DE Under 3: Letter Calling for the Suspension & Debarment of “Corporate Criminals” from Obtaining Federal Contracts
Episode 26: Should We Call the Debarment Official or Wait?
Suspension and Debarment: Part 5- Remedies and Compliance in Suspension and Debarment
Suspension and Debarment: Part 3- The convergence between the FCPA and suspension and debarment
Suspension and Debarment
Polsinelli Podcast - The Climate for I9 Audits in 2015
Tariffs have been in the news almost daily. Not only have tariff rates changed repeatedly, but the deadlines around implementation are subject to change. Meanwhile, the list of new commodities that are subject to additional...more
The Air Force is showing increased interest in using its Contractor Responsibility Watch List (CRWL). This is for companies that, in the agency’s view, should be blocked from further space projects. ...more
March 2025: Reducing the Negative Impacts of a Government Shutdown for Federal Contractors - On top of the uncertainty introduced through the Trump administration’s shifting priorities and rapid-fire executive orders,...more
In a recent Final Rule (Rule) made effective January 17, 2025, the Federal Acquisition Regulation’s (FAR) suspension and debarment procedures were revised to be more consistent with the procedures in 2 CFR part 180 applicable...more
Federal contractors and grant recipients facing stop-work or suspension orders are entitled to reimbursement of costs and added performance period. In its first two weeks, the new Trump administration has introduced a flurry...more
A flurry of presidential directives, agency communications, and court orders has left federal contract and grant recipients with operational disruptions and in a state of confusion. As we write, it has been difficult to...more
On January 3, 2025, the Department of Defense, General Services Administration, and National Aeronautics and Space Administration (collectively, the Federal Acquisition Regulation (FAR) Council) issued a final rule, Improving...more
A contractor who is proposed for debarment is effectively debarred as soon as the notice letter is received. It is like being sentenced before trial and it can take weeks, or months, for the contractor to convince the...more
Introduction - On January 3, 2025, the Federal Acquisition Regulatory Council (“FAR Council”) published a long-awaited final rule to update suspension and debarment procedures. 90 Fed. Reg. 507. The final rule takes...more
On January 3, 2025, the Defense Department, GSA, and NASA (together, the "FAR Council") published its final rule amending the suspension and debarment procedures under the Federal Acquisition Regulation ("FAR"). The rule,...more
The Federal Acquisition Regulation (FAR) Council has issued a final rule, effective January 17, 2025, to improve the consistency between the procurement and nonprocurement procedures for suspension and debarment. The changes,...more
WHAT: On January 3, 2025, the Federal Acquisition Regulation (FAR) Council published its final rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more
Much has been and will be written on responsibility determinations and compliance programs in federal contracting, particularly at the intersection of cybersecurity and recent developments. Although a federal contract is not...more
First-time landlords to the government are often overwhelmed by the number of Federal Acquisition Regulation (FAR) and General Services Acquisition Regulation (GSAR) clauses included in government leases. The compliance...more
Receiving a Notice of Proposed Debarment from a federal agency Suspending and Debarring Official (“SDO”) is an alarming moment for any government contractor. It means the government believes there is a basis to question...more
Suspension and debarment are among the most powerful administrative remedies the Government has at its disposal to address non-compliance with laws and regulations, and to protect the Government’s business interests....more
WHAT: On January 9, 2024, the Federal Acquisition Regulation (FAR) Council published a proposed rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more
In recent years, we have seen statutory and regulatory exclusions from federal contracting of various entities and their goods and services happening outside the normal suspension and debarment process, the most notable being...more
On January 17, the Antitrust Division of the Department of Justice announced that it had obtained another in a recent string of guilty pleas as a result of investigations into government contracting by the Procurement...more
The Interagency Suspension and Debarment Committee (ISDC) recently released its annual report to Congress regarding suspension and debarment across the federal government in FY 2019. The report serves as a yearly reminder...more
Contractors are well aware that being suspended or debarred renders them ineligible for federal contracts and subcontracts. Many contractors may believe that suspension and debarment are not realistic risks for them if they...more
OCIs can have a serious negative impact on contractors. If it is determined that an OCI exists, it can lead to a contractor being excluded from a contract competition, having an existing contract terminated, and, in some...more
The government can suspend or debar an entity or individual for a host of actions or omissions, barring them from doing business with the government. A proactive strategy of self-examination, corrective action and engagement...more
A recent federal court decision vacating a staggering 15-year debarment based on shortcomings in the administrative record offers a glimmer of hope to contractors facing exclusion from federal programs, and reinforces the...more
Key Points - - While making some welcomed changes to the proposed rule, the final rule leaves many of the significant burdens and costs associated with requiring contractors and subcontractors to disclose various...more