of Research and Project Administration
SPONSORED PROGRAMS COMPLIANCE
What Is "Debarment"?
makes it illegal for anyone who is not in good standing with federal agencies
to work on government grants or contracts, or to provide services under
Federal Health Care Programs like Medicare or Medicaid. Individuals who
are subject to these restrictions are generally described as having been "debarred", "suspended" or "excluded."
and exclusion laws carry VERY SEVERE CIVIL AND CRIMINAL PENALTIES. Among
other things, if a university lets a debarred or excluded individual perform
services in violation of these prohibitions, the entire university could
be prohibited from working on government grants and contracts, from participating
in Medicare and Medicaid, and from receiving other financial support.
SIMPLE AS DEFAULTING ON A STUDENT LOAN may subject a person to debarment,
suspension or exclusion. (Other examples of conduct that might subject
a person to such sanctions appear at the bottom of this message). The University
of Rochester uses a number of means to detect and prevent prohibited conduct.
But these efforts cannot be completely effective without your help.
We ask that
you assist us by doing the following:
If you have
been debarred, suspended or excluded, IMMEDIATELY notify the University
Counsel's Office (275-8019).
If you are
applying for federal grants and contracts, please complete ORPA's internal
proposal sign off forms carefully. These forms specifically ask about
debarment, suspension, and other important matters. They are one of the
most important safeguards against prohibited behavior.
If you have
any doubts about whether you or anyone receiving grant support is debarred,
suspended or excluded, IMMEDIATELY bring the matter to the attention
of the University Counsel's Office.
If you are
debarred or excluded, do not make assumptions about what you can or cannot
do. These issues are very complex. Problems with one agency may affect
your relationship with other agencies. Exclusion from Medicare or Medicaid
may impact job duties that are not related to federal health care programs.
Even state programs and grants and contracts with other institutions
may be affected. Make the University Counsel's Office aware of these
issues so that they can be evaluated carefully.
For your reference,
we have provided below examples of various types of debarments, suspensions
or exclusions. You may also consult the website maintained by the General
Services Administration. But whether or not you consult the web site, you should
bring your questions to the Office of Counsel.
may be excluded, debarred or suspended include the following:
who have been excluded from participation in Medicare, Medicaid or Federal
Health Care Programs;
who have defaulted on government loan obligations, including student
who have been disciplined or sanctioned by a government agency or who
have had a public transaction terminated for cause or default;
who have been debarred or suspended from government procurement (purchasing)
contracts or from government nonprocurement programs (grants, cooperative
agreements, scholarships, fellowships, and loans);
who have been convicted of certain crimes, or who are under indictment
or facing certain civil or criminal charges.
Note: These examples
are provided for illustration purposes. The list is not intended to be exhaustive.