Federal Debarment, Suspension, and Exclusion Screening
The federal government maintains a list of restricted parties in the System for Award Management (“SAM”) (www.SAM.gov), comprised of individuals and entities who are ineligible to receive federal funds due to debarment, suspension, or exclusion proceedings. Federal regulations (e.g., 2 CFR 180, “OMB Guidelines to Agencies on Governmentwide Debarment and Suspension”) expressly prohibit the use of federal funds to support or reimburse debarred, suspended, or excluded individuals. In order to comply with the federal requirements, Boston University screens our employees and students receiving funds from federal grants, cooperative agreements and contracts against the SAM list to ensure that the University remains compliant with excluded parties grant and contract obligations.
The University also screens against other publicly available list as required by law and relevant to a University member’s specific job duties.
What is exclusion screening?
Exclusion screening is Boston University’s process of verifying that current employees and students receiving funds from federal grants, cooperative agreements and contracts are not classified as excluded, suspended, or debarred by a federal agency.
What does it mean to be an excluded, suspended, or debarred individual?
An excluded individual is someone prohibited from receiving funds from federal grants, cooperative agreements and contracts, and certain types of federal financial and non-financial assistance and benefits.
A suspended individual is someone excluded for a temporary period of time pending debarment proceedings on suspected criminal, fraudulent, or otherwise improper conduct.
A debarred individual is someone excluded for a specified period of time or indefinitely after debarment proceedings found the individual engaged in criminal, fraudulent, or otherwise improper conduct.
There are many reasons that may lead to an individual ending up on the SAM list. These reasons range from fraud and tax evasion convictions to student loan defaults. Exclusions more commonly occur due to convictions, civil judgments, or pending charges for the following offenses:
- Commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public transaction, contract, or subcontract;
- Violation of federal or state antitrust statutes; and
- Commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property.
Why does the University conduct exclusion screening against the SAM list?
Boston University screens our employees and students receiving funds from federal grants, cooperative agreements and contracts against the SAM list to ensure that the University remains compliant with federal regulations (e.g., 2 CFR 180, “OMB Guidelines to Agencies on Governmentwide Debarment and Suspension”) that expressly prohibit federal funds from supporting or reimbursing debarred, suspended, or excluded individuals.
How does the University screen against the SAM list?
The University uses a third-party vendor to conduct exclusion checks on its behalf. The vendor checks the SAM list for the names of the applicable employees or students to ensure that they are not excluded, debarred or suspended.
Why is the University asking me about a potential positive hit?
The University may reach out about a positive hit in the exclusion screening process to confirm whether or not you are the person listed on the SAM list. If you are not the person whose name appears on the SAM list, you will be asked to sign a certification.
What will happen if the screening reveals that I am an excluded, suspended, or debarred individual?
Upon the rare confirmation that an employee or student is an excluded, debarred or suspended individual, federal funding to such individual will immediately be suspended. The individual will be notified and given the opportunity to provide additional information. The Associate Provost of Research or their designee(s) will review and recommend additional steps, if any, concerning the individual’s role at the University, reason for exclusion, and any other relevant information. In the case of employees, the University may take additional employment action up to and including termination of employment.
Who should I contact for questions?
For more questions on exclusion screening, please contact Sponsored Programs at ospera@bu.edu or 617-353-4365.
In instances where individual confirms they are not the named person in the SAM list, the Individual Certification: GSA SAM Exclusion form must be completed and submitted to spfedscr@bu.edu.