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• For courses that are non -DHS approved training, recipient must request approval to conduct training through the use of the Non -TED Form and provide a copy, along with email, showing approval granted for conduct. • For the conduct of training workshops, recipient must provide a copy of the course materials and sign -in sheets • The number of participants must be a minimum of 15 in order to justify the cost of holding a course For questions regarding adequate number of participants please contact the FDEM State Training Officer for course specific guidance Unless the recipient receives advance written approval from the State Training Officer for the number of participants, then the Division will reduce the amount authorized for reimbursement on a pro -rata basis for any training with less than 15 participants C. Procurement All procurement transactions will be conducted in a manner providing full and open competition and shall comply with the standards articulated in • 44 Code of Federal Regulation, Section 13 36, • Chapter 287, Florida Statues, and, • any local procurement policy To the extent that one standard is more stringent than another, then the subgrantee must follow the more stringent standard For example, if a State statute imposes a stricter requirement than a Federal regulation, then the subgrantee must adhere to the requirements of the State statute The Division shall pre -approve all scopes of work for projects funded under this agreement. Additionally, the subgrantee shall not execute a piggy -back contract unless the Division has approved the scope of work contained in the original contract that forms the basis for the piggy -back contract. ;Also, in order to receive reimbursement from the Division, the subgrantee must provide the Division with a suspension and debarment form for each vendor that performed work under the agreement. Furthermore, if requested by the Division, the subgrantee shall provide copies of solicitation documents including responses and justification of vendor selection D. Piggy -backing The practice of procurement by one agency using the agreement of another agency is called piggybacking The ability to piggyback onto an existing contract is not unlimited The existing contract must contain language or other legal authority authorizing third parties to make purchases from the contract with the vendor's consent. The terms and conditions of the new contract, including the scope of work, must be substantially the same as those of the existing contract. The piggyback contract may not exceed the existing contract in scope or volume of goods or services An agency may not use the preexisting contract merely as a "basis to begin negotiations" for a broader or materially different contract. Section 215.971, Florida Statutes Statutory changes enacted by the Legislature impose additional requirements on grant and subgrant agreements funded with Federal or State financial assistance In pertinent part, Section 215 971(1) states 24