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HomeMy WebLinkAbout24319AGREEMENT INFORMATION AGREEMENT NUMBER 24319 NAME/TYPE OF AGREEMENT BRANCHES, INC. DESCRIPTION MIAMI-DADE VITA COALITION PARTNERSHIP AGREEMENT / 2022 VOLUNTEER INCOME TAX ASSISTANCE PROGRAM / MATTER ID:22-3175 EFFECTIVE DATE December 1, 2021 ATTESTED BY TODD B. HANNON ATTESTED DATE 2/17/2023 DATE RECEIVED FROM ISSUING DEPT. 3/21/2023 NOTE CITY OF MIAMI DOCUMENT ROUTING FORM ORIGINATING DEPARTMENT: Dept. of Human Services DEPT. CONTACT PERSON: Michael Roman NAME OF OTHER CONTRACTUAL PARTY/ENTITY: G9O" '1rTP' EXT. 1 61 8 IS THIS AGREEMENT A RESULT OF A COMPETITIVE PROCUREMENT PROCESS? ❑ YES 0 NO TOTAL CONTRACT AMOUNT: S 10000 FUNDING INVOLVED? Q NO OYES TYPE OF AGREEMENT: ❑ MANAGEMENT AGREEMENT ❑ PROFESSIONAL SERVICES AGREEMENT 0 GRANT AGREEMENT ❑ EXPERT CONSULTANT AGREEMENT ❑ LICENSE AGREEMENT OTHER: (PLEASE SPECIFY) PURPOSE OF ITEM (BRIEF SUMMARY): ❑ PUBLIC WORKS AGREEMENT ❑ MAINTENANCE AGREEMENT ❑ INTER -LOCAL AGREEMENT ❑ LEASE AGREEMENT ❑ PURCHASE OR SALE AGREEMENT To review and accept the fagreement for 2023 tax sites COMMISSION APPROVAL DATE: / FILE ID: ENACTMENT NO.: 1F THIS DOES NOT REQUIRE COMMISSION APPROVAL, PLEASE EXPLAIN: ROUTING INFORMATION Date PLEASE PRINT AND SIGN APPROVAL BY DEPARTMENTAL DIRECTOR SUBMITTED TO RISK MANAGEMENT PRINT: William Porro SIGNATURE: Porro, Willam 5:A. =',',-5 m,tiN-MARGPm1§11 ark —by Date: 2023.02.09 FQ URF..: 10:08:49-05'00' SUBMITTED TO CITY ATTORNEY (JCP / 22-3175) APPROVAL BY ASSISTANT CITY MANAGER RECEIVED BY CITY MANAGER 2/10/23 2/► 3 /23 PRINT: VICTORIA MENDEZ s..hran ( SIG PRfiT: SIGNATURE: (1 PRINT: ART N SIGNATURE: / �U cArYi 1) ONE ORIGINAL TO CITY CLERK, 2) ONE COPY TO CITY ATTORNEY'S OFFICE, 3) REMAINING ORIGINAL(S) TO ORIGINATING DEPARTMENT PRINT: SIGNATURE: PRINT: SIGNATURE: PRINT: SIGNATURE: PLEASE ATTACH THIS ROUTING FORM TO ALL DOCUMENTS THAT REQUIRE EXECUTION BY THE CITY MANAGER CITY OF MIAMI DOCUMENT ROUTING FORM ORIGINATING DEPARTMENT: Dept. of Human Services DEPT. CONTACT PERSON: Michael Roman NAME OF OTHER CONTRACTUAL PARTY/ENTITY:idnt v t u 7A EXT. 1618 IS TIIIS AGREEMENT A RESULT OF A COMPETITIVE PROCUREMENT PROCESS? ❑ YES 0 NO TOTAL CONTRACT AMOUNT: $ mom FUNDING INVOLVED? ■❑ NO EYES TYPE OF AGREEMENT: ❑ MANAGEMENT AGREEMENT ❑ PROFESSIONAL SERVICES AGREEMENT 0 GRANT AGREEMENT ❑ EXPERT CONSULTANT AGREEMENT ❑ LICENSE AGREEMENT ❑ PUBLIC WORKS AGREEMENT ❑ MAINTENANCE AGREEMENT ❑ INTER -LOCAL AGREEMENT ❑ LEASE AGREEMENT 0 PURCHASE OR SALE AGREEMENT OTHER: (PLEASE SPECIFY) PURPOSE OF ITEM (BRIEF SUMMARY): To review and accept the fagreement for 2023 tax sites COMMISSION APPROVAL DATE: / / FILE ID: ENACTMENT NO.: IF THIS DOES NOT REQUIRE COMMISSION APPROVAL, PLEASE EXPLAIN: ROUTING INFORMATION ' Date PLEASE PRINT AND SIGN APPROVAL BY DEPARTMENTAL DIRECTOR PRINT: William Porro SIGNATURE: Porro, Willam �°°°°"r°°'`°�" o,ro zozao+.at ta.tasa SUBMITTED TO RISK MANAGEMENT Q� omez, ran -a}�Q'URE. , ,Date:2023.02.09 l 10:08:49-05'00' SUBMITTED TO CITY ATTORNEY (JCP / 22-3175) 2/10/23 PRINT: VICTORIA MENDEZ s Juan C. ez SIG APPROVAL BY ASSISTANT CITY MANAGER PR T: SIGNATURE: RECEIVED BY CITY MANAGER PRINT: ART NORIEGA SIGNATURE: 1 ONE ORIGINAL,TO.CITYCLERK; _�..................,,...._..,..._..�.�......_..._..__.......,.....,,,,...w....,..�.. ,_.__., 2) ONE CQPY TO:CITY ATTORNEY..bFFICE; 3) REMAINING ORIGINAL(S) TO ORIGINATING DEPARTMENT PRINT: SIGNATURE: PRINT: SIGNATURE: PRINT: SIGNATURE: PLEASE ATTACH THIS ROUTING FORM TO ALL DOCUMENTS THAT REQUIRE EXECUTION BY THE CITY MANAGER 2022 MIAMI-DADE VITA COALITION PARTNERSHIP AGREEMENT BETWEEN BRANCHES, INC. AND THE CITY OF MIAMI. THIS 2022 Miami Dade VITA Coalition Site Partner and Grant Agreement ("Agreement') is entered into effective as of December 1, 2021 ("'Effective Date") by and between Branches. Inc., a Florida not -for -profit Corporation with principal address at 11500 NW 121h Avenue, Miami, FL 33160, as set forth below ("Branches" and "Sub -Grantor"), and the City of Miami, a Florida municipal corporation, with principal address at 3500 Pan American Drive, Miami FL 33133 ("City", "Partner" and "Sub -Grantee"). Branches and the City may be each referred to as a "Party" and may collectively be referred to as the "Parties." RECITALS AND VALUES STATEMENT: WHEREAS, Branches. Inc. ("Branches") has