The GSA’s federal Excluded Parties List System (EPLS) was replaced by the System for Award Management (SAM) in November 2012. This article explains what the EPLS was, why the SAM replaced it, the differences between the EPLS and the SAM, and what has not changed.
What was the EPLS?
The EPLS database was established in 2007 by the U.S. General Services Administration (GSA) to allow federal agencies to check that potential vendors are eligible for federal contracts. It allowed them to see if vendors were suspended, debarred, or otherwise disqualified from federal contracts or receiving federal funds through programs like Medicaid.
Why EPLS Was Replaced by the SAM
In 2009, the US Government Accountability Office investigated the accuracy and usefulness of the EPLS after getting reports of vendors with federal contracts who were supposed to be excluded. Their report found that vendors who were supposed to be excluded were, in fact, still receiving government funds. In some cases, this was because the federal agencies were not using the EPLS, but in other cases it was because the EPLS was not accurate.
The report recommended that the GSA manage the database better and strengthen controls over it. Because of these recommendations and other reasons, the GSA decided to streamline and consolidate several vendor databases, including the EPLS, the Central Contractor Registration/Federal Agency Registration (CCR/FedReg) database, and the Online Representations and Certifications Application (ORCA) database. They named the new database the System for Award Management, or SAM.
Differences Between the EPLS and the SAM
The SAM has all of the information that was previously in the EPLS, but there are some differences in how that information is organized, sorted and searched. According to the SAM’s Quick Guide for Changes From the EPLS, these are the major differences:
- Exclusion Types instead of Cause and Treatment (CT) codes. The EPLS used CT codes to indicate the entity’s exclusion status. There were over 70 of these codes that indicated, for example, whether an entity was suspended, debarred, convicted, pending investigation, voluntarily excluded or some other status. A federal working group responsible for shaping the SAM decided it would be simpler and more efficient to consolidate these into four Exclusion Types: Preliminarily Ineligible (proceedings pending), Ineligible (proceedings completed), Prohibition/Restriction, and Voluntary Exclusion. You can see a list of which CT codes fall under which Exclusion Types at sam.gov. Simply select “Help” from the top navigation bar on the home page, then select “Exclusions Information” and then “Exclusion Types” in the left navigation bar.If a record was created in EPLS before the SAM took its place, the record will show both the Exclusion Type and the old CT code. But records created since the SAM was established will have Exclusion Types only.
- New Exclusion Categories. In the SAM, excluded entities fall into one of four categories called “Classification Types.” The four Classification Types are:
- Firm: a company with a valid DUNS number
- Individual: a person without a DUNS number
- Vessel: a mode of transportation capable of transportation by water
- Special Entity Designation: any organization that cannot be considered a firm, individual or vessel. This category was called “Entity” in the EPLS.
For each of these categories, the SAM gives both the “Nature” and “Effect” of the exclusion. “Nature” gives the reason for the exclusion and “Effect” gives guidance for organizations and contracting officers about what federal funding the excluded entity can and cannot receive.
Although most of the functionality is the same in the SAM as it was in the EPLS, some of the terminology is different:
- The EPLS “CT Code” is now “Exclusion Type” in SAM. “CT” stood for “Cause and Treatment” in the EPLS. In SAM, “Cause” is called “Nature” and “Treatment” is called “Effect.”
- The “Action Date” in EPLS is now the “Active Date” in SAM.
- A record that was “Archived” in EPLS is “Inactive” in SAM.
- The “Agency Contact” in EPLS is now called the “Agency POC” in SAM.
- The “Description” part of the EPLS record is now labeled “Additional Comments.”
EPLS and SAM: What Hasn’t Changed
Most of the functionality of the SAM remains the same as that of the EPLS.
Like the EPLS, the SAM does not reliably include all excluded entities, so it is important to search both the SAM and the OIG LEIE exclusion list monthly. Importantly, the SAM is a database of federal contractors and does not have the authority to impose fines or penalties on those who contract with excluded entities. However, the OIG does have this authority. For this and other reasons, it’s important for organizations to use both lists in their compliance efforts.