Reading a SAM.gov exclusion record.

A SAM exclusion is the public artifact of a federal action that bars a contractor from receiving new awards. SAM consolidated the data that used to live in the Excluded Parties List System (EPLS). The action itself is one of four legal instruments, a debarment, a suspension, a proposed debarment, a voluntary exclusion, or a statutory prohibition, entered by an authorized agency suspending and debarring official.

Suspension

Interim, "adequate evidence" standard, pending proceedings (FAR 9.407). Time-limited.

Debarment

Final, supported by preponderance of the evidence or conviction (FAR 9.406). Period typically 1 to 3 years.

Voluntary exclusion

Settlement-based. Almost always carries a defined termination date.

Prohibition / Restriction

Statutory or treaty-based. OFAC SDN-derived bars and partial-denial regimes appear here.

FAR 9.405(a)states the practical effect: a contractor with an active exclusion is barred from new awards across the government "unless the agency head determines that there is a compelling reason" to award anyway. The compelling-reason exception is real, narrow, and underused. It is the answer to "how did this contractor still win the bid" in cases where the answer is not corruption.

EPLS used a granular taxonomy of more than seventy Cause and Treatment (CT) codes describing both the reason and the procedural disposition of an exclusion. When GSA migrated EPLS into SAM, an interagency working group consolidated those codes into four Exclusion Types. New records carry only the Exclusion Type. Records originated in EPLS still display both the legacy CT code and the new Exclusion Type. Readers will encounter this on long-running exclusions and need to know it is not a bug.

Preliminarily Ineligible (Proceedings Pending)

Active immediately on entry. Maps to suspension or proposed debarment under FAR 9.407, adequate evidence of conduct indicating a lack of business honesty or integrity, pending the completion of an investigation or legal proceedings.

Ineligible (Proceedings Completed)

Maps to debarment under FAR 9.406-2. Determined ineligible upon completion of administrative proceedings establishing, by preponderance of the evidence, a cause of a serious and compelling nature that affects present responsibility.

Prohibition / Restriction

Statutory or treaty bars. Includes OFAC sanctions-derived listings, Treasury-imposed restrictions, and partial-denial regimes that fall short of full debarment but still gate procurement participation.

Voluntary Exclusion

The contractor accepted an agreement to be excluded under a settlement with one or more agencies. Almost always a defined termination date. Common where a contractor wants to avoid the reputational cost of a contested debarment.

The differentiator section. Each field on a SAM exclusion record carries operational weight in a responsibility determination. Misread one of them and the entire determination is wrong.

Classification / Exclusion Type

One of the four above. Controlling field. Read this first.

Name and Address

The legal entity as reported by the excluding agency. Not necessarily the trading name. Confirm UEI before assuming a match, name fuzziness has produced wrong-vendor screening errors.

DUNS / UEI / CAGE

Entity identifiers if available. Pre-2022 records may be DUNS-only. Cross-reference against the entity record to confirm which legal entity is excluded.

Cross-Reference

Links the principal to affiliated individuals or entities also excluded under the same action. The most-missed field in record reads. Clearing a parent without checking cross-references can leave excluded affiliates in the supply chain.

Excluding Agency

The agency that entered the exclusion (FAR 9.404(b)). Important because it sets the scope question, agencies with limited statutory authority issue narrower exclusions than the GSA suspending and debarring official.

Active Date

When the exclusion took effect.

Termination Date

A specific date or "Indefinite." See section 6, "Indefinite" does not mean "permanent." It means no defined end. Treat as active until proved otherwise.

Active vs Inactive status

"Active" means currently barring new awards. "Inactive" means the termination date has passed or the exclusion was rescinded. Inactive does not mean cleared, the historical record remains visible and remains relevant to FAR 9.104-1 present-responsibility analysis.

