Claudine:

I believe the requirement necessitates our exercising "due diligence" in
ensuring our vendors and sub recipients are not debarred or suspended from
participation on federally funded activities.  Since very few higher ed
institutions, or other second tier contractors that we use, are ever debarred or
suspended, a quarterly or semiannual review of the vendor list against the then
current Fed Register list should satisfy the requirement.  Your purchasing
software should be able to do the comparison automatically.  The most difficult
part would be getting the Fed's list in electronic form.

Greg Schmidt

"Riccillo, Claudine" wrote:

> I would like to know what other schools are doing to satisfy the
> certifications required by E.O 12549 (certification of debarrment &
> suspension) in lower tier transactions over $100,000. We are being asked to
> have separate certifications for every federal agency available via website
> that would use the specific agency's language. What about other
> certifications (drug free, clean water act, etc.)?
> Claudine Riccillo
> University of Texas at El Paso
>
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