A county or city pass-through entity in Pennsylvania

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)

Duty Sheet: 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements); Single Audit — Compliance Supplement Part 3 §I, Procurement and Suspension and Debarment (auditor's test)

• 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

• Record: SAM.gov Exclusions — Public Extract V2 · 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.

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

Duty Sheet: 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements)

• 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

• Record: SAM.gov Exclusions — Public Extract V2 · sam.gov/search/?index=ex — held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• Record: Federal Audit Clearinghouse (single audits) · 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).

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

Duty Sheet: Single Audit — Compliance Supplement Part 3 §I, Procurement and Suspension and Debarment (auditor's test); 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements)

• 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

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

The line: The prospective lower-tier participant certifies it is not presently debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded. Used with CDBG, HOME and ESG subrecipients and contractors; CDBG records in 24 CFR 570.506.

Citation: 2 CFR 2424 (HUD adoption of 2 CFR 180); 24 CFR 570.506

Duty Sheet: Accounts payable — the exclusion and sanctions record at the moment of payment (42 CFR 1001.1901; 2 CFR 200.214 / 180.300; 31 CFR Part 501; FAR 9.405-2); Payment Integrity Information Act (31 U.S.C. 3351–3358; OMB M-21-19) — pre-payment eligibility record for federal and federally funded disbursements

• 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

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

What a read cannot prove: That the certification is true; allowability of the cost.

The line: §XI.1 first-tier participants and §XI.2 lower-tier participants certify as to debarment and suspension (2 CFR 1200 / 180); §IV requires weekly certified payrolls from every contractor and subcontractor.

Citation: 23 CFR 633 subpart A; 2 CFR 1200; 23 CFR 635.117; 29 CFR 5.5

Duty Sheet: 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements)

• Step 2: Do not award to a person or firm on the WHD ineligible (debarred) list; check SAM Exclusions as well where federal funds flow. — 29 CFR 5.12(a)(1); 2 CFR 180.300; FHWA-1273 §XI

• Record: SAM.gov Exclusions — Public Extract V2 · sam.gov/search/?index=ex — held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• Record: DOL Wage & Hour enforcement cases (Davis-Bacon, SCA, CWHSSA) · enforcedata.dol.gov/views/data_summary.php — live, needs a free DOL key
• Record: DOL Davis-Bacon / Service Contract Act debarment list · www.dol.gov/agencies/whd/government-contracts/debarment — not read by this platform (site refuses automated reads) — go to the official page
• Record: OSHA Severe Violator Enforcement Program log · www.osha.gov/enforcement/svep/svep-log — not read by this platform (site refuses automated reads) — go to the official page

What a read cannot prove: Prequalification; wage accuracy; that a same-named DOL row is the same company.

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)

Duty Sheet: 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements)

• 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

• Record: USAspending subawards (prime-to-sub money flow) by exact sub-awardee name · 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.

The line: A.3(ii) weekly certified payrolls; A.11 subcontracts (the contractor is responsible for compliance by any subcontractor); 29 CFR 5.12 ineligible contractors.

Citation: HUD-4010; 29 CFR 5.5; 29 CFR 5.12; 24 CFR 70

Duty Sheet: none yet for this line

• Step 2: Do not award to a person or firm on the WHD ineligible (debarred) list; check SAM Exclusions as well where federal funds flow. — 29 CFR 5.12(a)(1); 2 CFR 180.300; FHWA-1273 §XI

• Record: DOL Wage & Hour enforcement cases (Davis-Bacon, SCA, CWHSSA) · enforcedata.dol.gov/views/data_summary.php — live, needs a free DOL key
• Record: DOL Davis-Bacon / Service Contract Act debarment list · www.dol.gov/agencies/whd/government-contracts/debarment — not read by this platform (site refuses automated reads) — go to the official page
• Record: SAM.gov Exclusions — Public Extract V2 · 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: Payroll accuracy; that a same-named row is this contractor.

The line: Category 01 'Certifications and Assurances Required of Every Applicant' includes the applicant's assurance that it will comply with 2 CFR 1200 / 2 CFR 180 on suspension and debarment for every third-party contract and subrecipient.

Citation: 2 CFR 1200; 2 CFR 180.300; 49 U.S.C. 5323

Duty Sheet: 2 CFR 200.214 / 2 CFR 180.300 — Suspension and debarment (federal grants and cooperative agreements); Single Audit — Compliance Supplement Part 3 §I, Procurement and Suspension and Debarment (auditor's test)

• 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

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

What a read cannot prove: Any other category of the certifications; procurement-system adequacy.