Procurement, Suspension, and Debarment

Scope

These procedures address how to check for Debarment or Suspension from an entity or agency that subawards or contracts for goods and/or services.

Reason for Policy

To ensure contracts or purchases to an entity or agency are not made if they have been Debarred or Suspended by the federal government.

Policy Statement

The Federal Government prohibits expending federal funds on goods and/or services from any entity Suspended or Debarred from doing business with the federal government. Procurement of goods and/or services with federal funds from a supplier or contractor should be checked for Debarment before purchasing and/or awarding a contract or subaward.

Debarment should be checked prior to purchasing or contracting with any entity or agency to ensure the entity or agency has not been Debarred or Suspended by the federal government at the System for Award Management (SAM.gov – previously EPLS) website (http://www.sam.gov/).  Each campus is responsible to ensure all templates for any type of procurement transaction, and all procurement contracts and agreements for both goods and services must have the following verbiage included in the documentation immediately adjacent to the signature line:

“Debarment and Suspension Certification - The contractor (or vendor, or consultant, depending on the transaction) certifies to the best of its knowledge and belief that it and its principals are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by any Federal department or agency in accordance with 2 CFR 200.213 and 2 CFR 180.”

The SAM website must be checked to verify the entity or agency has not been Debarred or Suspended prior to entering into a subaward with an entity or agency with federal dollars. The Sponsored Programs Office (SPO) must document the Suspension and Debarment verification by including a screen print of the Exclusions search in the subaward file. If the entity or agency is on the list, contracts cannot be approved until the entity or agency is removed from the Exclusions listing.

After a subaward is awarded, the UM System Controller’s office must verify the subrecipient is not listed on the SAM.gov website at the time an annual risk assessment is prepared during the life of each Federally funded subaward. The Suspension and Debarment verification must be documented by including a screen print of the Exclusions search with the other subrecipient monitoring documentation. If at any time the SAM.gov website indicates the subrecipient has active exclusions, no invoices will be paid until the entity or agency is removed from the exclusion listing.

Definitions

Debarred or Debarment - the exclusion of a person from participating in procurement transactions with the federal government, generally for no more than three years.

Suspended or Suspension - an action which suspends federal assistance under an award pending corrective action by the awardee or pending a decision to terminate the award.

Accountabilities

UM System Controller’s Office:

• Document evidence of verification that subrecipients are not Suspended or Debarred at the time annual risk assessments are prepared on active subawards.

Sponsored Programs Office (SPO):

• Document evidence of verification that subrecipients are not Suspended or Debarred prior to awarding a subaward.

SPO Manager (or delegate):

• On a basis, validate that of EPLS verification for subawards is

Additional Details

Forms

Related Information

System for Award Management website (http://www.sam.gov/)

History

Formerly Accounting Policy Manual 60.57 – Procurement, Suspension, and Debarment (revised 2/25/2009)

Procedure