Background

Suspension and debarment are actions taken by the federal government against organizations or individuals who have committed fraud or a criminal offense in violation of federal law. The federal government prohibits expending federal funds or goods and/or services from any entity suspended or debarred from doing business with the federal government.

Purpose

The purpose of this policy is to ensure that grant-related purchases are not made from an entity that has been suspended or debarred by the federal government.

Definitions

Suspension: A disqualification from federal procurement transactions for a temporary period, pending debarment proceedings.

Debarment: An exclusion from federal procurement transactions.

EPLS: All individuals and entities suspended or debarred are listed on the U.S. General Services Administration (GSA) Excluded Parties Listing System (EPLS). The search can be performed at www.sam.gov.

Policy

In accordance with Uniform Guidance 2 CFR 200.214, it is the policy of Davidson College to check procurement contracts for goods and services awarded under a nonprocurement transaction (e.g. grant or cooperative agreement) that are expected to equal or exceed $25,000, for debarment or suspension of the entity and its principals.

Procedure

  1. Pre-purchase – Prior to making a grant-related purchase that is expected to equal or exceed $25,000, the Principal Investigator (PI) must contact the Grants Accountant who will check the selected vendor on www.sam.gov prior to approving, in writing, the creation of a Capital Purchase Authorization form. The Grants Accountant will document the Suspension and Debarment verification by including a screen print of the Exclusions search in the grant file.
  2. Capital Purchase Authorization – The Director of Grants and Contracts must be included in the approval hierarchy for all grant-related purchases. Prior to approving the purchases, the Director will verify and document, on the form, that the vendor has been checked on www.sam.gov for Suspension and Debarment.
  3. Bi-annual check – Twice a year, the Grants Accountant will run a list of all vendors and employees paid from federal funds. This list will be reviewed against the EPLS as a double check to ensure no federal funds have been paid to excluded parties. The Office of Grants and Contracts will maintain documentation of this semiannual check.
  4. Training – The Office of Grants and Contracts sets up a post-award meeting with every faculty member (PI) awarded an external grant. As part of the training received by faculty awarded federal grants, the post-award meeting will include a detailed review of all post-award financial management policies and procedures, including the Suspension and Debarment Policy and Procedure. The PI will subsequently sign a form accepting responsibility for compliance with the post-award financial management policies and procedures. The signed form will be maintained in the grant project file.

Administration of Policy

The Director of Grants and Contracts shall oversee this policy and shall review it at least once every two years.  Changes to this policy shall be made in accordance with the college’s Policy on Policies.

Related Policies

Procurement Policy

Subrecipient Monitoring Policy

Grant-Related Expenditure Approval and Monitoring Procedure

Unallowable Costs Policy

Adopted: April 19, 2021

Last Reviewed: April 21, 2021