For grantees and pass-through entities

Subrecipient Suspension and Debarment Verification Checklist

Before a pass-through entity makes a subaward, it must verify that the subrecipient is not suspended, debarred, or otherwise excluded. This checklist walks the decision points in the rules, separates what must be verified from what is only one permitted method, and lists the evidence worth retaining. Every citation links to the current eCFR text.

Reviewed 2026-08-23 against the eCFR text current on that date.

Run a free exclusion check

What the rules require

2 CFR 200.332(a)

Verify each subrecipient

Before making a subaward, a pass-through entity must verify that the subrecipient is not excluded or disqualified, following the OMB guidance in 2 CFR part 180.

2 CFR 200.318(h) with 2 CFR 180.300

Procurement contracts

Recipients and subrecipients must award contracts only to responsible contractors. For covered transactions, 2 CFR 180.300 separately requires verifying that the party is not excluded or disqualified.

2 CFR 180.300

Three permitted methods

The duty is the verification. The rule permits any of three methods: checking SAM.gov Exclusions, collecting a certification from the party, or adding a clause to the transaction.

OMB Compliance Supplement

The item gets audited

The Compliance Supplement (2 CFR part 200 appendix XI) makes suspension and debarment a tested compliance requirement in the Single Audit. Auditors ask for the evidence of the verification itself.

The checklist

Classify the relationship

Decide whether the money flows as a subaward or a procurement contract; 2 CFR 200.331 states the distinction. A subaward triggers the 200.332(a) verification. A procurement contract follows 200.318(h), and a covered transaction carries the 180.300 duty. 2 CFR 200.331

Verify before money flows

The verification comes before the subaward or covered transaction, not after. A check run after signature documents a different fact than the rule asks for. 2 CFR 200.332(a)

Choose a method deliberately

Checking SAM.gov Exclusions is one of the three permitted methods, alongside a certification or a clause. A free SAM.gov search satisfies the rule on its own. Whichever method your program uses, name it in your procedures so the evidence matches the claim. 2 CFR 180.300

Resolve identity, not just names

A name match in the exclusions data is a potential match, never identity confirmation. Confirm or clear it against an identifier (UEI, and CAGE where available) and write down how the ambiguity was resolved. SAM.gov Exclusions

Retain the evidence

Keep what shows the verification happened: when the check ran, which source it ran against and the date of that data, and how names were resolved. The next section lists the evidence in full.

Decide your re-check policy

The rule attaches to the moment of the transaction. Recurring re-checks during performance are a control many programs add so a later exclusion does not go unnoticed. If you adopt one, keep the same evidence for every re-check.

Evidence worth retaining

What shows the verification happened

·When the check ran: date and time, with the timezone stated.
·Which source was checked and the as-of date of its data. For SAM.gov Exclusions that is the date of the extract the check ran against; an undated screenshot does not show when the data was from.
·The query as entered, and the identity resolution: which UEI a name resolved to, or how a name-only potential match was confirmed or cleared.
·Gaps and exceptions: parties that could not be resolved to an identifier, and what the program did about them.
·Who ran the check, if your procedures assign that responsibility.

Documented examples

federal.contractors returns a dated result from a SAM.gov exclusion check for review. Sealing a reviewed check saves a verification record with the check time, dated source, and identity resolution. Monitoring seals each completed re-check automatically. Who ran the check and what your program did about unresolved parties stay in your own procedures and workpapers. A record is evidence of diligence, not a verdict, and a free SAM.gov search satisfies 2 CFR 180.300 on its own.

See a real sealed record See a sample audit packet Start subrecipient monitoring

This page summarizes the cited rules for program staff. It is general information, not legal advice. The Compliance Supplement is published by OMB; the current edition is linked from the OMB circulars page and referenced at 2 CFR part 200 appendix XI.