A hospital or health system in Ohio

2 CFR 180.300 · 2 CFR 200.214 · 2 CFR 200.318(h) — Lower-tier covered transaction check for federal awards (grants, cooperative agreements, loans) — recipient's procurement file

The line: 180.300: before entering a covered transaction the participant must (a) check SAM Exclusions, (b) collect a certification from the other party, or (c) add a clause. 200.214 applies it to every federal award; 200.318(h) to every procurement.

Citation: 2 CFR 180.300; 2 CFR 200.214; 2 CFR 200.318(h) · text · official page

Duty Sheet(s):

• 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements) — Grantees, pass-through entities and subrecipients, before any covered transaction
• Single Audit — Compliance Supplement Part 3 §I, Procurement and Suspension and Debarment (auditor's test) — Independent auditors performing Single Audits under 2 CFR 200 Subpart F; the auditee's grants office preparing for one

The step where a dated receipt is the record:

• Step 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. — 2 CFR 180.300
• Step 3: Keep the read with the procurement history for that transaction. — 2 CFR 200.318(i); Retain 3 years from the date the final expenditure report is submitted (2 CFR 200.334).
• Step 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. — 24 CFR 570.506 (CDBG records); 2 CFR 200.403

Official record it rests on, and how this platform reads it:

• SAM.gov Exclusions — Public Extract V2 — https://sam.gov/search/?index=ex
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served

What a read cannot prove: That the vendor is the same entity as a same-named row (a name match is a candidate, not identity); that the award exceeded the threshold.

Finding pattern(s): Suspension & debarment check not documented, or evidence not retained; Payment to an ineligible party; insufficient documentation at invoice · register · procedure as written

SF-424B · SF-424D — SF-424B Assurances — Non-Construction Programs · SF-424D Assurances — Construction Programs

The line: The applicant assures it will comply with all applicable requirements of federal laws, executive orders, regulations and policies governing the program — which include 2 CFR 180 and 2 CFR 200.

Citation: SF-424B item 18 / SF-424D item 19 (as numbered on the current OMB form); 2 CFR 200.214 · text · official page

Duty Sheet(s):

• 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements) — Grantees, pass-through entities and subrecipients, before any covered transaction

The step where a dated receipt is the record:

• Step 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. — 2 CFR 180.300
• Step 3: Keep the read with the procurement history for that transaction. — 2 CFR 200.318(i); Retain 3 years from the date the final expenditure report is submitted (2 CFR 200.334).
• Step 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. — 24 CFR 570.506 (CDBG records); 2 CFR 200.403

Official record it rests on, and how this platform reads it:

• SAM.gov Exclusions — Public Extract V2 — https://sam.gov/search/?index=ex
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• Federal Audit Clearinghouse (single audits) — https://www.fac.gov
  live lookup at request time; 'did not answer' when the endpoint does not respond

What a read cannot prove: Any other assurance on the form (civil rights, environmental, labor standards, reporting).

Finding pattern(s): Suspension & debarment check not documented, or evidence not retained · register · procedure as written

SF-SAC — SF-SAC Data Collection Form for Reporting on Audits of States, Local Governments and Non-Profit Organizations

The line: Part III findings: reference number, compliance requirement type (I = Procurement and Suspension and Debarment; M = Subrecipient Monitoring), material weakness, repeat. The pass-through entity's duty to obtain the subrecipient's audit sits in 2 CFR 200.332(f) and 200.501.

Citation: 2 CFR 200.512 (submission); 2 CFR 200.332(f); 2 CFR 200.501 · text · official page

Duty Sheet(s):

• Single Audit — Compliance Supplement Part 3 §I, Procurement and Suspension and Debarment (auditor's test) — Independent auditors performing Single Audits under 2 CFR 200 Subpart F; the auditee's grants office preparing for one
• 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements) — Grantees, pass-through entities and subrecipients, before any covered transaction

The step where a dated receipt is the record:

• Step 3: Verify that a subrecipient expected to expend $1,000,000 or more in federal awards in its fiscal year ($750,000 for fiscal years beginning before 1 Oct 2024) had the required audit, and that it was filed. — 2 CFR 200.332(f); 2 CFR 200.501(a); 2 CFR 200.512(a)
• Step 5: Report each first-tier subaward of $30,000 or more, with the subrecipient's UEI, by the end of the month following the month of obligation. — 2 CFR 170 Appendix A; FAR 52.204-10(d) for contracts

Official record it rests on, and how this platform reads it:

• Federal Audit Clearinghouse (single audits) — https://www.fac.gov
  live lookup at request time; 'did not answer' when the endpoint does not respond
• USAspending subawards (prime-to-sub money flow) by exact sub-awardee name — https://www.usaspending.gov/search
  live lookup at request time; 'did not answer' when the endpoint does not respond

What a read cannot prove: The content of the audit beyond what FAC prints; whether the pass-through entity's monitoring was adequate.

