# How a Federal Contractor Is Suspended and Debarred The federal government buys well over half a trillion dollars of goods and services a year, and the sharpest thing it can do to a company that cheats it is not a fine or a prosecution. It is to stop buying. A contractor cut off from federal work is not merely penalised in one deal; it is removed from the customer. The machinery that does this sits in one short piece of the Federal Acquisition Regulation — Subpart 9.4 — and it runs on a logic most readers would not guess. It is not punishment. It is a judgment about whether the company can be trusted *now*, which is why the governing phrase is **present responsibility** and why a company can be debarred for conduct it was never convicted of, and left alone after a conviction it has convincingly cleaned up after. This map draws that machinery as a sequence: who may start it, what counts as a cause, what the company gets to say and when, who decides, how long it lasts, and the four very different ways out. It is the institutional companion to [[Federal Whistleblower Protection Crosswalk]], which maps what happens to a contractor *employee* who reports the same misconduct, and the comparison is the reason this page is worth reading twice. The employee who blows the whistle gets an inspector general investigation on a 180-day statutory clock and then, after 210 days, a case in federal district court tried by a jury if either side asks for one. The company accused of the underlying fraud gets thirty days to write a letter to one agency employee, who decides alone, usually without a hearing, on a record the company often cannot see. **The person who reports the fraud gets a jury; the company that allegedly committed it gets a paragraph.** Two further things make the subpart worth mapping rather than summarising. The first is that **a suspension takes effect before the company is told it is suspended** — the notice follows the exclusion rather than preceding it — and the opportunity to argue runs afterwards. The second is what happens at the exit. Of the four ways out, two are public and two are not, and the one that leaves the company still selling to the government is the one filed in a database the public has no statutory right to read. > [!note] How to read this chart > `──▶` = the main path · `└─▶` = a branch or bypass · `◇` = a decision point · `✕` = the company is out of federal work here · `★` = the step that actually decides it · `⚑` = a load-bearing stage, where the real attrition happens · `☐` = a deadline or period the company can count in advance · `◎` = one agency employee decides alone, with no hearing and no vote · `§` = the rule is in statute, so the regulation writers cannot change it · `⊘` = a right that exists on paper and that no public source counts · `◈` = a consequence written in no rule · `≠` = two parties to one contract, given unequal process · `[ ]` = a dated note. Stage numbers are this map's, not the regulation's; the regulation's own section numbers are given in each stage. ``` HOW A FEDERAL CONTRACTOR IS SUSPENDED AND DEBARRED (as of 10 November 2026) │ Legend: ──▶ main path └─▶ branch or bypass ◇ decision ✕ out of federal work │ ★ the step that decides it ⚑ load-bearing stage, where the attrition is │ ☐ a deadline or period the company can count in advance │ ◎ one agency employee decides alone, with no hearing and no vote │ § the rule is in statute, not the regulation ⊘ a right nobody counts │ ◈ a consequence written in no rule ≠ unequal process, same contract │ [ ] dated note │ Scale: Across the 24 largest federal agencies in fiscal year 2023: 2,018 cases │ referred · 423 suspensions · 1,165 proposed debarments · 1,009 debarments │ · 97 show-cause letters · 56 declinations · 15 voluntary exclusions · and │ 47 administrative agreements, entered by 10 agencies. Proposed debarments │ outnumber suspensions nearly three to one, and the negotiated exits are │ rarer than either — about one administrative agreement for every 21 │ debarments. │ [ Interagency Suspension and Debarment Committee, Section 873 report to │ Congress for FY2023, transmitted 31 Dec. 2024, Appendices 2 and 3. ] │ ■ 0. TWO INSTRUMENTS, TWO STANDARDS OF PROOF (FAR 9.406-2 · 9.407-2) ⚑ │ The subpart holds two tools that look alike and are not. Everything downstream │ — how fast it bites, what the company gets to say, how long it lasts — follows │ from which one is used. │ ├─◆ SUSPENSION · "suspected, upon adequate evidence" (FAR 9.407-2) │ ☐ Temporary, pending an investigation and any legal proceedings that follow. │ § An INDICTMENT is by itself adequate evidence. Nothing more is required. │ The lowest evidentiary bar in the subpart, and the fastest instrument. │ └─◆ DEBARMENT · a conviction, a civil judgment, or a preponderance (FAR 9.406-2) ☐ A fixed period, ended by the calendar rather than by an investigation. Three tracks into it: (a) a CONVICTION or CIVIL JUDGMENT — contract fraud, antitrust bid-rigging, embezzlement, forgery, bribery, falsified records, false statements, tax evasion, receiving stolen property, a false "Made in America" label, or "any other offense indicating a lack of business integrity." (b) a PREPONDERANCE OF THE EVIDENCE — no court involved at all. Covers wilful non-performance or a history of failure to perform; drug-free workplace violations; unfair trade practices; delinquent federal taxes over $10,000; and the disclosure rule below. ◈ (b)(vi) is the one most contractors are surprised by: a principal's KNOWING FAILURE to disclose credible evidence of fraud, bribery, conflict of interest, a False Claims Act violation or a significant overpayment — a duty that runs until three years after final payment. Staying quiet is itself a cause. (c) the CATCH-ALL — "any other cause of so serious or compelling a nature that it affects the present responsibility of the contractor." No list, no court, no ceiling. │ ■ 1. WHO DECIDES (FAR 2.101 · 9.406-1 · 9.407-1) ◎ ⚑ ★ │ ONE PERSON. The suspending and debarring official — "a designee authorized by │ the agency head to impose a suspension and/or a debarment." Not a board, not a │ judge, not a commission. An employee of the agency doing the excluding, holding │ no fixed term and no removal protection, deciding in the first instance and │ with no appeal inside the subpart. │ ◎ The title was unified in 2025: before then the regulation named a separate │ "debarring official" and "suspending official." │ [ FAR Case 2019-015, final rule effective 17 Jan. 2026 — see stage 13. ] │ § Once a cause exists, THE BURDEN FLIPS. The company must demonstrate that it │ is presently responsible and that exclusion is not necessary. The government │ does not have to show that it is. (FAR 9.406-1(b)) │ Where two agencies both have an interest, they coordinate through the │ Interagency Suspension and Debarment Committee to pick the official best │ situated to act; occasionally two act jointly. The committee is an unfunded │ interagency body created by Executive Order 12549, and it has no power to │ decide a case itself. │ │ ──▶ │ ■ 2. THE ORDER OF OPERATIONS, WHICH IS THE WHOLE POINT ⚑ ≠ │ This is where the two instruments split, and it is the stage a reader should │ slow down on. │ ├─◆ 2a. SUSPENSION — EFFECT FIRST, NOTICE SECOND (FAR 9.407-3(b)-(c)) ✕ │ │ The suspension is imposed. The company "shall be immediately advised" — │ │ afterwards. The opportunity to oppose it comes "following the imposition │ │ of suspension." │ │ ☐ The notice gives 30 days to respond. │ │ ◈ The notice describes the conduct "without disclosing the Government's │ │ evidence." The company is told what it is accused of and not what the │ │ accusation rests on. │ └─▶ The company is out of new federal work from this moment, before it has │ said a word. │ └─◆ 2b. DEBARMENT — NOTICE FIRST, BUT THE NOTICE ALREADY EXCLUDES (FAR 9.406-3(c)) │ A notice of PROPOSED debarment goes to the company and any named affiliates, │ stating the reasons and the cause relied on. │ ☐ 30 days to submit information and argument in opposition — in writing, in │ person, or through a representative. │ ✕ ◈ A PROPOSED debarment carries the same exclusionary effect as a finished │ one. A company under proposal is already off the eligible list while the │ proposal is pending. The word "proposed" does not soften anything. │ (FAR 9.405(a) · and see stage 7) └─▶ A pre-notice letter — a warning shot that excludes nobody — exists and is optional: "A pre-notice letter is not required to initiate debarment." 