Alpha Covenant Holdings · Duty Sheet · generated 2026-10-25 16:55 UTC · free · all sheets

Accounts payable — the exclusion and sanctions record at the moment of payment (42 CFR 1001.1901; 2 CFR 200.214 / 180.300; 31 CFR Part 501; FAR 9.405-2)

Applies to: Accounts-payable, treasury and procure-to-pay controllers; their ERP and payment-platform integrators · Rule text: https://www.ecfr.gov/current/title-42/chapter-V/subchapter-B/part-1001/subpart-K/section-1001.1901

The question the rule asks

Federal health care programs will not pay for items or services furnished by an excluded person (42 CFR 1001.1901), and civil monetary penalties follow payments to one (42 CFR 1003). Federal awards may not fund covered transactions with suspended or debarred parties (2 CFR 180.300; 200.214). Property of a blocked person must be blocked, not paid (31 CFR Part 501). The controller's question before funds release: what did the official files print for this payee, today, and what changed since we last read them?

The party this sheet is about

Wellpath LLC · keys supplied: UEI JL99G1YPJKK9 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_1afef40ed0f84622 · read 2026-10-25 16:55:47 UTC · SHA-256 82085ff8192dfaf98e588f342b58e2cee525b6316b69f870b1bd605f38597720 · verify: https://alphacovenantholdings.com/r/r_1afef40ed0f84622

The official files that answer it, as read on that date

SourceRoleStateRecordsWhat it printed
SAM.gov Exclusions — Public Extract V2 (GSA, daily)answers the questionanswered0No entry under this exact name/UEI in the SAM extract fetched 2026-10-24 (SAM_Exclusions_Public_Extract_V2_26297.ZIP).
HHS Office of Inspector General — LEIE (monthly downloadable file)answers the questionanswered0No entry under this exact name in the OIG file fetched 2026-10-18.
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)answers the questionanswered0No entry under this exact name or listed alias on the SDN list fetched 2026-10-24.
State Medicaid exclusion / termination lists (each state's own published file)supportinganswered0No entry under this exact name/NPI in the 13 state lists read (latest fetch 2026-10-24); 29 state lists are published in forms we cannot read and were not checked.
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directlysupportinganswered00 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
UFLPA Entity List (FLETF, 19 U.S.C. 4681) — complete list as published in the appendix to the latest Federal Register noticesupportinganswered00 UFLPA Entity List entries (name or alias as the FLETF prints it) under this exact printed name
HHS-OIG Corporate Integrity Agreements (public browse list, exact printed party name)supportinganswered0No corporate integrity agreement under this exact printed party name.

What to record in the file

The receipt read at payment time with partner_reference set to the payment or wire id, and since set to the previous receipt for the same payee — so the record shows the fresh read and every line that differs from the last one, with each file's date. Whether to hold the payment is the controller's rule in the AP system; this sheet records what the files printed, not a decision. Keep the receipt id with the payment record.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections