System for Award Management Exclusions

The System for Award Management Exclusions is the authoritative federal database of entities -- companies, individuals, vessels, and other parties -- that are currently prohibited from receiving federal contracts, grants, loans, and other federal financial assistance. It is maintained within SAM.gov and consolidates what was previously the Excluded Parties List System (EPLS). Contracting officers, grant officers, and prime contractors are required to check the SAM Exclusions database before making awards or certain subcontract and subgrant decisions.

What are SAM Exclusions?

SAM Exclusions is the public-facing component of the government-wide exclusions management system. When a federal agency's Suspending and Debarring Official (SDO) imposes a suspension or debarment, the SDO's administrative office enters the record into SAM.gov. The record becomes immediately visible to the public and to all federal agencies. Under FAR 9.405, contracting officers are prohibited from soliciting offers from, awarding contracts to, or consenting to subcontracts with excluded entities.

Each exclusions record includes the entity's name, Unique Entity Identifier (UEI) or CAGE code, the imposing agency, the exclusion type (suspension, debarment, proposed debarment, or ineligibility), the effective date, the termination date (if any), and a description of the exclusion cause. Exclusion records for debarred entities typically remain visible in SAM.gov for a defined period after expiration to support historical review by contracting officers conducting responsibility determinations.

Non-procurement exclusions -- covering grants, loans, and federal assistance programs administered under 2 CFR Part 180 -- are also recorded in SAM Exclusions. This means an entity excluded from federal assistance is excluded government-wide across both procurement and non-procurement programs unless the excluding agency explicitly limits the scope of the exclusion.

Why it matters for contractors

Prime contractors are required under FAR 52.209-6 to verify that prospective subcontractors are not excluded before awarding subcontracts valued above the simplified acquisition threshold (currently $50,000). Failure to check -- and awarding a subcontract to an excluded party -- is a contract compliance violation that can trigger cure notices, termination for default, and potential debarment of the prime contractor itself.

Contractors should also monitor their own SAM.gov status. A company that receives a Notice of Proposed Debarment has the right to respond and contest the action within 30 days under FAR 9.406-3. Missing that window, or being unaware that a proposed debarment record has appeared in SAM.gov, forfeits that opportunity. Periodic self-checks are a basic compliance hygiene measure.

Beyond procurement, many state and local governments and international organizations also query the SAM Exclusions database before awarding contracts or assistance, extending the practical impact of an exclusion well beyond the federal market.

Example

A prime contractor on a federal IT services contract needs to bring on a specialized subcontractor for a network infrastructure task. Before signing the subcontract, the program manager queries SAM.gov Exclusions using the subcontractor's legal name and UEI. The query returns an active debarment record imposed by the Department of Transportation six months earlier. The prime contractor cannot use that subcontractor under the federal prime contract and must identify an alternative. The check -- which takes under two minutes -- prevents a contract compliance violation that could have jeopardized the prime contract itself.