Government forms register · OMB (2 CFR)
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
Alpha Covenant Holdings, Government Forms Register: 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 (OMB (2 CFR)); citation 2 CFR 180.300; 2 CFR 200.214; 2 CFR 200.318(h); read 2026-10-08. https://alphacovenantholdings.com/forms/two-cfr-180-300
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Suspension and debarment check for federal awards (2 CFR 180 / 200) — the steps as written
● a dated receipt is the record at this step · printable
| # | 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 |
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.
Upstream — the rule as printed
2 CFR 180.300 — § 180.300 What must I do before I enter into a covered transaction with another person at the next lower tier? · as of 2026-10-20 · last amended 2024-10-01
When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.
Amended: 2016-11-28, 2024-10-01 · SHA-256 of the XML as served: 034cc836840a7ab4d66905457af08ac7b36c36f7e58abd2ac15377290c7e9ed9 · eCFR
The eCFR is an editorial compilation maintained by the Office of the Federal Register and GPO; it is updated daily and is not the official legal edition (the annual Code of Federal Regulations is). Text printed here is as the eCFR served it on the read date.
2 CFR 200.214 — § 200.214 Suspension and debarment. · as of 2026-10-20 · last amended 2024-10-01
Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards.
Amended: 2020-11-12, 2024-10-01 · SHA-256 of the XML as served: ab39be525f4724e000e3f464cf4c34235564d727da7ebc748e73a009edf426f3 · eCFR
The eCFR is an editorial compilation maintained by the Office of the Federal Register and GPO; it is updated daily and is not the official legal edition (the annual Code of Federal Regulations is). Text printed here is as the eCFR served it on the read date.
2 CFR 200.318 — § 200.318 General procurement standards. · as of 2026-10-20 · last amended 2024-10-01
(a) Documented procurement procedures. The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. (b) Oversight of contractors. Recipients and subrecipients must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. See also § 200.501(h). (c) Conflicts of interest. (1) The recipient or subrecipient must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, agent, or board member with a real or apparent conflict of interest may participate in the selection, award, or administration of a contract supported by the Federal award. A conflict of interest includes when the employee, officer, agent, or board member, any member of their immediate family, their partner, or an organization that employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from an entity considered for a contract. An employee, officer, agent, and board member of the recipient or subrecipient may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors. However, the recipient or subrecipient may set standards for situations where the financial interest is not substantial or a gift is an unsolicited item of nominal value. The recipient's or subrecipient's standards of conduct must also provide for disciplinary actions to be applied for violations by its employees, officers, agents, or board members. (2) If the recipient or subrecipient has a parent, affiliate, or subsidiary organization that is not a State, local government, or Indian Tribe, the recipient or subrecipient must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest mean that because of relationships with a parent company, affiliate, or subsidiary organization, the recipient or subrecipient is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. (d) Avoidance of unnecessary or duplicative items. The recipient's or subrecipient's procedures must avoid the acquisition of unnecessary or duplicative items. Consideration should be given to consolidating or breaking out procurements to obtain a more economical purchase. When appropriate, an analysis should be made between leasing and purchasing property or equipment to determine the most economical approach. (e) Procurement arrangements using strategic sourcing. When appropriate for the procurement or use of common or shared goods and services, recipients and subrecipients are encouraged to enter into State and local intergovernmental agreements or inter-entity agreements for procurement transactions. These or similar procurement arrangements using strategic sourcing may foster greater economy and efficiency. Documented procurement actions of this type (using strategic sourcing, shared services, and other similar procurement arrangements) will meet the competition requirements of this part. (f) Use of excess and surplus Federal property. The recipient or subrecipient is encouraged to use excess and surplus Federal property instead of purchasing new equipment and property when it is feasible and reduces project costs. (g) Use of value engineering clauses. When practical, the recipient or subrecipient is encouraged to use value engineering clauses in contracts for construction projects of sufficient size to offer reasonable opportunities for cost reductions. Value engineering means analyzing each contract item or task to ensure its essential function is provided at the overall lowest cost. (h) Responsible contractors. The recipient or subrecipient must award contracts only to responsible contractors that possess the ability to perform successfully under the terms and conditions of a proposed contract. The recipient or subrecipient must consider contractor integrity, public policy compliance, proper classification of employees (see the Fair Labor Standards Act, 29 U.S.C. 201, chapter 8), past performance record, and financial and technical resources when conducting a procurement transaction. See also § 200.214. (i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. (j) Time-and-materials type contracts. (1) The recipient or subrecipient may use a time-and-materials type contract only after a determination that no other contract is suitable and if the contract includes a ceiling price that the contractor exceeds at its own risk. Time-and-materials type contract means a contract whose cost to a recipient or subrecipient is the sum of: (i) The actual cost of materials; and (ii) Direct labor hours charged at fixed hourly rates that reflect wages, general and administrative expenses, and profit. (2) Because this formula generates an open-ended contract price, a time-and-materials contract provides no positive profit incentive to the contractor for cost control or labor efficiency. Therefore, each contract must set a ceiling price that the contractor exceeds at its own risk. Further, the recipient or subrecipient awarding such a contract must assert a high degree of oversight to obtain reasonable assurance that the contractor is using efficient methods and effective cost controls. (k) Settleme […] full text at the eCFR link
Amended: 2016-11-28, 2020-11-12, 2021-02-22, 2024-10-01 · SHA-256 of the XML as served: 353c584234f866a3883ac3e6a6c9bef0bf03e11d5164a7fb41799b0491dd2b38 · eCFR
The eCFR is an editorial compilation maintained by the Office of the Federal Register and GPO; it is updated daily and is not the official legal edition (the annual Code of Federal Regulations is). Text printed here is as the eCFR served it on the read date.
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