received funding to implement the 2022 Volunteer Income Tax Assistance (VITA) Program in Miami -Dade County, Florida ("VITA Program"'); and WHEREAS, Branches will partner with other organizations ("member(s)") to collectively execute the VITA Program as the Miami -Dade VITA Coalition Miami Tax Pros; and WHEREAS, members of the Coalition who sign a Partnership Agreement pursuant to the execution of the VITA Program are thereafter subrecipients as defined by Federal Regulations, and are responsible for complying with all applicable regulations therein; and WHEREAS, Branches selected these VITA Partners because of their capacity to operate a VITA Site(s), and the organization's stated vision, goal, and mission; and WHEREAS, the Coalition's primary objective shall be executing the VITA Program by offering help and support to organizations who offer Free Tax Preparation and Asset Building services to either Low -Income or Limited English Proficiency (LEP) clients in Miami -Dade; and WHEREAS, Branches has selected the City as a well -respected and active IRS VITA Sites at Jose Marti Park, Robert King High, Moore Park and Grapeland Heights Park, which are City owned and operated facilities (collectively, the "City's VITA Sites') for implementation of the VITA Program and for which Branches will provide to the City grant funding based on tax returned completed and accepts by the IRS in a total amount not to exceed $10,000.00; and WHEREAS, the City Manager pursuant to Section 18-115 of the City Code, as amended is authorized to receive donations not to exceed twenty-five thousand dollars ($25,000.00) for the VITA Program to receive assistance from Branches at the City's VITA Sites; NOW THEREFORE, in consideration of the mutual covenants hereinafter set forth and in consideration of valuable considerations, the sufficiency of which is hereby acknowledged by Branches and City as the parties, the parties covenant and agree as follows: 1. INCORPORATION OF RECITALS: The recitals and findings set forth above are hereby adopted by reference and incorporated herein as if fully set forth in this Agreement. 2. PURPOSE OF THIS AGREEMENT: Branches has received funding to implement the 2022 Volunteer Income Tax Assistance (VITA) Program in Miami -Dade County, Florida ("VITA Program"). Branches will partner with other organizations ("member(s)") to collectively execute the VITA Program as the Miami -Dade VITA Coalition: Miami Tax Pros. Members of the Coalition who sign a Partnership Agreement pursuant to the execution of the 1 VITA Program are thereafter Sub recipients as defined by Federal Regulations and are responsible for complying with all applicable regulations therein. As the VITA Grant Recipient, Branches reserves the right to offer the status of Sub recipient based on both an organization's capacity to operate a VITA site(s), and the organization's stated vision, goal, and mission. The Coalition's primary objective shall be executing the VITA Program by offering help and support to organizations who offer Free Tax Preparation and Asset Building services to either Low -Income or Limited English Proficiency (LEP) clients in Miami -Dade._ 3. TAX YEARS: Tax Year ("TY2021") refers to accepted Federal returns filed January 2022 through April 2022. Tax Year ("TY2022" refers to accepted Federal returns filed January 2023 through April 15, 2023. 4. TERMS OF AGREEMENT: This agreement sets forth the expectations and responsibilities of both Member and Branches, in relation to the execution of the VITA Program. Members agree to meet all applicable IRS guidelines and requirements in addition to the expectations herein. Failure to comply with any such expectation or Regulation may result in a delay, reduction, or elimination of any payment Member may otherwise be eligible for. This agreement shall remain in effect December 1, 2022, through July 31, 2023. 5. CITY/SUB-GRANTEE AGREES TO: A. GENERAL- 1. Operate one or more VITA site(s) in compliance with all IRS guidelines and requirements, including but not limited to: confidentiality, data collection and reporting, civil rights, and quality review/program evaluation. 2. Use all IRS prescribed forms and procedures for VITA activities. 3. Adhere and conform to any and all other requirements of the IRS VITA grant program. 