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FTA C&A (annual)

FTA Annual Certifications and Assurances (TrAMS) — Category 01 includes suspension and debarment; Category 05 Davis-Bacon

Suspension and debarment check for federal awards (2 CFR 180 / 200) — the steps as written

#	Step	Who	When	Record	Citation
1	Identify each covered transaction: a procurement contract expected to equal or exceed $25,000, any subaward, and any contract the award terms designate.	recipient or pass-through entity	before entering the transaction	the procurement or subaward file	2 CFR 180.220(b); 2 CFR 200.214
2 ●	Before entering it, do one of three things: (a) check SAM.gov Exclusions for the party, (b) collect a certification from the party, or (c) add a clause to the transaction.	recipient	before award	the dated SAM exclusions read under the party's name and UEI — option (a)	2 CFR 180.300
3 ●	Keep the read with the procurement history for that transaction.	recipient	at award	dated, hashed receipt filed with the procurement record	2 CFR 200.318(i); Retain 3 years from the date the final expenditure report is submitted (2 CFR 200.334).
4	Pass the requirement down: the subaward or contract carries the 2 CFR 180 terms so the lower tier does the same.	pass-through entity	at subaward	subaward terms	2 CFR 180.330; 2 CFR 200.332(a)
5 ●	Where the program conditions a payment on the payee's eligibility, read the payee's name before disbursing and file it with the invoice.	recipient (accounts payable)	before each covered disbursement	payment-time read on the payee's printed name	24 CFR 570.506 (CDBG records); 2 CFR 200.403

● a dated receipt is the record at this step.

Keeping the file

#	Step	Record	Where
F1	At each ● step, pull the dated receipt under the party's exact name or UEI and file its receipt id with the transaction record.	receipt id (r_…) on the procurement, subaward or payment record	https://alphacovenantholdings.com/screening
F2	Anchor your own document for the step — the signed check, the certification, the memo — by its SHA-256 beside the receipt. The document stays with you; only its hash is logged.	anchor id (a_…) in the same log as the receipt	https://alphacovenantholdings.com/r/{receipt_id} → Anchor
F3	Note the retention line the file sits under and, once the trigger date is known, the date the period runs to.	the rule's own words and date (FAR 4.703/4.705 or 2 CFR 200.334)	https://alphacovenantholdings.com/api/retention/rules
F4	At period end, keep the signed file statement for the organization: every receipt and anchor, the sources read and which did not answer, the log head they chain to.	one signed page per UEI; its hash and signature verify without Alpha Covenant	https://alphacovenantholdings.com/file/{uei}

How the dated records are kept, not what they prove. A receipt shows what the official file printed on the read date; an anchor shows a document existed in that exact form on that date; the file statement lists what the file holds. None of them states that a step was done correctly or that the organization is eligible or compliant.

How the auditor tests it

Select a sample of procurements at or above $25,000 and of subawards; determine whether, before entering each, the entity checked SAM Exclusions, collected a certification, or included a clause — and whether the file shows it. — OMB Compliance Supplement (2 CFR 200 App. XI), Part 3, Section I — Procurement and Suspension and Debarment, audit objectives and suggested audit procedures
Finding written when the check cannot be evidenced: 'documentation of verification through SAM.gov or equivalent methods was not available' (Hamilton Health Center 2025-003, FAC report 2025-03-GSAFAC-0000391916). — the auditor's words as filed at fac.gov

The steps as the regulation and the auditor's program state them, each with its citation. Nothing here is advice or a determination; the agency's text controls. A dated receipt is the record at the marked steps — it shows what the official file printed on the read date, not that the step was done correctly.

Not legal advice, not a compliance determination, not a statement that any filer's certification is true or false. Form numbers and line numbers are as published on the date noted and may be renumbered by their agencies; the official page controls. Audit findings quoted are the auditor's words as filed at the Federal Audit Clearinghouse, cited by report id; they describe a documentation gap, not a conclusion about any party.