2 CFR 180 and 200: exclusion checks for subrecipients and contractors

In the Uniform Guidance, a pass-through entity is a recipient or subrecipient that makes a subaward to a subrecipient to carry out part of a federal program (2 CFR 200.1). A subaward doesn't include payments to a contractor; buying goods or services under the award is a contract. The pass-through entity decides, case by case, which one each relationship is (2 CFR 200.331). Both kinds can need an exclusion check.

Part 200 was revised effective October 1, 2024; the section numbers here are the current ones, and the eCFR showed no later change to parts 25, 180 or 200 when this guide was checked.

As published on the eCFR (title 2 up to date as of October 22, 2026; checked October 26, 2026):

• 2 CFR 200.214: recipients and subrecipients are subject to the nonprocurement debarment and suspension rules in 2 CFR part 180, which restrict making federal awards, subawards and contracts with parties that are debarred, suspended or otherwise excluded.
• 2 CFR 180.300: before entering into a covered transaction at the next lower tier, you must verify that the person you intend to do business with is not excluded or disqualified, by checking SAM.gov Exclusions, collecting a certification from that person, or adding a clause or condition to the transaction. 180.330 has you pass the same requirement down to the next tier.
• Covered transactions include subawards, and a contract for goods or services awarded under one when it is expected to equal or exceed $25,000, needs a federal official's consent, or is for federally required audit services (2 CFR 180.220). Appendix II to part 200 has the matching contract clause: no contract award covered by 180.220 to parties listed in the SAM.gov exclusions.
• 2 CFR 200.332(a): a pass-through entity must verify that a subrecipient is not excluded or disqualified under 180.300, which includes confirming in SAM.gov that it isn't suspended, debarred or otherwise excluded.
• 200.332(b) has every subaward carry the subrecipient's unique entity identifier (UEI), with a name that matches the one tied to that UEI. 2 CFR 25.300: no subaward to a subrecipient that hasn't obtained a UEI and given it to you. A subrecipient doesn't need a full SAM.gov registration to get a UEI.
• 200.332(c) to (i): evaluate each subrecipient's fraud risk and risk of noncompliance, monitor its activities, follow up on audit findings, and verify that it is audited as subpart F requires.

Each federal agency adopts part 180 in its own chapter of title 2, sometimes with additions, and your award terms can add more. If you knowingly do business with an excluded person in a covered transaction, the agency may disallow costs, terminate the transaction or take other remedies (2 CFR 180.325).

Before each subaward, and each contract under the award of $25,000 or more, a pass-through entity wants to be able to show later:

• The subrecipient's UEI, and that the subaward names the party tied to it
• A check of that party against the SAM.gov exclusions, dated, made before the subaward or contract was signed
• Any certification or clause it relied on as well, kept with the file
• For subrecipients it keeps funding: that the check was repeated, and what it did when something changed

An exclusion can be added on any day, so a check from onboarding isn't the same as a check before a new subaward, an amendment or a renewal. See SAM.gov exclusion monitoring for how a linked exclusion differs from a name match.

• Exclusions, by UEI or CAGE. Watch loads the SAM.gov exclusions daily and re-checks each confirmed subrecipient or contractor on its schedule, and within about 15 minutes of a change to the list. An exclusion linked to the UEI or CAGE is a finding; a name-only resemblance is "possible, confirm" until a person at your organization decides.
• Registration and UEI status. For parties registered in SAM.gov, Watch shows whether the registration is active, expired or deleted and warns before it expires. Registration facts come from SAM.gov's public monthly extract. That extract lists registered entities only (active, or expired in the last six months), so a subrecipient that obtained a UEI without registering isn't in it, and can't be found by name. Give Watch its UEI: when Watch's lookup of UEIs assigned without a registration finds it, Watch confirms it as “UEI only (not registered in SAM.gov)” and checks the UEI's status, the exclusions linked to the UEI and the screening lists, without registration findings. When Watch can't find the UEI (including an entity SAM.gov doesn't show publicly), the subrecipient stays unmatched and isn't checked: check its UEI and the exclusions at SAM.gov directly and keep that record with the subaward. For subrecipients use the “Grant subrecipient (2 CFR 200)” requirement template, which asks for a UEI rather than a registration; “Federal subcontract: eligibility” asks for an active registration, which 2 CFR 25.300 doesn't require of subrecipients.
• Screening lists. The trade.gov Consolidated Screening List (OFAC, BIS, State), with each possible match decided by a person.
• A screen before the signing date. Put the date in a sentence ("Watch our Year 3 subrecipients for exclusions by 1/15") and Watch re-checks them ahead of it and freezes the result as a dated snapshot.
• Documents. Keep a signed certification, the subaward or anything else on the party's record, with its issue and expiry dates.
• The record. Every check keeps what the source said and its data date, every decision is in a hash-chained audit log, and the audit export or a per-party evidence package is what you hand an auditor or the awarding agency.

Watch doesn't make the subrecipient-or-contractor determination, assess a subrecipient's risk, review financial or performance reports, or review single audits. It reads business entities only, so check an individual (a consultant, a fellow, a principal) at SAM.gov directly. You can try one UEI now with the supplier check.