Finding pattern(s): Subrecipient single audit not obtained; no additional monitoring · register · procedure as written

CMS-855A · 855B · 855I · 855S — CMS-855A / 855B / 855I / 855S Medicare Enrollment Applications — Section 3 Final Adverse Legal Actions

The line: Section 3 asks the applicant to list exclusions, debarments, revocations and license suspensions; 42 CFR 424.516 requires reporting changes within 30 days; 42 CFR 424.535 lists revocation grounds.

Citation: 42 CFR 424.516; 42 CFR 424.535; 42 CFR 1001.1901 · text · official page

Duty Sheet(s):

• 42 CFR 455.436 — Federal database checks (Medicaid provider screening) — State Medicaid agencies and, by contract, Medicaid managed care organisations
• HHS-OIG General Compliance Program Guidance — exclusion screening of employees, medical staff and vendors — Any provider or supplier billing federal health care programs; OIG recommends screening at hire/contract and monthly

The step where a dated receipt is the record:

• Step 2: The state agency checks the provider and every disclosed person against the OIG LEIE and SAM Exclusions at enrollment and re-enrollment. — 42 CFR 455.436(b)
• Step 3: The state agency repeats the LEIE and SAM check monthly. — 42 CFR 455.436(c)(2)
• Step 4: No federal program payment for items or services furnished, ordered or prescribed by an excluded person; providers check their own staff and contractors. — 42 CFR 1001.1901(b); 42 CFR 438.610; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)
• Step 5: Managed care plans screen and the state enrolls network providers; plans report excluded or terminated providers. — 42 CFR 438.608(b)–(c)

Official record it rests on, and how this platform reads it:

• HHS-OIG LEIE (List of Excluded Individuals/Entities) — https://oig.hhs.gov/exclusions/exclusions_list.asp
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• SAM.gov Exclusions — Public Extract V2 — https://sam.gov/search/?index=ex
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• State Medicaid exclusion / termination lists — https://oig.hhs.gov/exclusions/state-exclusion-lists/
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• CMS NPPES NPI Registry — https://npiregistry.cms.hhs.gov
  live lookup at request time; 'did not answer' when the endpoint does not respond

What a read cannot prove: Identity (a name match is a candidate); whether a disclosure was owed; the outcome of enrollment.

Finding pattern(s): Provider exclusion screening not performed at enrollment or monthly · register · procedure as written

42 CFR 455.104 · 455.105 · 455.106 · 455.436 — State Medicaid provider enrollment application and disclosures (ownership and control, business transactions, criminal convictions) — one form per state

The line: 455.436(b)–(c): the state agency checks the LEIE and SAM exclusions at enrollment, re-enrollment and monthly thereafter; 455.104–106: the provider discloses owners, managing employees and convictions on the state's form.

Citation: 42 CFR 455.436; 42 CFR 455.104–455.106 · text · official page

Duty Sheet(s):

• 42 CFR 455.436 — Federal database checks (State Medicaid agency side) — State Medicaid agencies and their program-integrity units, at enrollment, re-enrollment, revalidation and no less frequently than monthly
• 42 CFR 455.436 — Federal database checks (Medicaid provider screening) — State Medicaid agencies and, by contract, Medicaid managed care organisations

The step where a dated receipt is the record:

• Step 2: The state agency checks the provider and every disclosed person against the OIG LEIE and SAM Exclusions at enrollment and re-enrollment. — 42 CFR 455.436(b)
• Step 3: The state agency repeats the LEIE and SAM check monthly. — 42 CFR 455.436(c)(2)
• Step 4: No federal program payment for items or services furnished, ordered or prescribed by an excluded person; providers check their own staff and contractors. — 42 CFR 1001.1901(b); 42 CFR 438.610; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)
• Step 5: Managed care plans screen and the state enrolls network providers; plans report excluded or terminated providers. — 42 CFR 438.608(b)–(c)

Official record it rests on, and how this platform reads it:

• HHS-OIG LEIE (List of Excluded Individuals/Entities) — https://oig.hhs.gov/exclusions/exclusions_list.asp
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• SAM.gov Exclusions — Public Extract V2 — https://sam.gov/search/?index=ex
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• State Medicaid exclusion / termination lists — https://oig.hhs.gov/exclusions/state-exclusion-lists/
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served

What a read cannot prove: Enrollment status; that disclosed owners were screened; identity behind a name match.

