A Semi-Answer to the SAM/EPLS Dilemma

August 22, 2012 | By Jerry Ashworth | Post a Comment

It took a while, but I believe I have an answer to my question I asked in a blog post a couple of weeks ago related to SAM.gov and the now-defunct Excluded Parties List System. An answer, yes. Details, no.

At the American Institute of Certified Public Accountants’ National Governmental Accounting and Auditing Update Conference this week, I asked the Karen Lee of the Office of Management and Budget if OMB was revamping 2 C.F.R. Part 180, the federal regulations related to governmentwide nonprocurement debarment and suspension, now that the EPLS has been merged into SAM.gov, administered by the General Services Administration. There are currently numerous references to the EPLS in the regulations, as well as references to EPLS.gov website. All exluded parties information is now available at SAM.gov. Lee agreed that “systems should not drive regulations” and said that as part of the current grants management reform initiative, OMB is considering all the changes that need to be made to current circulars and regulations.

Besides the EPLS issue, there are other outdated references in OMB circulars that OMB is fully aware of, Lee said. Personally, I’m glad to hear that OMB is mindful of these regulatory issues, although she couldn’t tell me how long it would take for them to be fully addressed and corrected. This makes it especially important for grantor agencies, as well as pass-through recipients, to inform new grantees and subgrantees about such inconsistencies in federal regulations and what the most up-to-date information is. Stay tuned for the next round of the grants management reforms this fall and be prepared to include your two-cents worth (if not your five-, 10 or 25-cents worth)!

What confusion do your see arising from the systems differing from federal regulations? We’d like your input.

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