Recipients of federal funding have long been required to screen contractors and subrecipients for suspension or debarment; however, some requirements are open to interpretation and can create more work than required.

• Who needs to be screened?
• How often?
• And what kind of documentation is required?

In this week’s tip, I’ll clarify SAM.gov screening requirements and provide practical advice to make it easier for you to stay compliant.

What is the Suspended and Debarred List?

The federal government maintains a list of organizations and individuals prohibited from receiving federal contracts or assistance—this is the suspended and debarred list.

Recipents and subrecipients are required to check this list to ensure monies aren't spent with parties that have previously violated significant terms or demonstrated a lack of business integrity.

The list is maintained at SAM.gov.

Who Needs to be Screened?

Any contractor or subrecipient who will be paid $25,000 or more with federal funds is required to be screened against the SAM.gov database.

Those are the baseline requirements; however, some organizations take it a step further and opt to screen all federally funded contractors and subrecipients whenever a contract is executed, regardless of dollar amount.

While these additional screens are not required by regulation, these organizations choose to perform them to provide more consistency and reduce the risk of working with an entity on the government's 'naughty list.'

How Often to Screen?

This is the big question.

The UG doesn't specify a set frequency for screening contractors and subrecipients after a contract has been awarded. However, it does imply that organizations have an ongoing responsibility for ensuring they are not working with third parties who are suspended or debarred.

That means you get to decide the frequency of your screens. Two factors you'll want to consider are: your organization’s risk appetite for working with a third-party on the naughty list, and expectations from your auditors?

In my work with many nonprofits (and auditors) over the years, here is where I've found they both tend to settle.

• At Least Annually for Ongoing Contracts or Subawards: If the contract or subaward will extend over multiple years, an annual screen would ensure the contractor or subrecipient’s status has not changed. Higher-risk contracts may warrant a more frequent screen, such as quarterly.
• Before Any Significant Modifications: If there are significant changes to the contract or subaward—such as an extension, increase in funding, or change in the scope of work— it's prudent to conduct a re-screening to confirm that the entity is still in good standing.
• When There Is a Change in Ownership: If there is a change in the contractor’s or subrecipient’s ownership, re-screening is essential to ensure the new ownership group is not suspended or debarred.

What Should You Document?

You’re required to maintain evidence that the screening was performed, typically in the form of a printout or digital copy of the search results from SAM.gov. You should retain the documentation in compliance with record retention requirements, and have it ready for review if requested by auditors or federal agencies.

Alternatively, you can automate the screening process through software like VendorRisk.

Platforms like VendorRisk automatically perform screens, alert you when there is a match, and provide an audit log (eliminating the need for screenshots or printouts). They are big-time savers when you have many contractors and subrecipients to screen and monitor.

Final Thoughts

Screening contractors and subrecipients for suspension or debarment can be an efficient process when you leverage technology and have clear guidelines for who needs to be screened, how often, and what documentation to maintain.

Whether you choose to screen only for contracts over $25,000 or take a more conservative approach by screening all contracts, the key is to establish a consistent process that aligns with your organization’s risk tolerance and audit expectations.