monthly financial report of its expenditure of
funds received under this Subgrant. The 'report must have
original signatures, and must be received by the 15th day of
the month following the reporting period. The GRANTEE, at
its discretion, may require SUBGRANTEE to submit an
addi tional statement each month which will reflect the
following:
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(a) Purpose of each expenditure;
(b) Payee of each expenditure;
(c) Amount of each expenditure; and
(d) Name of person requesting each expenditure.
A copy of the Monthly Financial Report (MFR) , and all
attachments, shall be submitted to the designated NCOA
Regional Manager.
lfanaaement Information Svstem (XIS 1 Re1X>rts
The SUBGRANTEE shall submit properly certified participant
tracking reports to the GRANTEE. These reports shall be
submitted in the format and within the tLme frame prescribed
by the GRANTEE. The reports shall include but not be
limited to, information on enrollment, activity change and
termination of participants. The SCSEP Procedures Manual
provides a full description of all required reports, due
dates, and persons to whom copies are distributed.
c. Other Reoorts
The SUBGRANTEE shall prepare in accordance with written
directives those documents as specified by the GRANTEE to
enable the GRANTEE to summarize and report the status of the
program as set forth in this Subgrant and as required by the
Department of Labor, other Federal agencies, and the
GRANTEE. This data, along with other reports will be used
to determine the performance of this Subgrant as set forth
herein.
VII. PERPOlUIARCE
A. PerfoJ:JDlUlC8 Stand.erds
The SUBGRANTEE shall have adequate administrative and
accounting controls, personnel standards, evaluation
programs and other policies as may be necessary to promote
the effective use of funds and to comply with Title V
regulations.
Performance by the SUBGRANTEE shall be measured monthly, by
the GRANTEE, on a cumulative basis against goals and
standards specified in this AGREEXtNT and incorporated by
reference. The performance standards for program activities
under this Subgrant, as outlined in the Program Narrative,
shall also be monitored. It will be the responsibility of
the SUBGRANTEE, to determine the nature, extent and cause of .
performance below relevant goals.
22
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Proaram and Financial Goals
GRANTEE will review and analyze at least monthly, all
reports submitted pursuant to provisions for program and
financial goals set forth in this Subgrant. The GRANTEE
reserves the right to require replanning or other
appropriate action which may involve the unilateral
deoblioation of funds.
The SUBGRANTEE will be expected to perform within a plus or
minus two percent (2%) variance of the monthly financial
plans, as stipulated in the Budger, however, appropriate
procedures must be initiated to assure that the total
subgrant is not over-expended. The unsubsidized placement
goal is stipulated on page 1 of this AGREEMENT, and progress
toward achieving same shall' be reviewed on a monthly basis.
Enrollee serv ices plans , as stipulated in the
narrative/workplan, shall be continuously reviewed to
determine that goals are being met.
c.
Evaluation
The frequency, format, accuracy and time of submission of
required MIS and financial reports and invoices shall
conform to instructions published by the GRANTEE. The
submission of delinquent or faulty data will be recorded and
such occurrences shall result in an adverse effect upon the
evaluation of the overall performance of the SUBGRANTEE, and
may result in'the suspension or termination of the Subgrant.
The submission of reports shall not be the only criterion by
which the SUBGRANTEE is evaluated. Total performance within
the scope of this Subgrant, Title V of the Older Americans
Act and regulations, other applicable laws and regulations,
and GRANTEE Directives, will all affect the evaluation of
the Subgrant.
VIII. JlISCELLAREOUS
All documents, records, reports, forms, or any other material
maintained, completed, or submitted by the SUBGRANTEE in
connection with the Performance of the work, as well as any
equipment, furniture, other tangible property (if any) acquired
with funds 'provided or reimbursed by the GRANTEE, shall be the
exclusive property of the GRANTEE and shall be delivered to the
GRANTEE at the termination date or earlier termination of this'
Subgrant, or upon request therefor.
All rights of COPYright, reproduction, and disposal of the
material gathered by the SUBGRANTEE, including but not limited to
23
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the aforesaid documents, reports, and forms, shall belong
exclusively to the GRANTEE, with the exception that the
SUBGRANTEE is authorized to make and retain for its official
records, copies of documents and reports provided to the grantee.
No publication or dissemination of any kind shall be made of
material, reports, or results of this SCSEP by SUBGRANTEE without
the prior consent of the GRANTEE, with the exception that the
SUBGRANTEE may provide normal public information concerning the
program, its purpose, and requirements for enrollment. The
SUBGRANTEE may publish statistical data concerning participation
and progress of the program.
It is understood and agreed that this AGREEMENT incorporates and
includes all prior negotiations, correspondence, conversations,
agreements, or understandings applicable to the matters contained
herein, and the parties agree that there are not commitments,
agreements, or understandings concerning the subject matter of
this AGREEMENT that are not contained herein. Accordingly, it is
agreed that no deviation from the terms hereof shall be
predicated upon any prior representations or agreements whether
written or oral; it is further agreed that no modification,
amendment or alteration in the terms or conditions contained
herein shall be effective unless contained in a written document
executed with the same formality and of equal dignity herewith.
