Debarment and suspension verification (SAM.gov)

Debarment and suspension verification is a mandatory pre-award compliance check, not an optional risk-management courtesy. Before a prime recipient issues a subaward or a procuring office signs a qualifying contract using federal funds, someone has to confirm the other party — and its principals — are not on the federal government’s list of parties excluded from receiving federal funds.

The legal basis: 2 CFR 200.214 and 2 CFR Part 180

2 CFR 200.214 (part of the Uniform Guidance) states that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as codified at 2 CFR Part 180. Those regulations restrict Federal agencies and non-Federal entities from making Federal awards, subawards, and covered contracts with parties that are debarred, suspended, proposed for debarment, or otherwise excluded from participating in federal programs.

A covered transaction under 2 CFR 180.200 is any nonprocurement transaction (a subaward, in most research-administration contexts) or a procurement contract that meets the criteria at 2 CFR 180.220 — principally, a procurement contract awarded under a federal grant or cooperative agreement that is expected to equal or exceed $25,000, a contract requiring the federal awarding agency’s consent regardless of dollar value, or a contract for federally required audit services. Subcontracts at $25,000 or more can also be covered if the federal agency extends coverage to that tier.

When it’s required

Verification is required before the covered transaction is executed — not after. In practice that means before a pass-through entity countersigns a subaward agreement, and before a procurement office issues a purchase order or contract that crosses the $25,000 covered-transaction threshold. It applies to the entity itself and to its listed principals (officers, directors, and others with primary management or supervisory responsibility). It is a distinct, narrower check from the broader ongoing oversight covered by subrecipient monitoring, which continues for the life of the award; exclusion screening is specifically the pre-award gate.

How institutions verify it: the three methods in 2 CFR 180.300

2 CFR 180.300 gives a participant three permitted ways to verify that a lower-tier party is not excluded or disqualified:

1. Search the party’s name and Unique Entity Identifier (UEI) directly in SAM.gov Exclusions (“Search Records”) and retain documentation of the result;
2. Collect a signed certification from the party stating it is not debarred, suspended, or otherwise excluded; or
3. Add a clause or condition to the covered transaction requiring the party to disclose exclusion status.

SAM.gov Exclusions is maintained by the General Services Administration (GSA). It absorbed the older Excluded Parties List System (EPLS) — a separate database GSA retired on November 21, 2012 and consolidated into SAM.gov along with vendor registration data — so any institutional policy that still references “checking the EPLS” is describing this same SAM.gov Exclusions search under an outdated name. Because debarment and suspension actions are reciprocal between the procurement (Federal Acquisition Regulation) and nonprocurement systems, an exclusion recorded under either system blocks covered transactions government-wide, not just within the agency that imposed it.

Consequences of skipping it

Failing to screen — or knowingly proceeding after finding an exclusion — carries real consequences, not just a paperwork finding:

• Unallowable costs. Charges to a federal award connected to a debarred, suspended, or excluded party (salary, subaward payments, contract payments) are treated as unallowable and subject to disallowance and repayment.
• Award termination or other remedies. A federal awarding agency can treat the failure as a material failure to comply with award terms, up to terminating the award, and can pursue any other remedy available to it, including referring the recipient itself for suspension or debarment.
• Audit findings. Missing or undocumented exclusion checks are a recurring Single Audit finding for institutions that receive federal funds, since 2 CFR 200.214 compliance is a standard compliance-testing area.
• Downstream exposure. Because a prime award recipient is accountable to the sponsor for its subrecipients’ compliance, an unscreened subrecipient’s exclusion status becomes the prime recipient’s problem, not just the subrecipient’s.

None of this requires bad faith to trigger — an institution that simply never built the check into its subaward or procurement workflow is still non-compliant. Documenting the screening result (a dated SAM.gov search export, a signed certification, or the contract clause used) at the time of the transaction is what demonstrates compliance later, whether to a sponsor, an auditor, or the institution’s own research-integrity office.