Does Your Business Need U.S. Federal Exclusions Screening?
Businesses that receive federal funds, perform government contracts, participate in federally supported programs, or hire subcontractors for federally connected work should determine whether they must screen people and business entities through the federal System for Award Management—SAM.gov.
SAM.gov is operated by the U.S. General Services Administration and contains government-wide exclusion records submitted by federal agencies. These records may identify businesses and individuals that are debarred, suspended, proposed for debarment, declared ineligible, voluntarily excluded, or otherwise prohibited from participating in certain federal transactions.
Your business should consider SAM.gov screening if it:
- Holds or pursues a US Federal contract
- Performs as a subcontractor on federally funded work
- Receives federal grants, loans, reimbursements, or program funding
- Participates in a Department of Education Title IV program
- Provides healthcare or human services supported by federal funds
- Works with the Departments of Defense, Education, HHS, HUD, Transportation, Homeland Security, or another federal agency
- Engages consultants, vendors, contractors, owners, officers, or principals whose eligibility may affect a government contract
- Must certify that excluded parties are not participating in a federally funded transaction
Federal Acquisition Regulation 9.404 identifies SAM.gov as the federal government’s system containing exclusion records. FAR 9.405 generally prevents federal agencies from awarding contracts to actively excluded contractors except under limited, documented circumstances. Certain federal contractors must also address exclusions when selecting subcontractors.
Who may need to be screened?
Depending on the contract, funding source, agency regulation, and role, screening may apply to:
- The business entity
- Owners and controlling affiliates
- Corporate officers and principals
- Individual contractors and consultants
- Proposed subcontractors
- Vendors participating in federally funded work
- Employees assigned to covered contracts or programs
FAR 9.404 does not require every private employer to screen every employee. The obligation depends on the business’s contracts, funding, program rules, representations, and applicable federal or state requirements. Businesses should review their award documents and consult qualified counsel or their contracting officer when the scope is uncertain.
SAM.gov is not the same as every other federal exclusion list.
A SAM.gov search does not replace:
- HHS-OIG LEIE screening for federal healthcare-program exclusions
- State Medicaid exclusion and debarment searches
- OFAC sanctions screening
- State contractor-debarment lists
- Agency-specific licensing or eligibility searches
A business may need several of these searches based on its industry and funding.
Recommended compliance practice
BestHire recommends screening covered businesses and individuals before award, hiring, onboarding, subcontracting, or assignment to federally connected work. Organizations should retain a dated record showing:
- The name and identifiers searched
- The database searched
- The date of the search
- The reported result
- Any potential match and the steps taken to resolve it
For continuing relationships, periodic monitoring should also be considered because an individual or entity that was eligible at onboarding can later become excluded.
BestHire, LLC can help your organization determine which exclusion searches fit its operations and provide documented screening of individuals and business entities.
Protecting Employers Before the First Day of Work℠
#SAMgov #FederalContracting #GovernmentContracting #FederalCompliance #Debarment #ExclusionScreening #BackgroundScreening #VendorRiskManagement #RiskManagement #BestHire
### Updated Aug 2026