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2 CFR 200.214 — Suspension and debarment; 2 CFR 180.300 — What must I do before I enter into a covered transaction with another person at the next lower tier?

2 CFR 200.214 suspension and debarment checks for federal awards

180.300: 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 Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. source

Who it reaches

Every recipient and pass-through entity of federal financial assistance — universities, hospitals, counties, states, nonprofits — before each subaward and each procurement contract above the covered-transaction thresholds.

The record the rule expects

Method (a): the SAM Exclusions read by UEI with its extract date and read time, filed with the award record the Single Audit will sample (Compliance Supplement Part 3 §I). Beside it, dated: the subrecipient's Federal Audit Clearinghouse status and its USAspending award rows.

Questions readers ask

Which method should we use?

The regulation gives three; (a) is the one an auditor can re-perform. The receipt is the dated record of (a).

When does the auditor look?

Procurement, suspension and debarment is a compliance requirement tested in the Single Audit (2 CFR 200.501 threshold). The auditor samples transactions and asks for the verification performed before each.

This page quotes the rule and describes the record; whether your organization meets the rule is your compliance office's and counsel's reading. All rules · Methodology.

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