Suspension and Debarment Checks in SAM.gov: How to Document the Exclusion Check

A search that happened but left no record

A finance manager at a grant-funded nonprofit is three weeks from a monitoring visit. The monitor has pulled a contract for IT services and asks one question about the vendor: was it excluded from federal awards on the day the organization signed? The manager remembers searching SAM.gov before the award. She cannot find a saved page, a date, or a note saying who ran the search.

The search itself probably happened. What is missing is proof of when it happened and what it returned. Without that, the monitor has only her recollection, and a recollection is a weak record when a funder is deciding whether to question a cost. She can rerun the search today, but a result from today says nothing about the day of award.

This is the usual gap with exclusion checks. They take a few minutes to run and are easy to leave undocumented, especially when the same person is also chairing the committee and drafting the award memo. The fix is not more work. It is a small, consistent entry that gets made at the right moment.

After reading, you will be able to show, for any award, when the exclusion check was run, who ran it and what it found.

Where the suspension and debarment check in SAM.gov for a nonprofit comes from

The government-wide suspension and debarment rules sit in 2 CFR Part 180. Under 2 CFR 200.214, recipients and subrecipients are subject to those rules, which restrict making federal awards, subawards and contracts with parties that are debarred, suspended or otherwise excluded. Appendix II to Part 200 adds that a contract award (see 2 CFR 180.220) must not be made to parties listed on the governmentwide exclusions in the System for Award Management (SAM). eCFR, where you can read both, describes itself as authoritative but unofficial; the official edition is the annual CFR on govinfo.gov.

Part 180 describes more than one way to verify a party's status. Under 2 CFR 180.300, before entering into a covered transaction at the next lower tier, you verify that the other party is not excluded or disqualified by checking SAM.gov Exclusions, collecting a certification from that party, or adding a clause or condition to the transaction. Awarding agencies may set their own expectations, so ask your awarding agency or pass-through entity which method it accepts and whether it wants a particular format. A dated SAM.gov search is the easiest of the three to show later.

The rules also move. OMB's revision of the Uniform Guidance took effect October 1, 2024 (89 FR 30046); check your award terms for the version that applies to your award. On May 29, 2026, OMB published a proposed rule (91 FR 32198) that would revise 2 CFR Part 200 again. As of October 2026 the Federal Register shows no final rule, so confirm current status before you rewrite any procedure. Record in each file which version of the rules you followed, because a file that does not say so cannot show which rule it followed at the time.

When to run the exclusion check

The check belongs after evaluation has produced a ranking and before the award decision is final. Run it earlier and the result may be stale by signing. Run it after signing and the organization may already be committed to a party it should not have selected. Either way, the file should show the date and time of the search in relation to the award decision, because 2 CFR 200.318(i) asks for records detailed enough to show the history of each procurement.

Some situations call for a second look. A long gap between ranking and signing, a contract modification or an option exercise can all change the facts. Whether your awarding agency expects a repeat check at those points is a question for the agency or pass-through entity. Ask, then write the answer into your procedures.

Know where the dollar line sits. Under 2 CFR 180.220(b)(1), a contract awarded by a participant in a covered nonprocurement transaction, such as a grant, is itself a covered transaction when "the contract amount is expected to equal or exceed $25,000" (2 CFR 180.220(b)(1), eCFR current text). A contract that requires the consent of a federal agency official, or one for federally required audit services, is covered at any amount. Below $25,000, award terms, agency rules or your own policy may still ask for a check, so confirm with the agency. Running and recording the search anyway costs little.

What to record in the file

A saved page with no context is better than nothing, but a short structured entry is stronger. For each vendor in contention for award, record:

• the vendor's legal name as it appears in the proposal and as you entered it in the search;
• any identifier you used, such as a UEI, if the vendor supplied one;
• the date and time of the search, and the name and title of the person who ran it;
• the source searched, which is the SAM.gov exclusion records;
• the result, including a plain "no matching record" when that is what you found;
• a saved copy of the results page, with the date in the file name;
• the procurement identifier the check belongs to; and
• what you did if a result looked like a match, and whom you consulted.

