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Debarment and Suspension Certification Policy

Background

Debarment and suspension are actions taken by the federal government against organizations or individuals who have committed fraud or a criminal offense in violation of federal law.  Wesleyan University must certify that employees who have been suspended, debarred or charged with criminal activity will not be allowed to administer federal funds on behalf of the University.

What is Debarment and Suspension

Suspension - A disqualification from government contracting and subcontracting for a temporary period of time because a company or individual is suspected of engaging in criminal, fraudulent, or seriously improper conduct.  Suspension is to be used on an interim basis pending debarment proceedings.

Debarment - An exclusion from government contracting and subcontracting for a reasonable, specified period of time because an individual or vendor failed to perform or their performance was inadequate. 

All individuals and entities suspended or debarred are listed on the U.S. General Services Administration (GSA) Excluded Parties Listing System (EPLS).  The search can be performed at www.sam.gov.

Parties Who Need to Certify

Each time the University submits a proposal to the federal government, the Authorized Organizational Representative is required to complete a certification stating that the prospective primary participant and its principals are not debarred or suspended.  For purposes of Wesleyan University, it has been determined that the principals are Principal Investigators, employees conducting research, the Vice President for Finance, the Associate Vice President for Finance, the Vice President for Academic Affairs, the Associate Provost and the President. 

Procedures for Principal Investigator Certification

When a principal investigator submits their checklist for a new proposal, there will be a question under the Additional Information section that will ask whether or not the PI has been suspended or debarred.  A negative response will mean that the PI:

  1. Is not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by any federal department or agency;
  2. Has not within a three-year period preceding this certification been convicted of or had a civil judgment rendered against him or her for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public (federal, state or local) transaction, contract, or subcontract under a public transaction; for violation of federal or state antitrust statutes; or for commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements or receiving stolen property;
  3. Is not presently indicted for or otherwise criminally or civilly charged by a governmental entity (federal, state, or local) with commission of any of the offenses enumerated in paragraph (2) above; and
  4. Has not within a three-year period preceding this certification had one or more public transactions (federal, state or local) terminated for cause or default. 

It will be the Principal Investigator's responsibility to notify the grants accounting office of any non-compliance or change in their status during the application process and ensuing project period.  In the absence of any statement of non-compliance, the University signatory will report that all principals involved in an application of federal funds are in compliance with the debarment regulations. 

Procedures for Research Employee Certification

The Principal Investigator agrees that no employee will be hired to work on their grant until they have been checked against the U.S. General Services Administration (GSA), Excluded Parties Listing System as not being debarred or suspended.  If the employee has a change of status and meets any of the conditions in 1-4 above, they must immediately inform the principal investigator and the grants accounting office.

Procedures for Officer and Administrative Certification

Annually the grants accounting office will obtain certification from the officers and administrative employees listed above that they are in compliance with the federal requirements through e-mail correspondence.