To provide services as set forth in the Subgrant Narrative, the
SUBGRANTEE shall continuously manage and operate this Subgrant at
the following administrative office(s) and/or subsite(s):
MONROE COUNTY DEPARTMENT OF SOCIAL SERVICES
1315 Whitehead St.
Key West, FL 33040
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IX. AUTHORITY TO EXECUTE
Each of the parties hereto covenant to the other party that it
has lawful authority to enter into this AGREEMENT and has
authorized the execution of this AGREEMENT by the party's
authorized representative. This AGREEMENT shall be effective
upon execution by both parties.
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IN WITNESS WHEREOF, the parties have caused this AGREEMENT to be
duly executed by their authorized representative, this day
of
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Approved for GRANTEE by:
Approved for SUBGRANTEE by:
Name
Michael H. Puto
Name
Title
Mayor of Monroe County, Florida
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Signature
Date
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SUBGRANT AGREEMENT INDEX
Article I: Prooram Purpose
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Clause A. Project Objectives
B. Special Assurances
Article II: Grantee/Suborantee Relationship
2
3
Clause A. Legal Authority
B. Fund Availability
C. Independent Contractor
D. Third Party Agreements
E. Indemnification
F. ~scellaneous Provisions
1. Personnel & Records Availability
2. Conflict of Interest
3. Lobbying
4. Scope of Agreement
5
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6
6
7
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8
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Clause A. Performance Period
B. Total Funds Awarded
C. Subgrant Identification
D. Compliance with Applicable Laws, Regulations,
Guidelines
E. Funding Obligations and Payments
F. Interest-Bearing Bank Account
G. Program Income
H. Use of Federal Funds
I. Subgrant Modifications and Changes
J. Subgrant Termination
K. Closeout Procedures
9
9
9
9
10
12
12
12
13
15
16
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Article IV: Financial Manaoement Provisions
Clause A. Accounting System
B. Bonding
C. Equipment
D. Indirect Costs
E. Insurance
F. Audits
16
17
17
18
18
19
Article V: Prooram Manaoement Provisions
Clause A. Policies and Records
B. Program Staff
C. Advisory Council
20
21
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-CONTINUED ON REVERSE-
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SUBGRANT AGREEMENT INDEX (continued.)
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Article VI: Reportinq Requirements
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Clause A. Financial Reports
B. Management Information System (MIS) Reports
C. Other Reports
Article VII: Performance
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Clause A. Performance Standards
B. Program and Financial Goals
C. Evaluation
22
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Article VIII: Miscellaneous
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o Copyrights
o Publication of Data
o Prior Agreements
o Location(s) of Activities
Article IX: Authoritv to Execute
23
24
24
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25
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Article X: Special Conditions or Chanqes to Subqrant Aqreement
(optional)
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THE NATIONAL COUNCIL ON THE AGING, INC.
Since 1950 working to improve the lives of older Americans
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600 MARYLAND AVE. SW · WEST WING 100 · WASHINGTON, DC 20024 · TELEPHONE (202) 479.1200
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NCOA/SCSEP SUBGRANT AGREEMENT
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The following changes have been made in the standard NCOA/SCSEP
Subgrant Agreement for Program Year 1989-90 subgrants.
paoe 3
Special Assurances, item 13: addition of sentence which reads,
"Documentation of the 501 (c) (3) status of non-governmental
worksites must be retained on file."
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Rationale: To assure that subgrantees comply with
Legislative/regulatory requirements.
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Special Assurances, item 119: new item which requires that
acti vi ties be conducted in accord with the provisions of the
Drug-Free Workplace Act of 1988.
Rationale: Legislative/regulatory requirement.
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Special Assurances, item 120: new item which requires compliance
with Section 89 of the Internal Revenue Code, as appropriate.
Rationale: Legislative/regulatory requirement.
paoe 13
ARTICLE III, Clause I, Item 13(a) (General Administrative
Provisions, Subgrant Modifications & Changes, Other
Modifications): change in level at which prior approval is
required for increases or decreases from approved enrollment.
Approval now required for changes exceeding ~, instead of the
previous requirement which was 20'.
Rationale: Administrative control.
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ARTICLE III, Clause K (General Administrative Provisions,
Closeout Procedures): ( 1 ) addi tional language stipulating the
date by which subgrant closeout data must be submitted; and (2)
additional language which states that payments under an existing,
subgrant may be suspended for failure to submit timely refunds on
prior subgrants.
Rationale: Administrative control.
Chalf Elva Walker: 1st Voce Chalf Franlcill F........., Esq,
2nd VIce Chalf 0_ Knowtes: Secretary Sylvia Vuen; ASSIstant Secretary CIlartes SclloI1tancl
Treasurer J_ Gunning; Assostan, Treasurer RobeI1 Popper
PreSident Or, Daniel ThurIz. ACSW
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ARTICLE VII, Clause B, paragraph #2 (Performance, Program and
Financial Goals): Deletion of requirement that approved
enrollment level be maintained at all times.
Rationale: Recognizing that many projects have budgeted
phase-in/phase-out enrollment plans, enforcement of the
deleted provision was impractical. However, nothing in this
change should be construed as relieving the subgrantee of
its obligation to maintain its full enrollment level within
normal budgetary constraints.
[3-20-89]
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