Vendor and contractor exclusion / debarment screening — before contract and monthly

Template version 2026-10-06 · for: 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 · 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

HHS-OIG General Compliance Program Guidance — vendors and contractors — https://oig.hhs.gov/compliance/general-compliance-program-guidance/
2 CFR 180.300 — verify non-exclusion before a covered transaction (federal-award funds) — 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 every federal award — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/section-200.214
31 CFR Part 501 / OFAC — sanctions screening of counterparties — https://ofac.treasury.gov/

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.

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

Finding	Computed as	Data source	Threshold
Pre-contract coverage	new contracts/POs with a dated receipt on or before signature ÷ new contracts/POs	contract system dates; receipt created_at	your protocol
Active-vendor monthly coverage	active vendors with a receipt this month ÷ active vendors	vendor master; results CSV	your protocol
UEI capture (federal-award vendors)	vendors paid with federal funds that carry a UEI ÷ all such vendors	vendor master	your protocol
Did-not-answer rate by source	receipts where source X did not answer ÷ receipts, per source, per month	results CSV / receipt telemetry	your protocol
Changed lines before payment	payments over $___ released after a changed line was reviewed ÷ payments with a changed line	AP log + ENTITY_STATE_DELTA events	your protocol

Records

Record	Kept by	Retention
Vendor master (roster)	Supply Chain	per HOSP-08
Pre-contract receipt in contract file	Contracting	contract life + per HOSP-08
Monthly receipts + review log	Compliance	per HOSP-08

What this procedure does not decide

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.

Change log

Date	Change
2026-10-06	First issue.
date	adopted / edited by name

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