Understanding the Watch List System for Award Management Exclusions
The General Services Administration (GSA) is the federal government’s main procurement agency. Through the GSA, federal government agencies purchase goods and services from vendors. For example, the federal Department of Defense (DoD) uses the GSA to procure and acquire equipment, supplies, telecommunications, and integrated information technology solutions from vendors. The DoD then uses these goods and services.
Prospective federal contractors must register with the GSA before they can do business with the federal government. Registration with the GSA System for Award Management (GSA SAM) is required for an entity to bid on and get paid for federal contracts, or to receive an award of federal funds for a public purpose. “Entities” include for-profit businesses, nonprofits, government contractors, government subcontractors, state governments, and local municipalities.
What Are Award Exclusions?
The General Services Administration (GSA) suspends or debars contractors from doing business with the government for a variety of reasons. These activities may include (among others):
- Fraud, theft, bribery, or embezzlement.
- Violation of the terms of the federal contract, or poor contract performance.
- Financial misconduct
- Failing to report overpayments.
Entities suspended, debarred, or proposed for debarment appear in the “Exclusions” database in the System for Award Management (SAM).
What is the System for Award Management (SAM) Exclusion List?
The GSA maintains a System for Award Management (SAM) exclusion database, or list. The list contains the names of individuals and entities that have been excluded, and that are therefore may be ineligible for federal contracts, grants, loans, subcontracts, and other assistance programs.
Can My Organization Do Business With an Entity on the System for Award Management (SAM) Exclusion List?
Generally, a federal contractor may not enter into a covered transaction (transaction in which an excluded person provides goods or services to the federal contractor) with an excluded person. A federal contractor ensures that it is not entering into a covered transaction with an excluded person by checking the award management exclusion list to see if the excluded person appears on the list. If the excluded person appears on the list, the federal contractor generally may not enter into the contemplated transaction.
Federal contractors who are not on the list who hire individuals or entities on the list, are subject to loss of federal funding through programs such as Medicare and Medicaid. Health plans and providers should screen individuals whom they employ or do business with, against the GSA SAM Exclusion List, to ensure that these individuals have not been suspended or debarred from conducting business with the federal government.
What If an Employee or Vendor Is on the System for Award Management Exclusion List?
If you check the GSA SAM Exclusion List and discover that an employee or vendor is on the list, you should verify that the name that appears on the list is in fact the name of the employee of vendor, by confirming that the person or entity’s information, as it appears on the list, matches the information you have on that person or entity.
Accessing the Award Management Exclusion List
You can access the system award management exclusion list for free at SAM.gov. This website contains exclusion list data for various entities. . While searching the list, you can narrow your search by exclusion classification (e.g., individual, entity),organization, location, and other parameters. While you don’t need to set up an account to view the list, you must register your entity if you enter into federal contracts or receive benefits from federal programs.
Searching the government’s list can be cumbersome and time-consuming. .Compliancy Group’s software, The Guard, contains a built-in Exclusion Module that allows youto automatically conduct GSA SAM Exclusion List (award management exclusion list) checks. The Guard also allows you to conduct LEIE OIG Exclusion list checks and state exclusion list checks – all in one convenient module. You can also use The Guard to ensure that your personnel obtain necessary compliance training.
Your organization’s having knowledge of who is on the GSA SAM Exclusion List (award management exclusion list), and then taking appropriate action, are crucial components of your compliance program. Contact Compliancy Group today for more information on our software and other resources that can support your compliance efforts.