97 were sent government-wide in FY2023, against 1,165 proposed debarments. │ │ ──▶ │ ■ 3. THE 30 DAYS (FAR 9.406-3(b)(1), (c) · 9.407-3(b)(1), (c)(5)) ☐ │ Both tracks converge on one written submission, and the regulation sets the │ register deliberately low: the procedures are to be "as informal as is │ practicable, consistent with principles of fundamental fairness." │ ⚑ The single most consequential sentence for a company drafting that letter: │ "A general denial is insufficient to raise a genuine dispute over facts │ material to the proposed debarment." (FAR 9.406-3(c)(3)(viii)(A)) │ A denial is not a dispute. Specificity in these thirty days is what decides │ whether stage 4 ever opens. │ │ ──▶ │ ■ 4. ◇ THE HEARING THAT USUALLY DOES NOT HAPPEN (FAR 9.406-3(b)(2) · 9.407-3) ⚑ ★ │ Everything that looks like a trial in this subpart lives behind two gates, and │ most cases never reach them. │ │ ◇ GATE ONE — IS THE ACTION BASED ON A COURT'S WORK? │ ├─▶ YES (a conviction · a civil judgment · for suspension, an indictment) │ │ ✕ No fact proceedings. The decision is made "on the basis of all the │ │ information in the administrative record." The company's 30-day letter │ │ is in that record; nothing else is added. │ │ § This is the hinge of the whole design: an indictment is adequate │ │ evidence for a suspension (stage 0), and an indictment-based action is │ │ also exempt from fact proceedings. A grand jury's finding, reached │ │ without the company present, both triggers the exclusion and forecloses │ │ the hearing about it. │ │ │ └─▶ NO ──▶ ◇ GATE TWO — DID THE LETTER RAISE A GENUINE DISPUTE OVER FACTS │ MATERIAL TO THE ACTION? │ ├─▶ NO ✕ Administrative record again. No hearing. │ └─▶ YES ──▶ ★ THE FULL PROCEDURE OPENS, and it is substantial: │ appear with counsel · submit documentary evidence · present │ witnesses · "confront any person the agency presents" · a │ transcribed record · and WRITTEN FINDINGS OF FACT. │ ◈ A fact-finder's findings bind the deciding official, who may │ reject them "only after specifically determining them to be │ arbitrary and capricious or clearly erroneous." │ ⊘ For SUSPENSION there is a third gate on top of these two: the │ Department of Justice or the responsible prosecutor may determine │ that substantial interests in a related proceeding would be │ prejudiced — and the fact proceedings do not happen at all. The │ company's right to a hearing can be switched off by a party that │ is not the deciding official and not reviewable in the │ proceeding. (FAR 9.407-3(c)(6) · (d)(1)) │ │ ──▶ │ ■ 5. THE DECISION (FAR 9.406-3(d) · 9.407-3(d)) ★ │ ☐ Where no suspension is already in effect and the case is decided on the │ record, the debarment decision is due within 45 days of the record closing, │ extendable for good cause. Where a suspension IS in effect, the clock in this │ stage does not bind — the company stays excluded while the official takes │ longer. │ For a debarment not based on a conviction or judgment, cause "must be │ established by a preponderance of the evidence." For a suspension the standard │ never rises above "adequate evidence." │ ◈ A suspension may be modified, terminated, or left in force — and termination │ is "without prejudice" to a later suspension or debarment by ANY agency. A │ company that wins is not cleared; it is returned to the queue. │ │ ──▶ │ ■ 6. THE EXCLUSION, GOVERNMENT-WIDE AND IMMEDIATE (FAR 9.404 · 9.405) ✕ ⚑ │ § One agency's decision binds the whole executive branch. A debarment or │ proposed debarment "shall be effective throughout the executive branch of the │ Government." Agencies "shall not solicit offers from, award contracts to, or │ consent to subcontracts with these contractors." │ ☐ The record goes into the exclusions section of the System for Award │ Management within 3 working days of the action taking effect, carrying the │ agency, the cause, the effect and the termination date. Contracting officers │ must re-check it before award. │ What the exclusion reaches, beyond new prime contracts: │ · the company may not act as an agent or representative of another contractor │ in dealings with the government │ · it may not act as an individual surety │ · its bids are rejected and its proposals are not evaluated — no discussions │ are even held — absent a written compelling-reason determination │ · other contractors are barred from subcontracting with it above $45,000 │ · ordering activities may not place new orders, place schedule orders, or add │ work or options under existing vehicles │ └─▶ ◎ THE ONE DOOR THAT STAYS OPEN: the agency head, or a designee, may state │ in writing a COMPELLING REASON to keep dealing