A Provider’s Guide to the GSA SAM Database.

The importance of screening employees, vendors and contractors against available federal and State exclusion databases cannot be overemphasized.  Despite the best efforts of the Department of Health and Human Services (HHS), Office of Inspector General (OIG), “exclusion screening” remains perhaps the least appreciated compliance risk faced by many small and mid-sized healthcare providers and suppliers._[1] To the extent that a health care provider has, in fact, taken steps to properly screen its staff and contractors, many have restricted their reviews to periodic screens of the OIG’s List of Excluded Individuals and Entities (LEIE),_[2] and their State’s list of parties excluded from participation in Medicaid and other state-funded health care programs.  Unfortunately, screening against these databases isn’t sufficient to identify individuals and entities that may have been excluded, suspended or debarred from doing business with other federal agencies and the non-Medicare programs they administer.  For the reasons set out in this article, insurance payors, health care providers and suppliers should also screen the General Services Administration’s (GSA’s) System for Award Management (SAM) database to ensure that the individuals and entities they employ or do business with have not been suspended or debarred from doing business with certain federal agencies and the programs they administer. This article also examines the role of the GSA’s SAM Database with respect to screening for excluded, suspended and debarred individuals and entities.

Historical Overview of the GSA’s System for Award Management (SAM) Database:

Today’s GSA’s SAM database has evolved from humble beginnings over the last 30 years. After being sworn in as President in 1993, President William Clinton instructed his administration to conduct a National Performance Review of the “business” of government.  In September 1993, the task force appointed to conduct this review issued its report and outlined 380 recommendations for (1) management reform, (2) reorganization, and (3) government downsizing.  A year later, in September 1994, the task force reported that 90% of its initial recommendations had been implemented, resulting in projected savings of $46.9 billion and reducing the federal employment rolls by 71,000 positions._[3]

These efforts to reduce and streamline the size of government enjoyed support from both Democratic and Republican legislators. Legislation previously passed by Congress, the “Federal Acquisition Streamlining Act of 1994”,_[4] was signed into law by President Clinton in October 1994.  The stated purpose of this legislation was to streamline and reform the federal procurement process.

A. Legacy Databases and Registries Folded into GSA’s SAM Database.

Subsequent to the passage of the “Federal Acquisition Streamlining Act of 1994,” a number of procurement-related programs were implemented by various federal agencies in an effort to reform the federal procurement process.  Several of these efforts included the following: 

• Establishment of the FedBizOpps (FBO) Website.  In 2002, the GSA first established the FedBizOpps (FBO) website.  The FBO was intended to serve as a single point-of-entry for federal procurement opportunities over $25,000.  While well intended, the FBO was roundly criticized by vendors and contractors hoping to learn of “Requests for Quotes” (RFQs) posted by federal agencies.  Unfortunately, the FBO was plagued with problems and was ultimately referred to as the “WORST WEBSITE IN GOVERNMENT” by the Federal News Network_[5] Ultimately, the GSA announced in October 2019 that the FBO’s functions would be merged into the beta version of the SAM database.  The migration and merger with the GSA’s SAM database officially occurred in May 2021.

• Establishment of the Central Contractor Registration (CCR) Program. Not surprisingly, the U.S. Department of Defense (DOD) played a key role in reorganizing and improving the federal government’s processes for purchasing goods and services from private vendors. Among its contributions, the DOD established a centralized electronic registration process known as the “Central Contractor Registration” (CCR) program.  The CCR was a serious step forward with respect to federal procurement.  It was intended to serve as a single point of contact for private vendors and contractors desiring to do business with the DOD.  To accomplish this, the DOD revised the Defense Federal Acquisition Regulation Supplement (DFARS) to require that vendors and contractors register with the CCR if they wanted to do business with DOD.  As required by DFARS 204.7302, the DOD mandated that after May 31, 1998, prospective vendors had to be registered with the CCR before they could be awarded a contract with the DOD. In October 2003, the GSA published a new Federal Acquisition Regulation(FAR)_[6] policy_[7] which required that ALL federal contractors register in the CCR database prior to awarding contracts and authorizing purchases from private vendors and contractors. In July 2012, the CCR transitioned to the GSA’s SAM database.   

• Establishment of the Excluded Parties List System (EPLS).  In 2007, the General Services Administration established the Excluded Parties List System (EPLS).  The purpose of the EPLS was to maintain a database of individuals and entities that were excluded, debarred or suspended from doing business with the government.  Unfortunately, the EPLS was criticized by both users and the Government Accountability Office (GAO) because a number of excluded and debarred individuals and companies were able to circumvent the terms of their exclusion or debarment merely by operating under different identities._[8] In July 2012, GSA migrated its EPLS, and a number of other legacy systems to the new GSA’s SAM database._[9]

In addition to the above, a number of other procurement-related federal databases_[10] have been folded into the GSA’s SAM database since its creation.  

