{"id":"hosp-02-vendor-screening","version":"2026-10-06","stamp":"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.","title":"Vendor and contractor exclusion / debarment screening — before contract and monthly","org":"Hospitals, health systems, group practices; grantee organizations for federally funded purchases","owner_role":"Supply Chain / Contracting (owner); Compliance Officer (oversight); Grants Office for federal-award purchases","scope":"Every vendor, contractor, staffing agency, consultant and subrecipient; both the entity and, where the contract names them, its owners and managing employees. Federal-award-funded purchases additionally fall under 2 CFR 180.","frequency":"Before contract signature or first PO; monthly thereafter while active; again before any payment over $___ (see HOSP-05).","procedure":["Vendor master data: legal name exactly as on the W-9, UEI (required for any federal-award purchase), EIN, state(s) of operation, contract owner. The vendor master is the roster.","Before signature: one dated record showing OIG LEIE, SAM.gov exclusions, the state Medicaid list(s), OFAC SDN and the Consolidated Screening List as read on that date, with file dates and the key used (UEI beats name). Attach to the contract file.","Monthly: re-run the active vendor master; review every changed line and every same-name candidate per HOSP-01 step 3. Record decisions.","For federal-award purchases: the SAM.gov read is method (a) of 2 CFR 180.300; file it with the procurement record the Single Audit will sample (Compliance Supplement Part 3 §I).","A source that did not answer leaves the vendor's check incomplete; re-run within ___ business days. Do not release a contract on a 'no results' that was really 'not read' — decide under your own rule, and write the rule here: ___.","Terminated vendors leave the roster after final payment; their records stay per HOSP-08."],"not_decided":"Whether to contract, pay, hold or terminate; whether a same-name row is the vendor; whether a 'compelling reason' exception applies. Those are the organization's and counsel's.","changes":[["2026-10-06","First issue."]],"standards":[{"standard":"HHS-OIG General Compliance Program Guidance — vendors and contractors","url":"https://oig.hhs.gov/compliance/general-compliance-program-guidance/"},{"standard":"2 CFR 180.300 — verify non-exclusion before a covered transaction (federal-award funds)","url":"https://www.ecfr.gov/current/title-2/subtitle-A/chapter-I/part-180/subpart-C/section-180.300"},{"standard":"2 CFR 200.214 — suspension and debarment applies to every federal award","url":"https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/section-200.214"},{"standard":"31 CFR Part 501 / OFAC — sanctions screening of counterparties","url":"https://ofac.treasury.gov/"}],"measures":[{"measure":"Pre-contract coverage","computed_as":"new contracts/POs with a dated receipt on or before signature ÷ new contracts/POs","data_source":"contract system dates; receipt created_at","threshold":"set by your protocol; the finding is the number"},{"measure":"Active-vendor monthly coverage","computed_as":"active vendors with a receipt this month ÷ active vendors","data_source":"vendor master; results CSV","threshold":"set by your protocol; the finding is the number"},{"measure":"UEI capture (federal-award vendors)","computed_as":"vendors paid with federal funds that carry a UEI ÷ all such vendors","data_source":"vendor master","threshold":"set by your protocol; the finding is the number"},{"measure":"Did-not-answer rate by source","computed_as":"receipts where source X did not answer ÷ receipts, per source, per month","data_source":"results CSV / receipt telemetry","threshold":"set by your protocol; the finding is the number"},{"measure":"Changed lines before payment","computed_as":"payments over $___ released after a changed line was reviewed ÷ payments with a changed line","data_source":"AP log + ENTITY_STATE_DELTA events","threshold":"set by your protocol; the finding is the number"}],"records":[{"record":"Vendor master (roster)","kept_by":"Supply Chain","retention":"per HOSP-08"},{"record":"Pre-contract receipt in contract file","kept_by":"Contracting","retention":"contract life + per HOSP-08"},{"record":"Monthly receipts + review log","kept_by":"Compliance","retention":"per HOSP-08"}]}