with an excluded company. │ Existing contracts also continue by default "unless the agency head directs │ otherwise." So the instrument that binds every agency at once can be │ unbound, one agency at a time, by one official with a memo. │ ⊘ No public source found in this survey counts how often that happens. │ │ ──▶ │ ■ 7. HOW LONG (FAR 9.406-4 · 9.407-4) ☐ § │ ├─◆ SUSPENSION — THE ONLY HARD CEILING IN THE SUBPART │ ☐ If legal proceedings are not begun within 12 MONTHS of the suspension notice, │ the suspension "shall be terminated" — unless a prosecuting office asks for │ more, in which case it "may be extended for an additional 6 months." │ ☐ "In no event may a suspension extend beyond 18 months, unless legal │ proceedings have been initiated within that period." │ § The suspending official must notify the Justice Department or the responsible │ prosecutor at least 30 days before the 12 months run out, so that office can │ ask for the extension. The deadline comes with a built-in reminder to the │ party most likely to want it extended. │ ◈ AND THERE THE CEILING STOPS. Once proceedings are begun inside the 18 months, │ the suspension runs "pending the completion of an investigation and any │ ensuing legal proceedings," with no further outer limit written anywhere. The │ temporary instrument becomes open-ended at the moment a case is filed. │ └─◆ DEBARMENT — A PRESUMPTION, NOT A LIMIT ☐ "Generally, debarment should not exceed 3 years," and must be "commensurate with the seriousness of the cause(s)." Three statutory departures: · drug-free workplace violations — up to 5 years · immigration-law determinations by Homeland Security or the Attorney General — 1 year, extendable in further one-year periods, and that determination "is not reviewable in the debarment proceedings" · false arms-control certifications — NOT LESS THAN 2 years, a floor rather than a ceiling, counting any suspension already served ☐ Time served under a suspension counts toward the debarment period. ◈ Both directions are open afterwards. The official MAY EXTEND a debarment to protect the government's interest — but "may not be extended solely on the basis of the facts and circumstances upon which the initial debarment action was based," so an extension needs something new. And the official MAY REDUCE it on the company's documented request: newly discovered evidence, a reversed conviction, or "a bona fide change in ownership or management." ⚑ That last clause is the most consequential sentence in the stage. Debarment attaches to present responsibility, and present responsibility can be acquired by replacing the people who lacked it. A change of management is a route out that a fine or a prosecution has no equivalent of. │ │ ──▶ │ ■ 8. THE FOUR EXITS, AND THEY ARE NOT EQUIVALENT (FAR 9.406-3(f)-(g) · 9.406-4) │ ├─◆ 8a. THE PERIOD EXPIRES ──▶ the SAM record carries a termination date; the │ company becomes eligible again with no further decision required. ├─◆ 8b. REDUCTION OR EARLY TERMINATION ──▶ the official shortens it on request │ (stage 7), or terminates a suspension outright — without prejudice. ├─◆ 8c. VOLUNTARY EXCLUSION ──▶ the company agrees to be excluded rather than │ litigate. § It "must have Governmentwide effect," and it is entered in the │ EXCLUSIONS SECTION OF SAM. 15 government-wide in FY2023. └─◆ 8d. ADMINISTRATIVE AGREEMENT ──▶ ⚑ ★ the negotiated settlement in which the company accepts compliance obligations — monitors, certifications, reporting — and is NOT suspended and NOT debarred. It keeps selling. 47 entered by 10 agencies in FY2023, against 1,009 debarments. ◈ This is the outcome a well-advised large contractor is working toward from the first notice, and the only exit that leaves the customer relationship intact. │ │ ──▶ │ ■ 9. WHO CAN SEE IT (FAR 9.404 · 9.406-3(f) · 41 U.S.C. § 2313) ⚑ ◈ ≠ │ The four exits land in two different databases with two different readerships, │ and this is the sharpest asymmetry on the page. │ ├─◆ SUSPENSIONS · DEBARMENTS · VOLUNTARY EXCLUSIONS ──▶ the exclusions section of │ the System for Award Management. Agency, cause, effect, termination date. This │ is the list every contracting officer must check, and it is the list that makes │ an exclusion a public fact. │ └─◆ ADMINISTRATIVE AGREEMENTS ──▶ the Federal Awardee Performance and Integrity Information System, reached through the contractor performance