What Was the Excluded Parties List System (EPLS)?
The EPLS was replaced by the System for Award Management (SAM)
The Excluded Parties List System (EPLS) was a database maintained by the General Services Administration (GSA)--an independent U.S. government agency, established in 1949, to help manage Federal agencies. The EPLS identified suppliers and vendors that were excluded from receiving Federal contracts, certain subcontracts, and some types of Federal financial and non-financial assistance.
In November 21, 2012, the EPLS was replaced by the System for Award Management (SAM), which consolidated the Federal procurement system and the Catalog of Federal Domestic Assistance, into one large entity.
Original Purpose of the EPLS
Launched in January 2007, the EPLS system covered the five following categories of individuals and businesses:
- Individuals excluded or disqualified under a Federal agency's codification of the Common Rules on Non-procurement suspension and debarment, or otherwise declared ineligible from receiving certain Federal assistance and/or benefits.
- Individuals debarred, suspended, proposed for debarment, or otherwise declared ineligible from participating in Federal procurement programs.
- Individuals barred or suspended from acting as sureties for bid and performance bond activity in procurement programs.
- Individuals barred from entering the United States.
- Individuals subject to sanctions with regards to 31 CFR Parts 500-599 and any relevant subparts.
Users of the EPLS
The GSA identified a number of specific users of the EPLS and the subsequent System for Award Management (SAM) application, including:
- Contracting officers and other Federal, state, and local government employees involved in procuring goods and services.
- A Federal, state, local, or foreign agency responsible for prosecuting, enforcing or carrying out a statute, rule, regulation or order where the records clearly indicate a violation of civil or criminal law or regulation.
- A Federal, state or local agency, financial institution or a healthcare or industry provider that administers assistance programs or benefits, where the information is needed to determine eligibility.
Errors on the Database
Before individuals and businesses were placed on the EPLS, they were notified by the agency that took the action to exclude them from Federal procurement and non-procurement programs. Those who wished to contest their placement on the list would have to directly contact the agency that named them.
Issues with the EPLS
In 2009, the US Government Accountability Office (GAO) evaluated the EPLS, to investigate an allegation stating that excluded parties on the EPLS were nonetheless still receiving Federal contracts. The report found the following:
- A number of suppliers who had been excluded for offenses like national security violations and tax fraud were still receiving funding for a number of reasons, including the failure of agency officials to properly search the EPLS database.
- Some businesses and individuals were able to circumvent the terms of their exclusions by operating under different identities.
- No single agency was charged with monitoring the content and function of the database.
- Agencies were not consistently inputting timely or accurate data related to excluded parties
- EPLS entries were incomplete, with insufficient search capabilities and missing points of contact.
The GAO report contributed to the EPLS' aforementioned replacement by the System for Award Management (SAM).
This article has been updated by Gary Marion, Logistics and Supply Chain Expert for The Balance.