2 CFR 180: Debarment Rules, Subpart by Subpart

2 CFR Part 180 is the government-wide rulebook on debarment and suspension for nonprocurement transactions such as grants and cooperative agreements. Its full title is “OMB Guidelines to Agencies on Government-wide Debarment and Suspension (Nonprocurement)”. It is organised into nine lettered subparts (A through I) plus an appendix, and each subpart answers a different question: who is covered, what a recipient must check, how an agency acts, and how long an exclusion lasts. This guide maps those subparts and pulls out the provisions research administrators meet most, based on the eCFR and Cornell Legal Information Institute texts checked on 2026-10-29.

What 2 CFR 180 is

Part 180 sets government-wide rules for how federal agencies suspend and debar people and organizations from nonprocurement transactions. It sits in Title 2 of the Code of Federal Regulations, which also holds the Uniform Guidance at 2 CFR 200. The official source is the eCFR page for 2 CFR Part 180 (ecfr.gov/current/title-2/part-180); the section text below follows the eCFR and the Cornell LII copy of it.

For a recipient, the practical link is the Uniform Guidance, which ties award recipients to these rules. The existing CASRAI guide on Uniform Guidance (2 CFR 200) covers that wider framework, and the definition of SAM.gov debarment and suspension verification covers the checking step.

Subpart-by-subpart map

The table lists the subparts exactly as the Part 180 table of contents lists them (checked 2026-10-29). There are no subparts J or K.

Subpart	Title	Sections
A	General	180.100 to 180.155
B	Covered Transactions	180.200 to 180.225
C	Responsibilities of Participants Regarding Transactions Doing Business With Other Persons	180.300 to 180.365
D	Responsibilities of Federal Agency Officials Regarding Transactions	180.400 to 180.450
E	System for Award Management (SAM.gov) Exclusions	180.500 to 180.530
F	General Principles Relating to Suspension and Debarment Actions	180.600 to 180.660
G	Suspension	180.700 to 180.760
H	Debarment	180.800 to 180.885
I	Definitions	180.900 to 180.1020

The part also carries Appendix A, “Covered Transactions”. Read the subparts by question:

Is this transaction covered? Subpart B, with Appendix A.
What must we do before dealing with another party? Subpart C, starting at 180.300.
What must the agency do? Subpart D.
Where is an exclusion recorded? Subpart E, SAM.gov Exclusions.
What counts as grounds, and how long does it last? Subparts F, G and H.
What does a defined term mean? Subpart I.

What counts as a covered transaction

Section 180.220 sets out which contracts are covered when they are made under a nonprocurement transaction such as a grant. As checked on 2026-10-29:

Situation	Covered?
Procurement contract awarded directly by a Federal agency	Not covered by Part 180
Contract for goods or services under a nonprocurement transaction, expected to equal or exceed $25,000	Covered
Contract that requires the consent of a Federal agency official	Covered regardless of amount
Contract for federally required audit services	Covered
Subcontract, where the agency’s transaction extends coverage to lower tiers and the value is expected to be $25,000 or more	Covered

Two points follow from the text. The $25,000 figure is an expected-value test, and the consent and audit-service rules apply whatever the amount. For vendor screening in practice, see the CASRAI guide on debarment and exclusion screening for vendors.

Causes for debarment

Section 180.800 lists the grounds on which a debarring official may debar a person. It groups them into four sets, (a) to (d). A recurring test across the section is whether the conduct “seriously and directly affects your present responsibility”.