reporting system, within 3 working days. § The filing is not discretionary. Congress required it: the database must include "each Federal administrative agreement entered into by the person and the Federal Government" to resolve a suspension or debarment proceeding. (41 U.S.C. § 2313(c)(4)) ⚑ AND THE READERSHIP IS NOT THE PUBLIC. The current statute makes the database available to acquisition officials of federal agencies, to other government officials as the General Services Administration determines appropriate, and on request to the chairman and ranking member of the relevant congressional committees. It contains no public-access provision. (§ 2313(e)(1)) [ The predecessor statute did. Former 41 U.S.C. § 417b directed that the information be posted, "excluding past performance reviews, on a publicly available Internet website." That language survives in the current code only as an editorial note to the section that replaced it. ] ◈ So the exit that ends the relationship is published, and the exit that preserves it is filed where the public has no statutory right to look. The 47 agreements of FY2023 are known as a COUNT, from the committee's report to Congress, and not as DOCUMENTS. │ │ ──▶ │ ■ 10. ⊘ CAN THE COMPANY SUE — AND THE HONEST ANSWER IS PARTLY UNSETTLED │ Yes, and the route is sixty years old: a debarment is reviewable under the │ Administrative Procedure Act. [ Gonzalez v. Freeman, 334 F.2d 570 (D.C. Cir. │ 1964). ] Courts have also set a due-process floor: absent an indictment, a │ hearing should follow a suspension within thirty days [ Horne Bros. v. Laird, │ 463 F.2d 1268 (D.C. Cir. 1972) ], and an agency that excludes a company in │ practice without saying so owes it notice of the charges [ Old Dominion Dairy │ Prods. v. Sec'y of Def., 631 F.2d 953 (D.C. Cir. 1980) ]. │ ⊘ THREE THINGS THIS MAP DOES NOT ASSERT, BECAUSE THEY COULD NOT BE ESTABLISHED │ TO TWO SOURCES HERE: │ · WHICH COURT. Challenges have been entertained in federal district court │ and in the Court of Federal Claims, and the sources surveyed do not │ establish an exclusive forum. [ District court: Agility Defense & Gov't │ Servs. v. DoD (N.D. Ala. 2012), rev'd, 739 F.3d 586 (11th Cir. 2013); │ Friedler v. GSA (D.D.C. 2017). Court of Federal Claims: Inchcape Shipping │ Servs. Holdings v. United States, No. 13-953 (Fed. Cl. 2 Jan. 2014). ] │ · THE STANDARD. The Administrative Procedure Act confines a reviewing court │ to "the whole record or those parts of it cited by a party" and permits │ fresh factfinding only where a statute provides for trial de novo — and │ no statute provides for one here. (5 U.S.C. § 706) Whether and how │ closely courts in fact scrutinise these decisions is contested in the │ literature and is not settled on this page. │ · HOW OFTEN IT WORKS. No source found in this survey publishes a rate at │ which suspensions or debarments are overturned. The government counts the │ actions it takes and nobody appears to count the ones that do not hold. │ ■ 11. ≠ THE MIRROR, WHICH IS WHY THIS PAGE EXISTS │ The same alleged fraud, two parties, two procedures. │ │ THE EMPLOYEE WHO REPORTS IT │ THE COMPANY ACCUSED OF IT │ (41 U.S.C. § 4712) │ (FAR Subpart 9.4) │ ───────────────────────────────────────┼──────────────────────────────────────── │ § an inspector general MUST │ ◎ one agency employee, no fixed term, │ investigate │ decides alone │ ☐ 180 days to a determination or │ ☐ 30 days to write a letter │ report, extendable by agreement │ │ § agency head must decide within 30 │ ◇ a hearing only if the action rests │ days of the report │ on no court finding AND the letter │ │ raises a genuine factual dispute │ ☐ after 210 days, remedies are deemed │ ✕ for a suspension, prosecutors can │ exhausted and the courthouse opens │ close even that door │ ★ a DE NOVO action in federal district │ ⊘ review exists; the forum and the │ court — "shall, at the request of │ standard are unsettled, and the │ either party, be tried by the court │ success rate is uncounted │ with a jury" │ │ ☐ 3 years to complain · 2 years to sue │ ◈ exclusion begins before any of it │ │ │ ◈ The asymmetry is not an accident of drafting. The employee's remedy is a │ statute Congress wrote to create a private right of action. The company's │ is a regulation the executive branch wrote to protect its own purchasing. │ One is designed to be used by the party it protects; the