Name variants matter. Vendors operate under trade names, parent names and legacy names, so note the variants you tried. A "no match" on a single spelling is thin evidence.

If a result does appear, pause the award decision and resolve it with your awarding agency or counsel. Keep that correspondence in the same file, so the record shows both the hit and how it was handled.

How the check fits a responsibility review under 2 CFR 200.318

Under 2 CFR 200.318(h), the recipient or subrecipient must award contracts only to responsible contractors that possess the ability to perform successfully, and must consider contractor integrity, public policy compliance, proper classification of employees, past performance record, and financial and technical resources. Exclusion status is one input to that judgment, not the whole of it. A vendor can be absent from the exclusion records and still lack the capacity, history or resources your solicitation called for. The difference between a proposal that is responsive and a vendor that is responsible is covered in responsive vs. responsible bidder.

Your written procedures, which 2 CFR 200.318(a) requires, should say what a responsibility determination looks at beyond exclusion status. The file should then hold a short written determination for the selected vendor that lists each item reviewed and the finding. A paragraph per item is enough. The point is that a reader can see what was checked, in what order, and by whom.

Keep the conflict-of-interest question separate. Under 2 CFR 200.318(c), no employee, officer, agent or board member with a real or apparent conflict may take part in selection or award. That is a check on your own people, not on the vendor. The wider set of standards is summarized in Uniform Guidance procurement standards for nonprofits.

Subrecipients and pass-through entities

Where a nonprofit passes award money to subrecipients, two checks can be in play. One concerns the status of the subrecipient itself. The other concerns the vendors the subrecipient later selects with that money.

Under 2 CFR 200.332, a pass-through entity must verify that the subrecipient is not excluded or disqualified in accordance with 2 CFR 180.300 (paragraph (a)), and must evaluate each subrecipient's fraud risk and risk of noncompliance to decide how to monitor it (paragraph (c)). How a pass-through reviews a subrecipient's procurement, and what evidence it wants to see, can vary. Ask early rather than at the monitoring visit. Subrecipient procurement monitoring shows how that review can be organized.

Keeping the record where a monitor can find it

Under 2 CFR 200.318(i), the file must show four things: the rationale for the procurement method, the contract type selection, contractor selection or rejection, and the basis for the contract price. The exclusion check supports the contractor-selection element. A one-page checklist of everything else a file should hold is in the procurement file documentation checklist.

Under 2 CFR 200.318(k), the recipient or subrecipient is responsible for the settlement of all contractual and administrative issues arising out of its procurement transactions:

"These issues include, but are not limited to, source evaluation, protests, disputes, and claims."

That makes your own record the thing you rely on. Retention under 2 CFR 200.334 is three years from the final financial report unless an exception applies, such as a written notice extending the period. Local public-records rules may require longer.

Where noncompliance cannot be remedied by specific conditions, the remedies under 2 CFR 200.339 include temporarily withholding payments, disallowing costs, suspending or terminating an award, and initiating suspension or debarment proceedings. See single audit procurement findings for how these findings arise.

Setting up a repeatable exclusion record

Four decisions turn a habit into a record. Set the timing rule, name who runs the check, use one entry format, and save the result in the procurement folder. Tie the entry to the date of the award memo so the sequence is visible to anyone reading the file later.

RFPManagement is built to hold a per-proposal responsiveness checklist, a human-entered award decision, and an append-only, hash-chained audit trail, with export of the full evaluation file. It does not query SAM.gov. Staff run the search and enter the result.

The Vendor Responsibility Review Log is a store workbook designed to record, for each vendor, the date and time of the exclusion check, who ran it, what it returned and the other responsibility items reviewed. It is available in the store now, and it records what you enter without connecting to SAM.gov. You can read about it on the Vendor Responsibility Review Log page.

RFPManagement records and computes. It does not give legal or procurement advice. The award decision stays with your organization.