4. Ensure that Member's site(s) is accessible in accordance with local and federal laws regarding persons with disabilities. Member also agrees not to discriminate against any persons on the basis of color, creed, religion, age, disability, gender or age. 5. Have internet access, printer, copier, filing cabinet, and any other office equipment required to successfully e- file tax returns and maintain proper documentation. 6. Have a minimum of two computer workstations available and staffed during all site operating hours. 7. Ensure all computers used for Member's VITA operations are able to connect to TaxSlayer Online. B. SITE DETAILS AND SCHEDULE- 1. Provide site operating information for Member's VITA site(s) via the supplied Site Detail Form prior to December 9, 2022. 2. All Coalition sites should strive to maximize production by offering preparation hours including: 1) at least one weeknight each week; AND 2) at least one weekend block of four hours every other week in TY2022. 3. All Coalition sites should be open from January 27th through at least April 15th. 4. Any site wishing to participate in the Extended Season preparation schedule must provide notice before April 1, 2023. If no notice is provided, Branches will assume the site does not wish to opt -in to the Extended Season schedule. C. COALITION PARTICIPATION- 1. All Sites should have at least one Site Coordinator, or administrative representative who is responsible for Member's VITA efforts, and who will participate in all Coalition communications and meetings. 2. Add all Coalition designed "Marketing Questions" to TaxSlayer software to enable data and marketing research. 3. Track in -kind contributions related to Member's VITA operations including: space, stafftime, marketing activities, equipment, etc. Any such In -Kind donation must be calculated and substantiated in accordance with the relevant IRS Code(s). A sample form can be provided. 4. Submit all reporting and documentation, as outlined in the Reporting and Documentation section below, in a timely manner. 2 D. VOLUNTEER MANAGEMENT- 1. Member will try to have volunteers who reflect the cultural and demographic needs of Member's target populations. 2. Member will ensure that new and returning volunteers are directed to the Miami Tax Pros website volunteer page: https://branchesfl.galaxydigital.com/user/register/ to complete registration information. 3. Contact all prior volunteers to request re -engagement with the VITA program, or provide contact information to Branches for such communication, prior to November 11, 2022. 4. Provide training to Member's volunteers to achieve their required certification levels, and verify completion according to VITA guidelines. Such training may be online, provided by Member, or coordinated by Branches as needed. 5. Schedule volunteers as required to meet client demand at Member's VITA site(s). 6. Have at least one identified Site Coordinator on -site at all times Member's VITA site is operational. 7. Ensure volunteers have the necessary training and reference materials (Pub. 17, Pub. 4012, Pub. 4299 and, Volunteer Tax Alerts) as required by VITA/TCE Volunteer Quality Site Requirements. 8. Ensure volunteers are accurately completing the Coalition Marketing Questions for each client. E. MARKETING / CLIENT RECRUITMENT- 1. Include information about VITA, EITC, and Child Tax Credit on Member publicity materials wherever possible. 2. Participate in any Miami Tax Pros VITA Coalition Social Media marketing campaigns including "liking" and "sharing" Coalition social media posts through Member's social media accounts, and promoting Coalition developed hashtags. 3. Share any media interviews or appearances in advance with Branches and Member's SPEC Relationship Manager to ensure the Coalition can adequately support its efforts. F. ASSET BUILDING & ADDITIONAL STRATEGIES- 1 Should utilize provided training and marketing materials to encourage SaveYourRefund program participation at Member's site(s). 2. Should utilize provided training and marketing materials to implement voter registration. This would be OPTIONAL for all taxpayers. 