Page 10 - AASBO EDGE Winter 2023

PROCUREMENT

BY BILL MUNCH, CPPO, CPPB
How to Comply with Suspension and Debarment

Status Verification When Spending Federal Dollars
Bill Munch

It's January 11, 2023, and lucky me – I am serving Non-federal entities (including school districts) are
jury duty for the city of Tempe. As I anxiously await prohibited from contracting with or making sub-
to be called to perform my civic responsibilities, awards under covered transactions to parties that
what better time to work on another article for the are suspended or debarred. "Covered transactions"
World-Renowned AASBO Edge? Thank goodness include contracts for goods and services awarded
for Android! under a non-procurement transaction (e.g., grant or
cooperative agreement) that are expected to equal
Last month, the following information was sent out or exceed $25,000 or meet certain other criteria
via the NIGP National email listserv. NIGP (The as specified in 2 CFR section 180.220. All non-
Institute for Public Procurement) is an association procurement transactions entered into by a pass-
made up of public procurement professionals through entity (i.e., AZ Department of is generally
across the United States and Canada. Arizona is the pass-through entity), irrespective of award
lucky enough to have two chapters; one in Phoenix amount, are considered covered transactions,
and one in Tucson. You can reach each chapter unless they are exempt as provided in 2 CFR
at www.aznigp.org and www.copperchapter.org section 180.215.
respectively.
When a non-federal entity enters into a covered
This little article is just a reminder there are other transaction with an entity at a lower tier, the
options to sam.gov <http://sam.gov> for verifying non-federal entity must verify that the entity, as
debarment status. Every procurement stands on its defined in 2 CFR section 180.995 and agency
own. Use the method that is more efficient for each adopting regulations, is not suspended or debarred
particular purchase. While this information is most or otherwise excluded from participating in the
critical for school districts, our vendors should be transaction. This verification may be accomplished
keenly aware of this requirement when districts are by:
spending federal dollars.
1. Checking the System for Award
There are definitive federal requirements for Management (SAM) Exclusions maintained
verification of suspension and debarment status of by the General Services Administration
vendors that districts wish to award contracts. (GSA) and available at: www.sam.org
(click on Search Record, then click on Advanced
2 CFR Part 200 is pretty clear on what the Search Exclusions) (Note: The OMB guidance
requirement is for non-federal entities such as at 2 CFR Part 180 and agency implementing
school districts. Collecting a self-certification from regulations still refer to the SAM Exclusions
the vendor is explicitly authorized. as the Excluded Parties List System (EPLS)).

CONTINUED ON PAGE 12

|
10 THE EDGE WINTER 2022-2023