SAM.gov Debarment Explained: A Contractor Guide

Hiring a debarred subcontractor on a federal project can get your contract terminated and your company excluded from future federal work. Under FAR 9.405, federal agencies cannot award contracts to—or consent to subcontracts with—excluded contractors. Even on private projects, a SAM.gov exclusion signals serious misconduct: fraud, bribery, or criminal conduct that failed federal integrity standards. This guide explains what SAM.gov debarment means, how to search the exclusions database, and why every GC should check before hiring.

What is Federal Debarment?

Federal debarment is an official government action that prevents a contractor from doing business with the federal government for a specific period. The System for Award Management (SAM.gov) maintains the exclusions database—a publicly searchable list of all debarred, suspended, and excluded parties.

Under the Federal Acquisition Regulation (FAR) Subpart 9.4 (opens in new tab), debarred contractors are excluded from:

Receiving any federal contracts
Acting as a subcontractor on federal projects exceeding $45,000
Conducting business with the government as agents or representatives
Acting as individual sureties

Per FAR 9.405, agencies "shall not solicit offers from, award contracts to, or consent to subcontracts with" contractors who have an active exclusion record. This exclusion is governmentwide—once debarred by one agency, all federal agencies must honor that exclusion.

SAM.gov: The Official Exclusions Database

The General Services Administration (GSA) maintains SAM.gov, which replaced the former Excluded Parties List System (EPLS) in 2012. SAM.gov consolidates exclusion records from over 50 federal agencies including DOD, HHS, USDA, and others into a single searchable repository.

Anyone can search the exclusions database for free—no account required. This makes it easy for general contractors to verify subcontractors before awarding work.

Types of Exclusion

SAM.gov tracks four exclusion types, each with different implications for contractors:

Debarment

Under FAR 9.406, debarment is a final exclusion action typically lasting one to three years. It results from convictions, civil judgments, or agency evidence proving misconduct by a preponderance of the evidence. A debarment takes effect on the date the decision is finalized.

Suspension

Per FAR 9.407, suspension is a temporary exclusion imposed immediately when an agency has "adequate evidence" of misconduct pending investigation. Key points about suspension:

Takes effect immediately—no prior notice required
Cannot exceed 12 months if legal proceedings have not begun
May continue until conclusion of ongoing legal/debarment proceedings
Has the same effect as debarment while active

Proposed Debarment

A notice of proposed debarment under FAR immediately excludes the party while they have an opportunity to respond. This is distinct from the Nonprocurement Common Rule (NCR) system, where proposed debarment does not trigger immediate exclusion. For contractors, this matters—even "proposed" status means you cannot work with them on federal projects.

Voluntary Exclusion

A contractor may agree to be excluded for a period under terms of a settlement. This must be in writing and has governmentwide effect. Some contractors choose this route to avoid the formal debarment process and its public findings.

Statutory Ineligibility

Statutory ineligibility occurs when a contractor is excluded based on specific laws or regulations (such as Davis-Bacon Act violations or Clean Air Act penalties). The conditions and duration are set by the specific statute or regulation, not the standard FAR debarment process.

Causes for Debarment

FAR 9.406-2 (opens in new tab) lists authorized causes for debarment. Common grounds include:

Fraud: Conviction of fraud or a criminal offense in connection with a public contract
Antitrust: Violation of federal or state antitrust statutes
Financial crimes: Embezzlement, theft, forgery, bribery, or falsification of records
Tax evasion: Often results in permanent or indefinite exclusion
False claims: Intentionally affixing "Made in America" labels when false
Integrity issues: Commission of any offense indicating lack of business integrity
Contract violations: Serious violation of contract terms affecting performance
Poor performance: History of failure to perform or unsatisfactory performance
Drug violations: Violation of the Drug-Free Workplace Act

The Imputation Doctrine

Under the imputation doctrine, misconduct by officers, directors, shareholders, partners, or employees may be imputed to the contractor when the conduct occurred in connection with their duties or with the contractor's knowledge or approval.

This means a company can be debarred for the actions of its principals—even if the company itself was not directly involved. Conversely, exclusion of a company can extend to its subsidiaries, parent companies, and affiliated individuals.

Debarment Duration

Per 2 CFR 180.865 (opens in new tab), the standard debarment period is three years. However, the Suspending and Debarring Official (SDO) may:

Extend the period beyond 3 years for severe misconduct
Reduce the period upon the contractor's request with supporting documentation
Impose conditions for reinstatement (e.g., ethics training, compliance programs)

Exclusion Type	Typical Duration	Notes
Suspension	Up to 12-18 months	Until legal proceedings conclude
Debarment	1-3 years (standard)	May be extended for severe cases
Tax fraud	Indefinite/Permanent	Often no termination date
Voluntary	Per settlement terms	Negotiated with agency

A contractor may request removal from the exclusion list before the debarment period ends by demonstrating remedial action, changed circumstances, or other factors supporting early termination. However, this is rarely granted.