Scope: Government-wide vs Agency-specific

Government-wide is the FAR 9.406 / 9.407 default and applies across all federal procurement. Agency-specific bars apply only to the issuing agency, often limited to nonprocurement (grants, loans) under 2 CFR Part 180. A scope read is mandatory before treating an exclusion as a government-wide bar.

Reciprocal-enforcement indicator

When present, indicates the action is reciprocally enforced across procurement (FAR) and nonprocurement (2 CFR Part 180) systems. Most FAR 9.406 debarments are reciprocal by default; some statutory prohibitions are not.

Action / Cause

The underlying conduct (fraud conviction, antitrust violation, false certification, drug-free workplace violation, delinquent federal taxes, etc.) keyed to FAR 9.406-2 or 9.407-2 categories.

Additional Information / Comments

Agency-supplied free text. Often the only field that explains the actual conduct. Read it.

sam.gov/content/exclusions is free, public, and requires no login for the search itself (some advanced features require sign-in). Search by name, UEI, CAGE, DUNS, or SSN/TIN with proper authorization.

Re-check before award, not just at solicitation. Agencies have 3 working days to enter a new exclusion and 5 working days to update one (FAR 9.404(c)). A 60-day-old screen is stale. FAR 9.405 contemplates the contracting officer reviewing both after bid opening and immediately before award.

The single most common confusion in exclusion-record reads. The two lists overlap but are not equivalent.

OIG LEIE

List of Excluded Individuals and Entities, maintained by HHS Office of Inspector General. Covers participation in federal health care programs (Medicare, Medicaid, etc.) under Social Security Act §1128 (mandatory) and §1128(b) (permissive). Mandatory exclusions are minimum 5 years; permissive are discretionary.

SAM exclusions

The procurement-side gate, governed by FAR 9.404. Covers any federal contract award.

Asymmetric overlap

OIG forwards its exclusions to SAM, so most LEIE entries appear in SAM as Prohibition/Restriction or Ineligible (Proceedings Completed) records. SAM exclusions do NOT flow back to LEIE. A FAR 9.406 debarment for procurement fraud will not appear on LEIE.

State Medicaid exclusions

Roughly half never reach the federal LEIE. Healthcare-adjacent procurement (CMS, VA, IHS) requires checking SAM, the federal LEIE, and the relevant state list.

The net rule: for a federal procurement responsibility determination, SAM is the authoritative gate. For a healthcare-program contract, you need both SAM and LEIE, and depending on jurisdiction, the relevant state list.

• Treating "Inactive" as "cleared." Inactive means the period elapsed; the historical action and any underlying conviction or settlement are still on file and still relevant to a present-responsibility determination under FAR 9.104-1.
• Reading "Indefinite" as a system glitch. It is a deliberate value indicating no defined end. Always active until rescinded.
• Assuming agency-specific equals government-wide. A nonprocurement-only bar from one agency does not block a DOD contract award. It is still a flag for present-responsibility purposes, but it is not a hard exclusion.
• Skipping cross-references. The principal entry is rarely the whole picture. Affiliated individuals and entities listed as cross-references are also excluded.
• Assuming OIG and SAM mirror each other. They do not, and the gap runs in both directions.
• Trusting a CT code on a legacy record. Informational only. The Exclusion Type is the controlling field.
• Single screening at solicitation. FAR 9.405 contemplates a re-check immediately before award. New entries land daily.

DiligenceDesk pulls SAM exclusion records keyed to the resolved UEI from the SAM identity step. The verdict ladder treats exclusions as follows:

• Active exclusion (any of the four types) → FAIL, regardless of scope. We surface the scope read separately so the user can apply the FAR 9.405(a) compelling-reason analysis if relevant.
• Inactive exclusion within the last 3 years → WARNING (present-responsibility relevance under FAR 9.104-1).
• Older inactive → NEUTRAL with note.
• Cross-references are followed and surfaced as their own evidence rows.

See the methodology page for the full verdict ladder, and FAPIIS / R/Q records for the responsibility-record sibling layer (FAPIIS is integrity data; SAM exclusions are the bar itself).