3. Provide access to identified Asset Building Services via referrals to Coalition partners. Such access may be through direct referrals or through Branches. G. REPORTING AND DOCUMENTATION - These reporting and documentation requirements are designed to help inform Coalition Strategic Planning in various areas. Each data point offers insight into a valuable topic. To the extent applicable, Member must meet all IRS reporting requirements in addition to anything listed here. 1. All standard IRS VITA documentation must be timely submitted to the SPEC relationship manager, and to Branches as requested. 2. Member will submit this signed agreement by close of business November 11, 2022. 3. Member will provide site operating details using the supplied form by close of business December 9, 2022. 4. As requested, provide Branches a fonnal letter outlining all In -Kind Contributions from tax year 2022. H. BRANCHES, INC. AGREES TO: 1. Provide Member guidance and assistance in planning operating hours, staffing needs, and equipment requirements. 2. Coordinate, and take lead responsibility for, all Coalition -wide publicity and marketing efforts across the county through its relationship with the United Way of Miami -Dade, city and county government departments, media, and private organizations. 3. Coordinate facilities and instructors for in -person training courses available to all Coalition tax preparers. In - person courses will be held in January 2022 and will be structured around the Advanced VITA Certification 3 program and include training on the new TaxSlayer Customer Portal. 4. Coordinate instructors for virtual training courses available to all Coalition tax preparers. Virtual courses will be held in January 2022 and will be structured around the Advanced VITA Certification program and include training on the new TaxSlayer Customer Portal. 5. Coordinate facilities and instructors for a Site Coordinator training for all coalition Site Coordinators. This course will cover: volunteer engagement and retention strategies, asset building programs and strategies, and general best practice sharing for site operations. 6. Facilitate a Site Coordinator "help line" open to all Coalition Site Coordinators. 7. Provide a volunteer recognition event that celebrates volunteers' accomplishments and engages them for future VITA involvement. 8. Provide a Subrecipient award to all Members producing more than the 50 minimum returns expected by the IRS, in consideration of fulfilling the aforementioned responsibilities, based on the Program Payment Guidelines and Schedule attached as Addendum 1. 6. INDEMNIFICATION: Branches hereby agrees to indemnify. protect, defend, save, release. and hold harmless the City, its their respective officers, employees, agents, representatives, and principals from and against any and all claims, actions, damages, liability and expense (including fees, costs, and expenses of attorneys. investigators and experts) in connection with loss of life, personal injury, or damage to property arising out of the performance or non- performance of this Agreement except to the extent such loss, injury or damage was caused by the gross negligence of the City or their respective officers. employees, agents, representatives, and principals. 7. INSURANCE: Branches shall furnish to the City insurance documentation pursuant to Exhibit A attached and incorporated herein. The City reserves the right to require additional insurance requirements as may be warranted by the scope of services in connection with this Agreement. 8. TERMINATION: Branches will make every reasonable effort to help its partner VITA Sites fulfill their obligations and encourages Member to request assistance from Branches staff whenever necessary. However, Branches, Inc. and Member retain the right to terminate this agreement with 30 days' notice if either party fails to comply with the conditions stipulated herein. In the event of gross breach of contract (e.g. violation of IRS VITA standards), Branches, Inc. may terminate the agreement without prior notice. Upon separation, the site will be paid, to the extent eligible under IRS Grant regulations, for services rendered through the date of separation within 15 days of receipt of an invoice and all other required documentation. No payment will be made without submission of all reports and documentation as described in the Program .Payment Guidelines and Schedule Addendum. 