What is suspension and debarment verification?

Suspension and debarment verification is the compliance duty to verify that a party is not excluded or disqualified before entering a covered transaction. The duty belongs to the participant or other responsible person, not to the search tool.

The phrase describes more than looking for the words suspended or debarred. Verification must account for the active SAM.gov Exclusions records that affect the transaction, including other exclusion types and statutory disqualifications within the applicable program.

Nonprocurement covered transactions

Under 2 CFR 180.300, a participant must verify that the person at the next lower tier is not excluded or disqualified before entering a covered transaction. The rule permits three methods: checking SAM.gov Exclusions, collecting a certification, or adding a clause or condition to the covered transaction.

The duty does not automatically apply to every purchase made with federal funds. Vendor transactions require verification under this rule only when they are covered transactions.

Subrecipient verification

2 CFR 200.332(a) requires a pass-through entity to verify that every subrecipient is not excluded or disqualified in accordance with 2 CFR 180.300. That duty is part of establishing the subaward relationship.

The subrecipient classification matters. A contractor or vendor is not converted into a subrecipient merely because federal funds pay for the purchase.

Prime contractor subcontracting rules

Federal prime contractors follow the procurement framework in FAR 9.405-2 and, when included, FAR 52.209-6. The rules address certain subcontracts above $45,000, include a COTS exception, and require disclosure or notice in the circumstances they cover.

This prime-facing process is commonly called subcontractor screening. The contract, clause, tier, subcontract value, and item type determine the actual duty.

Timing, cadence, and evidence

Verification should occur at the time required by the governing transaction, award term, or internal control. No single rule creates a universal daily re-check requirement for every party. Recurring monitoring is an operational control used to detect later changes across an ongoing roster.

Evidence should identify the party, method, check time, source as-of time, source retrieval time, and result. When SAM.gov Exclusions is used, preserve the matching basis and distinguish identifier matches from potential name matches.

What federal.contractors documents

The service runs exclusion checks and seals format 2 verification records containing the query, result, check time, source as-of and retrieval times, source artifact and digest, completeness facts, identity basis, candidate state, and method versions. It can re-check a roster on a schedule and preserve each dated observation.

The resulting record is evidence of diligence, not a legal opinion or promise about how a third party will assess the transaction.

Primary sources

Run a documented exclusion check