B. Establishment of the SAM Database.

In 2012, the GSA first launched its “System for Award Management” (SAM) in an effort to address ongoing deficiencies with existing registries and to provide for a government-wide database that covers the needs of private contractors and vendors seeking to conduct business with the government. The SAM database also serves as a central registry for agencies to report certain adverse actions taken against individuals and vendors that have been suspended, excluded, debarred or otherwise sanctioned by a federal agency.  There is no cost to use the SAM database. The GSA’s SAM database website can be used to: 

• Register to do business with the U.S. Government.
• Update, renew, or check the status of your entity registration.
• Search for entity registration and exclusion records.
• Search for assistance listings (formerly CFDA.gov), wage determinations (formerly WDOL.gov), contract opportunities (formerly FBO.gov), and contract data reports (formerly part of FPDS.gov).
• View and submit BioPreferred and Service Contract Reports.
• Access publicly available award data via data extracts and system accounts

The SAM database is one of the sanction lists most frequently searched at the request of Exclusion Screening^SM clients.  As discussed below, more than a hundred federal agencies, administrative offices, commissions, advisory councils, etc. In fact, a number of federal agencies have their own version of a “Suspension & Debarment Committee” that is responsible for reviewing procurement-related referrals for potential suspension and debarment action.

C. Various Agencies Currently Report Adverse Actions to GSA for Inclusion in the GSA’s SAM Database.

Since being established, the GSA’s SAM database has essentially become the central compendium for excluded, suspended, and debarred individuals and entities.  As of the end of 2023, there were more than 148,000 parties were listed in the SAM database.   

Final Thoughts Regarding the Screening of the GSA’s SAM Database

In order to protect your health care organization, it is strongly recommended that you screen employees, contractors, vendors and against the GSA’s SAM database.  We do not recommend that you limit your search efforts to only the OIG LEIE and all available State Medicaid exclusion lists. To ensure that your office is protected and potentially knows about an excluded, suspended or debarred individual, Exclusion Screening recommends that health care providers conduct a comprehensive search of all available databases, including the SAM database, each month. For a free consultation, please call 1-800-294-0952 or fill out our assessment of needs and costs found below.

Robert Liles is the author of this article. Contact the exclusion experts at Exclusion Screening, LLC today for a free consultation by calling 1-800-294-0952 or by filling out the form below.

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[1] A detailed article covering the OIG exclusion process titled “A Provider’s Guide to OIG Exclusions” can be found on Exclusion Screening’s website.  

[2] The authority to exclude was granted to the Secretary of the Department of Health and Human services in the Civil Money Penalties Law (Public Law 97-35, 1981 (as codified at section 1128A of the SSA). The Secretary delegated it to its Office of Inspector General in 1988 (53 Fed. Reg. 12,993 (April 20, 1988)).  

[3] The National Performance Review and Other Government Reform Initiatives: An Overview, 1993-2001.  CRS Report for Congress.  (Updated June 4, 2001).

[4] “Federal Acquisition Streamlining Act of 1994,” Public Law No. 103-355. (10/13/1994). 

[5] See Federal News Network’s article titled “GSA’s eBuy Open pilot reminds us why FBO.gov remains a problem.”  (February 11, 2019).

[6] The Federal Acquisition Regulation(FAR) is the “primary regulation for use by all executive agencies in their acquisition of supplies and services with appropriated funds.” The Department of Defense (DOD), the General Services Administration (GSA), and the National Aeronautics and Space Administration (NASA) are jointly responsible for issuing the FAR. 

[7] Circular 2003-016, FAR case 2002-018. 

[8] Government Accountability Office (GAO) report titled “EXCLUDED PARTIES LIST SYSTEM – Suspended and Debarred Businesses and Individuals Improperly Receive Federal Funds.” GAO-09-174(February 2009).

[9] Department of Health and Human Services, Office of Inspector General (OIG), issuance titled “UPDATED — Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs.”  (Issued May 8, 2013).  See Footnote 6. 

[10] For example, both the Federal Agency Registration (Fedreg) and the Online Representations and Certifications Application (ORCA) were migrated over to the GSA’s SAM database.

[11] For additional information on the OPM suspension and debarment process, see Liles Parker’s article titled “The OPM Debarment Process – Responding to an FEHBP Debarment or Suspension Action in 2024.”

[12]  With respect to vendors and contractors, the OIG suggests that providers use the same analysis in determining “whether or not to screen contractors, subcontractors, and the employees of contractors” that it uses for its own employee.  

[13] The OIG has twice published guidance of the effect of an OIG Exclusion. A Special Advisory Bulletin on the Effects of Exclusion from Federal Health Care Programs” was issued September 2, 1999, and an “Updated Special Advisory Bulletin on the Effect of Exclusions from Participation in Federal Health Care Programs” was issued May 8, 2013.   

[14] The FAR allows for contractors to be suspended or debarred. A contractor is any individual or organization that: (a) Directly or indirectly submits offers for or is awarded, or reasonably may be expected to submit offers for or be awarded, a government contract or subcontract; or (b) Conducts business, or reasonably may be expected to conduct business, with the Government as an agent or representative of another contractor; or (c) Those directly and indirectly involved in the wrongdoing or alleged wrongdoing. See GSA’s Acquisition Policy page.  

[15] See FAR Part 9, Contractor Qualifications, Subpart 9.407-2.

[16] See GSA’s Acquisition Policy page.   

[17] See FAR Part 9, Contractor Qualifications, Subpart 9.406-2. 

[18] Executive Order 12549 was put into place by President Ronald Reagan on February 18, 1986.

[19] See OFAC’s Civil Penalties and Enforcement Information chart for 2023.