Finding pattern(s): Provider exclusion screening not performed at enrollment or monthly · register · procedure as written

42 CFR 422.503(b)(4)(vi)(F) · 423.504(b)(4)(vi)(F) — Medicare Advantage / Part D compliance program — first-tier, downstream and related entity (FDR) exclusion screening attestation (HPMS)

The line: The sponsor's compliance program must screen employees, governing body and FDRs against the OIG LEIE and SAM before hire or contract and monthly thereafter; attested annually in HPMS.

Citation: 42 CFR 422.503(b)(4)(vi)(F); 42 CFR 423.504(b)(4)(vi)(F) · text · official page

Duty Sheet(s):

• CMS Medicare Advantage / Part D compliance program — first-tier, downstream and related entity (FDR) exclusion screening — MA organisations and Part D sponsors, and their FDRs

The step where a dated receipt is the record:

• Step 2: The state agency checks the provider and every disclosed person against the OIG LEIE and SAM Exclusions at enrollment and re-enrollment. — 42 CFR 455.436(b)
• Step 3: The state agency repeats the LEIE and SAM check monthly. — 42 CFR 455.436(c)(2)
• Step 4: No federal program payment for items or services furnished, ordered or prescribed by an excluded person; providers check their own staff and contractors. — 42 CFR 1001.1901(b); 42 CFR 438.610; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)
• Step 5: Managed care plans screen and the state enrolls network providers; plans report excluded or terminated providers. — 42 CFR 438.608(b)–(c)

Official record it rests on, and how this platform reads it:

• HHS-OIG LEIE (List of Excluded Individuals/Entities) — https://oig.hhs.gov/exclusions/exclusions_list.asp
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• SAM.gov Exclusions — Public Extract V2 — https://sam.gov/search/?index=ex
  held copy, re-fetched on the cadence shown; SHA-256 of the file as served

What a read cannot prove: That the compliance program is effective; CMS audit outcome.

Finding pattern(s): Provider exclusion screening not performed at enrollment or monthly · register · procedure as written

FAR 52.204-10 · FFATA — Reporting Executive Compensation and First-Tier Subcontract Awards (FSRS / SAM.gov)

The line: (d): the contractor reports each first-tier subcontract of $30,000 or more, with the subcontractor's UEI; the report is published through USAspending.

Citation: 48 CFR 52.204-10; 2 CFR 170 (grants); Pub. L. 109-282 (FFATA) · text · official page

Duty Sheet(s):

• 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements) — Grantees, pass-through entities and subrecipients, before any covered transaction

The step where a dated receipt is the record:

• Step 3: Verify that a subrecipient expected to expend $1,000,000 or more in federal awards in its fiscal year ($750,000 for fiscal years beginning before 1 Oct 2024) had the required audit, and that it was filed. — 2 CFR 200.332(f); 2 CFR 200.501(a); 2 CFR 200.512(a)
• Step 5: Report each first-tier subaward of $30,000 or more, with the subrecipient's UEI, by the end of the month following the month of obligation. — 2 CFR 170 Appendix A; FAR 52.204-10(d) for contracts

Official record it rests on, and how this platform reads it:

• USAspending subawards (prime-to-sub money flow) by exact sub-awardee name — https://www.usaspending.gov/search
  live lookup at request time; 'did not answer' when the endpoint does not respond

What a read cannot prove: That every reportable subcontract was reported; dollar accuracy.

Finding pattern(s): Subrecipient single audit not obtained; no additional monitoring · register · procedure as written

State layer — OH

Ohio Department of Medicaid: Provider Exclusion and Suspension List · https://medicaid.ohio.gov/wps/portal/gov/medicaid/resources-for-providers/enrollment-and-support/provider-enrollment/provider-exclusion-and-suspension-list (file)

• OhioBuys supplier registration (Ohio DAS) — ORC 125; ORC 9.24 (unresolved findings for recovery — Auditor of State) · https://ohiobuys.ohio.gov/
  Registration page held. Ohio's debarred-vendor list and ORC 9.24 unresolved-findings list are published by DAS and the Auditor of State; we hold no direct link.

Cite as

Alpha Covenant Holdings, Sector Map: A hospital or health system in Ohio (as of 2026-10-08), https://alphacovenantholdings.com/maps/oh-hospital

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.