Performing Federal Debarment Checks for Sub-Recipients

A public agency receiving federal funding that in turn grants sub-awards to sub-recipients to carry out the terms of the grant, must check to ensure that none of the sub-recipients are suspended or debarred from doing business with the federal government.  The provision applies to such contracts of $25,000 or more.

Audit Finding:  Kitsap County, Washington recently received an audit finding from the Washington State Auditor's Office for failing to check on the suspension and debarment status of  sub-recipients.  Click here to read the audit finding.

How to Check for Debarment:  Public agencies may check on federal suspension and debarment of sub-recipients (and contractors) by either of the following three methods:

• Consult the federal Excluded Parties List System before awarding funds to sub-recipients or contractors.  www.epls.gov.
• Insert a clause or condition into the contract that states the sub-recipient or contractor is not suspended or debarred.
• Obtain a written suspension and debarment certification from the sub-recipient or contractor.

From my perspective, checking www.epls.gov and printing the documentation to maintain in your contract file, is one of the best methods for checking the suspension and debarment status.