October 2, 2022

Volume XII, Number 275

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September 30, 2022

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September 29, 2022

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Suspension & Debarment Annual Report: Key Takeaways

The Interagency Suspension and Debarment Committee (ISDC) recently issued its annual report to Congress on federal government suspension and debarment activities for fiscal year (FY) 2020. Key takeaways from the year’s ISDC report are discussed below.

What is the ISDC Suspension and Debarment Report?

Created by Executive Order 12549, the ISDC is an interagency body “consisting of Federal agencies that pool resources, experience, and promising practices to provide support for suspension and debarment programs throughout the Federal Government.” Section 873 of Public Law 110-417 requires the ISDC to submit an annual report to Congress on, among other things, “the progress and efforts to improve the suspension and debarment system” and “a summary of each agency’s activities and accomplishments in the Government debarment system.”

What are the key takeaways from this year’s report?

As the following chart from the ISDC report shows, agencies reported issuing 415 suspensions, 1,317 proposed debarments, and 1,256 debarments government-wide in FY 2020, “notwithstanding the COVID-19 pandemic and dispersed, remote, or socially distanced workforce.”

By comparison, federal agencies initiated a total of 3,358 suspension and debarment-related actions in FY 2019 (722 suspensions, 1,437 proposed debarments, and 1,199 debarments).

In FY 2020, federal agencies also reported a total receipt of 2,446 referrals and the issuance of 183 declinations government-wide. Agencies also reported an approximately 20% increase in total post-notice engagements with respondents from FY 2019.

Finally, the report notes that for FY 2020 federal agencies reported entering into 58 administrative agreements, which are used as an alternative to suspension and debarment and typically mandate the implementation of measures to improve the ethical culture and corporate governance of a respondence. By comparison, for FY 2019 federal agencies reported entering into 54 administrative agreements.

© 2022 Bradley Arant Boult Cummings LLPNational Law Review, Volume XII, Number 152
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About this Author

Aron C. Beezley Government Contracts Attorney Bradley D.C.
Partner

Aron Beezley is the co-leader of Bradley’s Government Contracts Practice Group. Ranked nationally in Government Contracts Law by Chambers in 2019-2021, named one of the “Top Attorneys Under 40” nationwide in Government Contracts Law by Law360 in 2016-2017, and listed in Washington, D.C. Super Lawyers as a “Rising Star” in Government Contracts Law in 2014-2021, Aron’s vast experience includes representation of government contractors in numerous industries and in all aspects of the government-contracting process, including negotiation, award,...

202-719-8254
Nathaniel J. Greeson Government Contracts Lawyer Bradley Law Firm
Associate

Nathaniel Greeson helps clients solve government contracts challenges. Nathaniel represents clients in a range of government procurement issues, including bid protests, claims, disputes, audits and investigations. He has extensive experience with GAO bid protests, agency-level protests, Court of Federal Claims (COFC) bid protests, and SBA OHA size and NAICS appeals, as well as experience with agency-level requests for equitable adjustments (REA) and claims, and Boards of Contract Appeals claims.

Nathaniel advises government contractors on compliance issues, prime/subcontractor...

202.719.8202
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