Sponsored Program Compliance

What Is "Debarment"?

Federal 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.

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.

We ask that you assist us by doing the following:

1. If you have been debarred, suspended or excluded, IMMEDIATELY notify the University Counsel's Office (275-8019).
2. 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.
3. 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.
4. 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.

Persons who may be excluded, debarred or suspended include the following:

1. individuals who have been excluded from participation in Medicare, Medicaid or Federal Health Care Programs;
2. individuals who have defaulted on government loan obligations, including student loans;
3. individuals who have been disciplined or sanctioned by a government agency or who have had a public transaction terminated for cause or default;
4. individuals who have been debarred or suspended from government procurement (purchasing) contracts or from government nonprocurement programs (grants, cooperative agreements, scholarships, fellowships, and loans);
5. individuals who have been convicted of certain crimes, or who are under indictment or facing certain civil or criminal charges.