other is designed │ to be used ON the party it binds. │ ■ 12. WHAT IS PENDING [ as of 10 November 2026 ] │ Subpart 9.4 is inside the government-wide rewrite of the acquisition rules. The │ proposal for Part 9 was published on 18 September 2026 and comments closed on │ 19 October 2026. For a reader the two things worth knowing are: │ ☐ IT KEEPS THE SUBPART. Debarment, suspension and ineligibility survive the │ rewrite with their section numbers, and the preamble says the Part 9 │ streamlining does "not substantively change policy or procedures in the │ part." The deadlines, periods and procedures mapped above are the current │ rules and are proposed to stay. │ ◈ IT ADDS A CAUSE. The proposal would make non-compliance with a new clause │ on diversity-related discrimination by federal contractors a cause for both │ debarment and suspension, inserted into the lists at stage 0. │ [ FAR Case 2026-011, RIN 9000-AO84, 91 Fed. Reg. 59584 (18 Sept. 2026), │ proposed rule; the added cause implements Executive Order 14398 of 26 March │ 2026, 91 Fed. Reg. 16147 (31 Mar. 2026). A proposed rule is not law; no │ final rule had issued as of this page's date. ] │ │ Legend, restated: │ ──▶ main path └─▶ branch or bypass ◇ decision point │ ✕ out of federal work ★ the step that decides it │ ⚑ load-bearing stage, where the attrition is │ ☐ a deadline or period the company can count in advance │ ◎ one agency employee decides alone, with no hearing and no vote │ § the rule is in statute, not the regulation │ ⊘ a right that exists on paper and that no public source counts │ ◈ a consequence written in no rule │ ≠ two parties to one contract, given unequal process │ [ ] a dated note or caveat ``` ## Notes - **Officeholders.** This map names no individuals and no current officeholders. Every stage is an office, a standard of proof, a deadline or a database, so nothing on it turns over with an election or a resignation. - **Which text governs.** The regulation quoted throughout is the current Federal Acquisition Regulation as published by the councils that write it, at Federal Acquisition Circular 2026-01, effective 13 March 2026. Individual agencies have issued their own deviations from Part 9 during the ongoing rewrite, so a company's actual procedure in a given case may differ from the codified text in details this map does not reach. - **The 2025 consolidation.** A final rule effective 17 January 2026 aligned the procurement procedures with the parallel rules for grants: it merged the separate "debarring official" and "suspending official" into a single suspending and debarring official, defined that office in the regulation's general definitions, and set out the optional pre-notice letter. It did not change the three-year presumption or the suspension ceilings. The rule is identified as FAR Case 2019-015; it was proposed in January 2024 and published as final on 3 January 2025. - **The scale figures.** Every count in the chart's scale block comes from one document: the Interagency Suspension and Debarment Committee's report to Congress for fiscal year 2023, required by Section 873 of the National Defense Authorization Act for Fiscal Year 2009, transmitted 31 December 2024. It covers the 24 agencies subject to the Chief Financial Officers Act. It was the most recent report in the committee's published archive as of this page's date, which means the newest government-wide figures available to a reader are three fiscal years old. - **A second, older count, for direction rather than level.** A 2018 law-review treatment reports committee proceedings rising from 1,585 in 2010 to 2,938 in 2014 and then flattening at 2,791 in 2015. That is a different measure from the figures above and the two should not be added or compared directly; it is cited here only because it is the one published series that shows a trend. - **What a "proposed" debarment does.** The single most common misreading of this subpart is that a proposed debarment is a warning. It is not: the exclusionary effect attaches on the proposal. The optional pre-notice letter is the step that genuinely excludes nobody, and in fiscal year 2023 it was used about once for every twelve proposed debarments. - **The indictment double-counting.