3 CRITICAL TIMES TO CHECK FOR SUSPENSION AND DEBARMENT – DO YOU KNOW THE REQUIREMENTS?
It’s every kid’s nightmare. That day when their “friend” says “I don’t like you anymore!” This unpleasant situation can also happen to organizations, governmental units and individuals.
It’s called “suspension and debarment.” It is when the Federal Government says “I don’t like you anymore!” Sometimes, we make up with each other. That’s called “suspension.” Sometimes, we don’t. That’s called “debarment.” As a Grant recipient, you can’t let any Federal money go out to anyone who is suspended or debarred.
Suspension and Debarment Video Lesson.
Length: Approx. 3 minutes
Grant Management Basics: Suspension and Debarment
Organizations, governmental units, and individuals can be excluded from participation in Federal Awards, Subawards and certain types of Federal contracts if they are suspended, debarred or otherwise excluded from participation in Federal spending.
It is the responsibility of the Grant recipient to make sure that no Federal funds flow out to an excluded person or organization.
How do I check for suspension and debarment?
Grant recipients can find out who is excluded from participation by checking the Excluded Parties List System (EPLS).
The EPLS is the comprehensive list maintained by the Federal Government containing names of individuals, organizations and governmental units that are prohibited from participating in Federal procurement and non-procurement transactions.
This list is updated continuously by various Federal Agencies.
To check the Excluded Parties List System, go to www.EPLS.gov. There you will be able to query on both simple searches and advanced searches.
For example, you can search on:
- 1) Individual Name
- 2) Organization Name
- 3) Taxpayer identification number, also known as T-I-N
- 4) Other Criteria
Who has to check?
Both Recipients of Federal Awards and Federal Agencies are required to check the excluded parties’ list system prior to opening bids or awarding work. Think of this process with a primary objective towards making sure funds do not flow out to an excluded party.
When do I have to check?
Federal Agencies must check the Excluded Parties List System:
- #1: Before approving any primary tier covered transaction, such as a Grant, Cooperative Agreement or contract.
- #2: To make the sure the “principal individual” involved in a primary tier covered transaction is not an excluded party.
- #3: To check lower tier participants or principals when Agency approval is required for the lower tier transactions. (For example if there is a Subaward or other contract that requires Agency approval.)
For contracting officers at a Grant recipient, there are also several milestones that require checking the EPLS.
The Grant recipient must:
- #1: Check at the opening of bids or receipt of proposals
- #2: Check again immediately before letting out the work
- 3: Check again before awarding any new work to make sure nothing changed since the bid was opened
How do I prove I checked?
The documentation for the Excluded Parties List System is concerned with both when you checked and who you checked. Therefore, it is important that you include both the date checked and the criteria used in the query.
An easy way to document this is to print the results of the query from your web browser. This will show both the date stamp and the query criteria.
Remember, this topic is a favorite of auditors, so put the documentation in a place it can be easily accessed for both auditors and Agency requests.
P.S. Here’s even more free information.
Get your own very cool, one page “Quick Reference Guide: Suspension and Debarment.”
(Just click on the link to download the .pdf file.)
This is the seventh section in our seven part series on “Grant Management Basics.”
Thanks for taking the series. Want to find out even more?
You can find out more about Grant Management requirements in MyFedTrainer.com’s Grants Management Boot Camp for Federal Grant Recipients. Check out the online courses:
Grant Management Boot Camp includes 12 modules on the Administrative Requirements and Cost Principles, specifically:
These 8 “Boot Camp” courses cover the main areas related to Administrative Requirements for Recipients of Federal Awards:
- Course #1: Getting Started
- Course #2: Preaward Requirements
- Course #3: Financial Management Systems
- Course #4: Payment Management
- Course #5: Other Financial and Program Management Topics
- Course #6: Property Standards
- Course #7: Procurement Standards
- Course #8: Closing Out Awards
These 4 “Boot Camp” courses cover the main areas related to Cost Principles requirements for Recipients of Federal Awards:
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- Course #2: Indirect Cost Principles
- Course #3: Allowable Cost Principles
- Course #4: Unallowable Cost Principles
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