9. CONTACTS: Correspondence related to this agreement should be addressed to: Branches, Inc. Contact Karla Bachmann, Vice President of Financial Wellness Branches, Inc. 11500 NW 12th Avenue Miami, FL 33168 Phone: (305) 688-3551 ext. 2008 Email: kbachmann@branchesfl.org City of Miami Contact William Porro, Department of Human Services, Director City of Miami 444 SW 2°`t Ave, 10`1' Floor Miami, FL 33130 (305)416-2181 wporro@miamigov.com 10. SEVERABILITY: If any provision of this Agreement, or any paragraph, or any sentence, or any clause, phrase or word or the application thereof, is held invalid, then the remainder of this Agreement shall be construed as if such invalid part were never included herein and the Agreement shall be and remain valid and enforceable to the fullest extent permitted by law. 4 11. CONSTRUCTION OF AGREEMENT: This Agreement shall be construed and enforced according to the laws of the State of Florida. 12. GOVERNING LAW, VENUE,.AND FEES: This Agreement shall be construed and enforced according to the laws of the State of.Florida. Venue in all proceedings shall be in Miami -Dade County, Florida and the Parties explicitly agree to the use of this venue. The term "proceedings" shall include, but is not limited to, all meetings to resolve the dispute, including voluntary arbitration, mediation, or other alternative dispute resolution mechanism. The parties both waive any defense that venue in. Miami -Dade County is not convenient. In any civil action or other proceedings between the parties arising out of the Agreement, each party shall bear its own attorney' s fees. 13. PUBLIC RECORDS: Parties acknowledge that the public shallhave access, at all reasonable times, to this Agreement and any related documents subject to the provisions of Chapter 119, Florida Statutes, and the Parties agree to allow access by each other and by the public to all documents subject to disclosure under applicable law 1.4. AM.ENDMENTS, EXTENSIONS, AND RENEWALS: The City Manager on behalf of the City and' Karla -Bachmann behalf of Branches, have the authority and the right by mutual agreement, but not the obligation to amend, extend, and renew this Agreement so long as the total grant amount to this Agreement does not exceed twenty-five thousand dollars ($25.000.00). Such written amendments, extensions, or renewals shall be effective only when signed by the City Manager and by and shall be incorporated into and become a part of this Agreement. 15. COUNTERPARTS AND ELECTRONIC SIGNATURES: This Agreement may be executed in any number of counterparts, each of which so executed shall be'deemed to be an original. and such counterparts shall together constitute but one and the same Agreement. The parties shall be entitled to sign and transmit an electronic signature of this Agreement (whether by facsimile, PDF or other email transmission), which signature shall be binding on the party whose name is contained therein. Any party providing an electronic signature agrees to promptly execute'and deliver to the other parties an original. signed Agreement upon request. 16. ENTIRE AGREEMENT: This Agreement represents the total agreement between the City and Branches. All other prior agreements between the City and Branches, either verbal or written, are superseded by this Agreement and are therefore no .longer valid. IN WITNESS WHEREOF; "the parties hereto have individually. through their proper officials. have caused this instrument to be executed thereunto duly authorized, as of the Effective Date written above. AGREED & SIGNED BY: FOR BRANCHES, INC., '51171 rj—` Brent McLaughlin — si ent Branches; Inc. DUNS Number: 844926188 1.1500 NW 12th Avenue Miami, FL 33168 Phone: (305) 688-3.551 Email: BMcLaughlin@branchesfl.org Date: 5 ATTEST: Todd B. Hanno City Clerk APPROVED AS TO FORM AND CORRECTNESS THE CITY OF MIAMI, a municipal Corporation of the State of Florida By: Arthur Noriega City Manager APPROVED AS TO INSURANCE REQUIREMENTS Gomez Digitally signed by Gomez, Frank Date: 2023.02.09 By: ,� By: F ra n k 10:11:14-05'00' Victoria endez City ttorney,} Ann -Marie Sharpe, Director Department of Risk Management (JCP / 22-3175 - Branches, Inc. - Free Tax Preparation) 6 Addendum 1: Program Payment Guidelines and Schedule VITA Tax Preparation - Subrecipient Award Guidelines: Branches will distribute awards using the guidelines below. a. The