Exclusions in the System for Award Management
Agencies must promptly and accurately enter, update, and maintain exclusion records in SAM to prevent awards to debarred or ineligible entities.
Overview
FAR 9.404 outlines the requirements for managing and using exclusion records in the System for Award Management (SAM). The General Services Administration (GSA) operates SAM, which serves as the central repository for exclusion records, including debarments, suspensions, and other ineligibility actions. The regulation details the information that must be included in exclusion records, agency responsibilities for data entry and maintenance, and procedures to prevent contracting with excluded entities. Agencies must ensure timely and accurate updates to SAM, maintain internal records, and establish controls to avoid awarding contracts to excluded parties. The section also provides guidance on technical support and directs users to the SAM website.
Key Rules
- GSA Operation of SAM
- GSA manages SAM and provides technical support to agencies.
- Exclusion Record Content
- Exclusion records must include specific data such as names, addresses, cause, effect, termination date, and agency contact information.
- Agency Data Entry and Maintenance
- Agencies must assign responsible individuals, enter/update exclusion data promptly, and remove roles when staff change.
- Timeliness of Updates
- Exclusion information must be entered within 3 working days of action and updated within 5 working days of any changes.
- Internal Controls and Recordkeeping
- Agencies must maintain records and ensure procedures prevent contracting with excluded entities.
Responsibilities
- Contracting Officers: Must check SAM for exclusions before awarding contracts and avoid contracting with listed entities.
- Contractors: Must ensure they are not listed in SAM as excluded entities.
- Agencies: Must assign roles, maintain and update exclusion records, and establish procedures to prevent awards to excluded parties.
Practical Implications
- This section ensures government contracts are not awarded to entities that are debarred, suspended, or otherwise ineligible, protecting the integrity of federal procurement. Timely and accurate data entry in SAM is critical, and failure to comply can result in improper awards or administrative penalties. Agencies must have robust internal controls and clear assignment of responsibilities to maintain compliance.