How to Search SAM.gov for Debarment

The SAM.gov exclusions database is publicly accessible and free to search. No account or login is required. Here's how to check if a contractor is excluded:

Step 1: Go to SAM.gov

Navigate to sam.gov/search (opens in new tab). You do not need to create an account or log in to search exclusions.

Step 2: Select "Exclusions" Domain

Under "Select Domain," choose Exclusions. This filters your search to only show debarred, suspended, and excluded parties—not all registered entities.

Step 3: Enter Search Criteria

You can search by:

Entity name: Business name, DBA, or prior name
Individual name: Owner, principal, or officer name
UEI: Unique Entity Identifier (replaced DUNS in 2022)
CAGE Code: Commercial and Government Entity code

Step 4: Review Results

If a match is found, the exclusion record shows:

Name and address of the excluded party
Excluding agency (e.g., DOD, HHS, EPA)
Cause for exclusion (FAR reference codes)
Exclusion type (Debarment, Suspension, etc.)
Active/Termination date
Cross-references to related exclusions

What to Check Beyond the Business Name

Pro tip: Don't just search the company name. Also check:

Individual owner/principals: They may be personally excluded
DBAs (doing business as): Exclusions may be under alternate names
Prior business names: Check if they recently renamed
Parent companies: Exclusions can extend to subsidiaries

Search SAM.gov Exclusions Database (opens in new tab)

GC Obligations

General contractors on federal projects have specific legal obligations regarding subcontractor verification. Failure to comply can result in contract termination and potential debarment of the prime contractor.

Federal Project Requirements

Before Award: Per FAR 9.405-2, verify subcontractors are not excluded in SAM.gov before awarding subcontracts exceeding $45,000
FAR Clause 52.209-6: Contractors must certify they have verified that proposed subcontractors are not debarred, suspended, or proposed for debarment
Ongoing Monitoring: Prime contractors should periodically verify subcontractor status throughout the contract period
Notification Requirement: If you must use a debarred subcontractor, you must notify the contracting officer in writing with compelling reasons

Consequences of Non-Compliance

Awarding a subcontract to an excluded contractor can result in:

Contract termination for default
Loss of future bidding opportunities
Potential suspension or debarment of the prime contractor
False Claims Act liability if certifications were inaccurate

Private Projects: Why It Still Matters

Even on non-federal projects, a SAM.gov exclusion is a significant red flag. It indicates the contractor failed to meet federal integrity standards due to fraud, criminal conduct, or serious contract violations.

A debarred contractor is a risky hire because:

The underlying misconduct (fraud, theft, poor performance) affects all work—not just federal
Debarment indicates a pattern of behavior, not a one-time mistake
They may be financially distressed if cut off from federal revenue
Your insurance carrier may view it as a red flag for coverage

For a comprehensive vetting process, see our Subcontractor Prequalification Checklist.

Frequently Asked Questions

Do I need a SAM.gov account to check exclusions?

No. The exclusions search is publicly accessible without any account or login. Go to sam.gov/search (opens in new tab), select "Exclusions," and enter the contractor's name or UEI.

What is the difference between debarment and suspension?

Suspension is a temporary exclusion (typically 12-18 months) imposed while an investigation is ongoing. Debarment is a final exclusion action (typically 1-3 years) after proceedings are complete. Both have the same practical effect—the contractor cannot work on federal projects.

How long does federal debarment last?

The standard debarment period is three years. However, debarments can be extended for severe cases or reduced for demonstrated remediation. Tax fraud debarments are often indefinite or permanent.

Can a debarred contractor work as a subcontractor on private projects?

Yes, technically. SAM.gov exclusion only bars work on federalcontracts and subcontracts over $45,000. However, many state and local governments also check SAM.gov, and many GCs refuse to hire debarred contractors due to the underlying integrity concerns.

What if I hired a debarred contractor before checking SAM.gov?

If on a federal project, notify your contracting officer immediately. You may need to terminate the subcontract. On private projects, assess whether to continue based on the nature of the exclusion—fraud and theft are more concerning than a paperwork violation.

Does SAM.gov track state debarments?

No. SAM.gov only tracks federal exclusions. Many states maintain separate debarment lists. In California, check the CSLB license lookup (opens in new tab) for license status and disciplinary actions.