Month: March 2015

SAM.gov Exclusions – What Are They, and Where do They Come From?

SAM.gov publishes an exclusion file used by many organizations for screening and/or compliance purposes. This exclusion file replaces the former EPLS files as of November, 2012. The SAM exclusion file receives regular updates and contains the collective exclusion reporting of over 80 different federal agencies totaling to approximately 130,000 exclusion records. An exclusion record from SAM.gov indicates that the individual or organization listed is disqualified from receiving any federal government contracts. S.A.M. stands for System for Award Management. This system is used for any party seeking to be awarded a federal government contract and become a federal vendor or supplier.

Let’s take a look at the break-down of the SAM.gov exclusions to see where most of the information comes from. As seen in the chart below, almost 1/2 of the SAM.gov exclusion records come from the Department of Health and Human Services’ OIG LEIE exclusion list. The top 6 contributors to the SAM.gov file makeup over 90% of its total records. The chart below only shows the top 27 federal agencies that report to SAM, there are many more which have made small record contributions.

Each agency that reports to the SAM exclusion system is responsible for the accuracy of its records and the information they contain. Exclusions records have a “type” and a “termination date”. The types are generally “Prohibition/Restriction” or “Ineligible”. In some cases the type may indicate “Proceedings Pending” or “Proceedings Completed”. These types give a little insight into the status of the investigation resulting in exclusion. The termination date in the record indicates the shelf-life of the exclusion. In some cases, a future date is present. This means that once that date is reached, the party on record is no longer excluded. In many cases, the word “Indefinite” is seen in the termination date. An indefinite exclusion never expires and can only be removed at the digression of the reporting agency. If specific conditions or criteria are met, the excluding agency may remove the exclusion. SAM does not publish a reinstatement list, non-excluded parties are simply removed from the updated file. Some reporting agencies (such as the OIG) do maintain their own reinstatement lists.

 

SAM Pie3

TyphoonDATA offers data and compliance solutions that include the SAM.gov exclusions file and much more.

To speak with TyphoonDATA directly, please contact:

Richard Rupert, VP Compliance Solutions
Office: 800.780.5901 extension 705
rrupert@typhoondata.com