Suspension-and-debarment purchase file — local governments, authorities and school districts (federal funds; PA cooperative purchases)

Template version 2026-10-09 · for: Townships, boroughs, cities, counties, authorities, school districts and other local public procurement units spending federal awards (direct or pass-through) · owner role: Finance Director / CFO (owner); Purchasing or AP (record keeper); Solicitor (decisions); the Single Audit firm (reader) · adopted by organization effective date . Editable .txt · JSON

Template. Written against the public text of the standard cited; the organization adopts, edits and owns it as its protocol. Every threshold, identity, hold or disclosure decision belongs to the organization. We report the findings against the protocol — counts, dates, states — nothing more. Not legal advice, not a compliance determination, not a consumer report.

Standards served

2 CFR 180.300 — before entering a covered transaction, check SAM.gov exclusions, collect a certification, or add a clause — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-I/part-180/subpart-C/section-180.300
2 CFR 200.214 — suspension and debarment applies to all federal awards — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-C/section-200.214
2 CFR 200.318(h) — award only to responsible contractors — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/section-200.318
2 CFR 200.334 — records retained three years from the final expenditure report — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/section-200.334
OMB Compliance Supplement, Part 3, section I (Procurement and Suspension and Debarment) — the auditor's test — https://www.whitehouse.gov/omb/information-for-agencies/circulars/
62 Pa.C.S. § 1902 — Pennsylvania cooperative purchasing (COSTARS) for local public procurement units — https://www.legis.state.pa.us/cfdocs/legis/LI/consCheck.cfm?txtType=HTM&ttl=62&div=0&chpt=19

Scope

Every contract, purchase order or subaward of $25,000 or more paid in whole or part from a federal award (2 CFR 180.220 covered transactions), including purchases made through a cooperative contract. A cooperative contract does not perform the exclusion check for you.

Frequency

Once before each covered transaction is signed or the purchase order is issued; again at renewal or extension; the file is kept for the retention period in 2 CFR 200.334.

Procedure

Before signature or PO: read SAM.gov exclusions for the vendor's exact legal name as it appears on the W-9 or contract (and its UEI where held). Keep a dated record that shows the source, the file date, the read time, the exact name or key used, the rows as printed (or 'no row under this printed name'), and a hash or other means for the auditor to re-check it. A memory of having looked is not a record; neither is a screenshot without a date.
Record the federal award the purchase is charged to (ALN, pass-through agency, award number) and the procurement method used (2 CFR 200.320 threshold), on the same sheet as the exclusion read.
State list, where your state law or the funding agreement requires it: read your state's own debarment list for the same name and date it. Several state lists refuse automated reads (Pennsylvania's debarment search and Texas's Comptroller list publish robots.txt rules that disallow it; Ohio's DAS list page did not answer our reader), so this line is often a by-hand read: print the official page with its date, or record the search and result in your own words with the time. New York's OGS non-responsible list and NY DOL debarment list are published as tables. A state list is not the SAM.gov read and does not replace it.
Cooperative purchase (COSTARS or another vehicle): record the contract number and that the supplier held the contract on the purchase date, as the directory or contract document shows it. Your auditor may also ask how the cooperative award itself met 2 CFR 200.318–200.327 for this federal award; file what the vehicle publishes about its competition.
A row printed under the vendor's name is a candidate, not a finding. Route it to the Solicitor with the agency's record (UEI, address, exclusion type, dates); the Solicitor and the Finance Director decide whether it is the same party and whether the purchase proceeds. Record who decided, when, and on what.
If SAM.gov did not answer (quota, outage), the file says so and the read is repeated before signature; 'did not answer' is never recorded as 'no result'.
Keep the dated record, the award line, the procurement-method line, the cooperative-contract line and any Solicitor decision together in the purchase file for the 2 CFR 200.334 period. When the Single Audit firm samples the transaction, hand over the file as kept — nothing is reconstructed after the fact.

Findings reported — computed from your own records; the threshold is your protocol's

Finding	Computed as	Data source	Threshold
Covered transactions with a dated pre-award read	transactions ≥ $25,000 on federal funds with a dated exclusion record in the file before the signature or PO date ÷ all such transactions	AP ledger (federal fund codes); purchase files; receipts or results CSV	your protocol
Reads that did not answer and were repeated	files where SAM.gov printed did-not-answer and a second dated read exists before signature ÷ files with a did-not-answer line	receipt did_not_answer lists	your protocol
Cooperative purchases with contract line	cooperative purchases on federal funds whose file shows the contract number and the supplier's contract status on the purchase date ÷ all cooperative purchases on federal funds	purchase files	your protocol
Candidate rows routed before signature	printed-name rows routed to the Solicitor before signature ÷ rows printed	routing log	your protocol
Evidence producibility	minutes to produce the complete file for a randomly chosen covered transaction from a prior year (test before each audit)	drill	your protocol

Records

Record	Kept by	Retention
Dated exclusion read per covered transaction (source, file date, read time, name/key, rows, hash)	Purchasing / AP	3 years from final expenditure report (200.334)
Award and procurement-method line	Finance	same
Cooperative-contract line (contract number, supplier status on purchase date)	Purchasing	same
Solicitor decision on any printed-name row	Solicitor / Finance Director	same
Pre-audit producibility drill result	Finance Director	same

Pilot kit — how to send the file

What to send	A CSV of the vendors paid from federal funds in the last 12 months (or the vendors on open covered transactions): column name (legal name as on the W-9), optional uei, ein, state, reference (your PO or contract number), forms (write two-cfr-180-300; add costars-contract for cooperative purchases). Up to 500 rows under the standing offer.
Where	https://alphacovenantholdings.com/challenge (free, one time per organization; the comparison is published as counts and dates only) or, for a monthly cycle, https://alphacovenantholdings.com/roster.
What comes back	One dated receipt per vendor name within 48 hours — SAM.gov exclusions, OIG LEIE, OFAC and the state lists as printed, with every source that did not answer named — plus the counts above for your Finance Director. The award decision stays with you.
CSV header	`name,uei,ein,state,reference,forms`

What this procedure does not decide

Whether a printed-name row is your vendor; whether the purchase proceeds; whether a cooperative award satisfied the federal procurement standards for your award; what your auditor concludes. The Solicitor, the Finance Director and the auditor decide those. This template and any receipt record what the official files printed on a date.

Change log

Date	Change
2026-10-09	State-list step added after a research pass on state debarment lists (PA, OH, NY, TX): duty depends on state law or the funding agreement; most lists refuse automated reads, so the step is written as a dated by-hand read.
2026-10-09	First issue. Written after Township of Cranberry FAC finding 2025-002 (no evidence a SAM.gov record was reviewed before contract) and City of Lancaster FAC finding 2024-001 (COSTARS price treated as competitive procurement), both audited by the same firm — the two most common shapes of the local-government finding.
date	adopted / edited by name

Other templates: 01 · 02 · 03 · 05 · 06 · 07 · 08 · 09 · 10 · Duty Sheets (one page per rule, generated on any receipt) · our own procedures · 2026-10-25