** It is worth stating plainly because it is easy to miss across two stages: an indictment is sufficient evidence to impose a suspension, and an indictment-based suspension is also exempt from the fact-finding procedure. The same document opens the exclusion and closes the hearing. - **Where the administrative agreements are, and are not.** The statute requires each agreement resolving a suspension or debarment proceeding to be entered in the integrity database, and the statute's list of who may read that database does not include the public. The repealed predecessor statute had directed public posting. Whether any given agreement can in practice be obtained — by a records request, or because an agency chooses to publish it — is not established by the statute or the regulation and is not asserted here. - **Judicial review is the weakest-sourced part of this map, deliberately.** The reviewability of a debarment under the Administrative Procedure Act rests on a 1964 decision that later sources treat as settled. The forum question does not: challenges appear in both the district courts and the Court of Federal Claims, and the two secondary treatments consulted — a Congressional Research Service legal overview whose latest revision is 27 May 2015, and a 2018 law-review essay — disagree in emphasis about how deferential courts are, with the essay arguing the standard is "in flux." Both predate the current regulation. A reader who needs the answer for a live matter should not take it from this page. - **Nobody publishes a reversal rate.** The government counts referrals, suspensions, proposed debarments, debarments, declinations, voluntary exclusions and administrative agreements. No source found here counts how many of those actions were set aside, narrowed or abandoned in litigation. That absence is structural rather than accidental: the counting body is the committee of the officials who take the actions, and its statutory reporting duty is to report activity. - **Dollar thresholds.** The $45,000 subcontract threshold and the $10,000 delinquent-tax threshold are the figures in the current regulation. Thresholds of this kind are adjusted for inflation periodically and should be read against the regulation rather than quoted from here if the exact number matters. - **A transcription oddity in the source.** The delinquent-tax cause renders the threshold as "$10;000" in the regulation as published online, in both the debarment and suspension cause lists. The intended figure is ten thousand dollars. ## See also - [[Federal Whistleblower Protection Crosswalk]] — the other side of the mirror at stage 11, and the page this one was built against: what the employee who reports the conduct gets, forum by forum. - [[Deferred and Non-Prosecution Agreement Crosswalk]] — the criminal-law analogue of the administrative agreement at stage 8d. A company facing both tracks is often negotiating two settlements at once, with different officials, on different standards, and only one of them published. - [[Present Responsibility]] — the doctrinal test the whole subpart turns on, and the reason a change of management is a route out. - [[Administrative Agreement]] — the instrument at stage 8d. - [[System for Award Management]] — the public exclusion list at stages 6 and 9. - [[Federal Awardee Performance and Integrity Information System]] — the restricted database at stage 9, and the asymmetry the map is built around. - [[Interagency Suspension and Debarment Committee]] — the coordinating body at stage 1 and the source of every scale figure on the page. - [[Federal Acquisition Regulation]] — the rulebook Subpart 9.4 sits in, and the rewrite described at stage 12. - [[False Claims Act]] — the statute behind the disclosure duty at stage 0(b)(vi), and the one that lets a private party sue on the government's behalf for the same conduct. - [[Inspector General]] — the office that investigates both the company and the employee's reprisal complaint. - [[Merit Systems Protection Board]] — the forum a federal employee uses, and the contrast that makes the contractor employee's district-court route unusual. - [[How an Inspector General Is Appointed and Removed]] — how secure the office at stage 11 is. - [[Agency Head Removal Protections Crosswalk]] — the tenure question at stage 1, asked of agency heads; the suspending and debarring official has no answer to it at all. - [[GSA]] — the agency that runs both databases at stage 9. - [[Federal Agencies Hub]] · [[Oversight and Accountability Hub]] · [[Foundations Hub]]