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law 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."
The
debarment 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.
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SOMETHING
AS 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.
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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.
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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.
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Persons
who may be excluded, debarred or suspended include the
following:
- individuals
who have been excluded from participation in Medicare,
Medicaid or Federal Health Care Programs;
- individuals
who have defaulted on government loan obligations,
including student loans;
- individuals
who have been disciplined or sanctioned by a government
agency or who have had a public transaction terminated
for cause or default;
- individuals
who have been debarred or suspended from government
procurement (purchasing) contracts or from government
nonprocurement programs (grants, cooperative agreements,
scholarships, fellowships, and loans);
- individuals
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. |
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