The federal government and other sponsors expect the University to conduct business with responsible persons and organizations to protect the interests of the sponsor and to ensure the integrity of the programs supported. The Office of Management and Budget presents guidance on this matter to federal agencies and recipients of federal funds at 2 CFR Part 180; each agency’s specific policies and procedures pertaining to debarment and suspension are then issued in a regulation within its specific chapter of the Code of Federal Regulations (CFR).
When the Office of Sponsored Programs (OSP) submits proposals to sponsors, it certifies on behalf of the University that the proposal does not include persons or organizations debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from receiving financial assistance by any Federal department or agency. OSP certification is supported by the PI/PD’s attestation on the Internal Routing and Review Form.
The principal investigator/project director (PI/PD) is responsible for adherence to suspension and debarment regulations prior to proposal submission and during the life of the award. Departmental administrative staff and various University offices assist the PI/PD with the task of verifying eligibility. For example, OSP subscribes to a proprietary service to screen eligibility of SU employees, subcontractors or consultants named in an application or award, regardless of sponsor type. OSP will also screen any new award sponsors to confirm their “good standing” with federal agencies. Having been identified in this resource, the parties are scanned by the service daily; OSP is notified of any individual or entity whose status has changed, triggering further investigation and, if appropriate, action by the PI/PD.
During the life of the award, the PI/PD or his/her designee is responsible for ensuring the eligibility of individuals not named in the proposal who participate in a sponsored project [1]. Such individuals may be SU employees including graduate students, postdoctoral researchers, or technical personnel or non-SU personnel such as consultants. The PI/PD is also required to ensure the eligibility of vendors of goods or services that will cost $25,000 or more prior to the acquisition of goods or performance of services.
PI/PDs or their designee may use the System for Award Management (SAM) to verify that their staff, collaborators and vendors are not debarred, suspended or otherwise excluded from receiving federal funds. Copies of such checks should be available upon request. To support the PI/PD, OSP will also verify previously unnamed consultants or subrecipients upon request by the PI, designee or other University office. Documentation would be available upon request.
Responsibility for confirming eligibility of vendors for procurements greater than $24,999 is assigned to the Purchasing Office for acquisitions that use standard University procurement procedures. The Office of Sponsored Accounting will verify debarment/suspension screening with PI/PD for those procurements greater than $24,999 that do not use standard procedures (e.g. ‘confirming invoice attached’).