Paragraph	Ground, as stated in 180.800
(a) Conviction or civil judgment	Fraud or a criminal offense in connection with obtaining or performing a public or private agreement; federal or state antitrust violations, including price fixing, customer allocation and bid rigging; embezzlement, theft, forgery, bribery, falsification or destruction of records, false statements, federal criminal tax violations, receiving stolen property, false claims and obstruction of justice; and any other offense indicating a lack of business integrity or honesty that seriously and directly affects present responsibility
(b) Violation of a public agreement	A violation serious enough to affect the integrity of an agency program: willful failure to perform, a history of failure or unsatisfactory performance, or willful violation of a statutory or regulatory provision
(c) Other causes	Certain earlier debarments (nonprocurement debarment before October 1, 1988 or procurement debarment before August 25, 1995); knowingly doing business with an ineligible person, except as permitted under 180.135; failure to pay a substantial debt that is uncontested or whose remedies are exhausted; violating a material provision of a voluntary exclusion agreement under 180.640 or another resolving agreement; and a violation of the Drug-Free Workplace Act of 1988
(d) Catch-all	Any other cause so serious or compelling that it affects present responsibility

Several items in paragraph (a), such as false claims and falsification of records, are the same kinds of conduct that appear in research misconduct and grant fraud cases. The CASRAI guide on FAPIIS, suspension and debarment, and federal award integrity checks covers how those checks fit into award management.

How long debarment lasts

Section 180.865 says that, generally, debarment should not exceed three years. The debarring official may impose a longer period if circumstances warrant. If a suspension came first, the debarring official must consider the time already suspended. A debarment based on the Drug-Free Workplace Act may not exceed five years. Suspension itself is the subject of Subpart G. A grant suspension in the award-management sense is defined separately on CASRAI.

What a recipient must verify before a lower-tier transaction

Section 180.300 is headed “What must I do before I enter into a covered transaction with another person at the next lower tier?” The answer is that you must verify the person is not excluded or disqualified, by one of three routes:

Checking SAM.gov Exclusions.
Collecting a certification from that person.
Adding a clause or condition to the covered transaction with that person.

The rule is a choice among the three, and the regulation does not require all of them. The System for Award Management definition explains the system behind the first route.

Phases of a suspension or debarment action

Part 180 arranges the process across subparts rather than as a single timeline. Subpart F sets the general principles, Subpart G deals with suspension, Subpart H with debarment, and Subpart E governs how an action is posted in SAM.gov Exclusions. Follow them in that order to trace a case from cause to listing. Response periods and notice contents are set in the individual sections, so check the current text of the section for them.

Common mistakes

Treating every purchase as covered, or none. Directly awarded federal procurement contracts fall outside Part 180, while a $25,000 expected-value contract under a grant, or any contract needing agency consent, falls inside it (180.220).
Looking for subparts that are not there. The part ends at Subpart I, Definitions, followed by Appendix A.
Assuming a fixed debarment term. Three years is the general expectation in 180.865, not a cap, and the Drug-Free Workplace Act limit of five years is a separate rule.

Related CASRAI pages

Page	What it covers
Uniform Guidance (2 CFR 200)	The wider federal award framework in the same title of the CFR
2 CFR 200 procurement standards	Procurement sections of the Uniform Guidance
FAR Part 9	The procurement-side contractor qualification rules
FAPIIS, suspension and debarment	Federal award integrity checks
Debarment and exclusion screening	Vendor screening step by step

FAQ

What is 2 CFR 180?

It is the OMB guidance on government-wide debarment and suspension for nonprocurement transactions, such as grants and cooperative agreements. It has nine subparts (A to I) and one appendix.

How long does debarment last?

Generally it should not exceed three years, though the debarring official may impose a longer period if circumstances warrant. If a suspension came first, the debarring official must consider the time suspended, and debarment under the Drug-Free Workplace Act may not exceed five years (180.865).

Is a contract under $25,000 covered?

Usually not, with exceptions. Under 180.220 a contract under a nonprocurement transaction is covered when expected to equal or exceed $25,000, but a contract that requires the consent of a Federal agency official is covered regardless of amount, and so are contracts for federally required audit services.

What are the ways to verify a lower-tier party?

Section 180.300 allows three: check SAM.gov Exclusions, collect a certification from the person, or add a clause or condition to the covered transaction.