A hospital or health system 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: Section 3 asks the applicant to list exclusions, debarments, revocations and license suspensions; 42 CFR 424.516 requires reporting changes within 30 days; 42 CFR 424.535 lists revocation grounds.

Citation: 42 CFR 424.516; 42 CFR 424.535; 42 CFR 1001.1901

Duty Sheet: 42 CFR 455.436 — Federal database checks (Medicaid provider screening); HHS-OIG General Compliance Program Guidance — exclusion screening of employees, medical staff and vendors

• Step 2: The state agency checks the provider and every disclosed person against the OIG LEIE and SAM Exclusions at enrollment and re-enrollment. — 42 CFR 455.436(b)
• Step 3: The state agency repeats the LEIE and SAM check monthly. — 42 CFR 455.436(c)(2)
• Step 4: No federal program payment for items or services furnished, ordered or prescribed by an excluded person; providers check their own staff and contractors. — 42 CFR 1001.1901(b); 42 CFR 438.610; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)
• Step 5: Managed care plans screen and the state enrolls network providers; plans report excluded or terminated providers. — 42 CFR 438.608(b)–(c)

• 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: 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: State Medicaid exclusion / termination lists · oig.hhs.gov/exclusions/state-exclusion-lists/ — held copy, re-fetched on the cadence shown; SHA-256 of the file as served
• Record: CMS NPPES NPI Registry · npiregistry.cms.hhs.gov — live lookup at request time; 'did not answer' when the endpoint does not respond

What a read cannot prove: Identity (a name match is a candidate); whether a disclosure was owed; the outcome of enrollment.

The line: 455.436(b)–(c): the state agency checks the LEIE and SAM exclusions at enrollment, re-enrollment and monthly thereafter; 455.104–106: the provider discloses owners, managing employees and convictions on the state's form.

Citation: 42 CFR 455.436; 42 CFR 455.104–455.106

Duty Sheet: 42 CFR 455.436 — Federal database checks (State Medicaid agency side); 42 CFR 455.436 — Federal database checks (Medicaid provider screening)

• Step 2: The state agency checks the provider and every disclosed person against the OIG LEIE and SAM Exclusions at enrollment and re-enrollment. — 42 CFR 455.436(b)
• Step 3: The state agency repeats the LEIE and SAM check monthly. — 42 CFR 455.436(c)(2)
• Step 4: No federal program payment for items or services furnished, ordered or prescribed by an excluded person; providers check their own staff and contractors. — 42 CFR 1001.1901(b); 42 CFR 438.610; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)
• Step 5: Managed care plans screen and the state enrolls network providers; plans report excluded or terminated providers. — 42 CFR 438.608(b)–(c)

• 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: 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: State Medicaid exclusion / termination lists · oig.hhs.gov/exclusions/state-exclusion-lists/ — held copy, re-fetched on the cadence shown; SHA-256 of the file as served

What a read cannot prove: Enrollment status; that disclosed owners were screened; identity behind a name match.

The line: The sponsor's compliance program must screen employees, governing body and FDRs against the OIG LEIE and SAM before hire or contract and monthly thereafter; attested annually in HPMS.

Citation: 42 CFR 422.503(b)(4)(vi)(F); 42 CFR 423.504(b)(4)(vi)(F)

Duty Sheet: CMS Medicare Advantage / Part D compliance program — first-tier, downstream and related entity (FDR) exclusion screening

• Step 2: The state agency checks the provider and every disclosed person against the OIG LEIE and SAM Exclusions at enrollment and re-enrollment. — 42 CFR 455.436(b)
• Step 3: The state agency repeats the LEIE and SAM check monthly. — 42 CFR 455.436(c)(2)
• Step 4: No federal program payment for items or services furnished, ordered or prescribed by an excluded person; providers check their own staff and contractors. — 42 CFR 1001.1901(b); 42 CFR 438.610; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)
• Step 5: Managed care plans screen and the state enrolls network providers; plans report excluded or terminated providers. — 42 CFR 438.608(b)–(c)

• 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: 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 compliance program is effective; CMS audit outcome.

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.