VITA grant program is an IRS initiative designed to support free tax preparation service for underserved populations, including low- to moderate -income individuals and limited -English proficiency populations. As such, VITA Coalition awards are intended to be used to support VITA efforts at each site, including: Improving the quality and quantity of VITA services provided to theunderserved; ii. Enhancing volunteer recruitment and retention efforts; and iii. Helping reimburse for the cost of essential supplies such as paper, ink, pens, etc. b. Total funds available for awards will be proportionally distributed based on the number of qualified accepted Federal Returns filed by each Coalition site as reported by the IRS. 'E-files" and "paper" returns will be counted equally for production calculations. **TY2021 refers to accepted Federal returns filed January 2022-April 2022. **TY2022 refers to accepted Federal returns tiled January 2023 — April 15, 2023. NOTE: These funds will be calculated and awarded in the following categories based on the number of accepted returns reported to Branches by the IRS. General Production Award — This is the base award designed to help subsidize the cost of running a VITA site. Each site will be placed in a payment tier based on their production. Awards will be paid to Coalition members based on their TY2022 Production. c. Base Rate Payment by Tier Calculation (per site): Base Rate = Site TY2022 * Base Rate $ i. Tier I: $4.50 per Accepted Return — Sites with under 150 accepted returns in TY2022; or sites in their first operational year. ii. Tier II: $4.75 per Accepted Return — Sites with 150-299 accepted returns in last year of operation. iii. Tier III: $5.00 per Accepted Return — Sites with 300-449 accepted returns in last year of operation. iv. Tier IV: $5.25 per Accepted Return — Sites with 450-599 accepted returns in last year of operation. v. Tier V: $5.50 per Accepted Return. — Sites with 600+ accepted returns in last year of operation. Client Growth Incentives — These incentives are designed to encourage production growth year over year through: new client acquisition, effective client re -engagement procedures, increased operational efficiencies, and community marketing activities. d. Production Growth Incentive — This incentive is paid on ALL returns representing incremental growth over last year's production number. This is in addition to the Base Rate for the incremental returns. Calculation (per site): = (Site TY2022 Production — Site TY2021 Production) * Incentive $ e. All Sites will receive $2.00 PER RETURN for ALL RETURNS representing incremental growth over TY2022 Payment Schedule Branches, Inc. will process VITA Coalition awards and disburse all funds by July 31, 2023. 7 EXHIBIT "A" 2-(-31 "INSURANCE" INSURANCE REQUIREMENTS -BRANCHES INC MIAMI DADE VITA COALITION AGREEMENT I. Commercial General Liability A. Limits of Liability Bodily Injury and Property Damage Liability Each Occurrence General Aggregate Limit Personal and Adv. Injury Products/Completed Operations B. Endorsements Required $1,000,000 $ 2,000,000 $ 1,000,000 $ 1,000,000 City of Miami listed as additional insured Contingent & Contractual Liability Premises and Operations Liability Primary Insurance Clause Endorsement Hired and Non Owned Auto Exposures Included II. Worker's Compensation Limits of Liability Statutory -State of Florida Waiver of Subrogation Employer's Liability A. Limits of Liability $100,000 for bodily injury caused by an accident, each accident $100,000 for bodily injury caused by disease, each employee $500,000 for bodily injury caused by disease, policy limit The above policies shall provide the City of Miami with written notice of cancellation or material change from the insurer in accordance to policy provisions. Companies authorized to do business in the State of Florida, with the following qualifications, shall issue all insurance policies required above: The company must be rated no less than "A-" as to management, and no less than "Class V" as to Financial Strength, by the latest edition of Best's Insurance Guide, published by A.M. Best Company, Oldwick, New Jersey, or its equivalent. All policies and /or certificates of insurance are subject to review and verification by Risk Management prior to insurance approval. 8