Confirm FAR 9.405 determinations for awards made during an exclusion.
The dataset shows 1 VA awards first actioned inside a SAM.gov exclusion period for the same party (1 matched by UEI, 0 by name and state only), totalling $60K. Awards to excluded parties require a written compelling-reason determination; name-only matches may be different firms. The recommendation is grounded in 1 pattern-detector match across the VA award data. Each cited match links back to specific source records, so every dollar in the headline can be re-added from them. Dollars are obligations on the cited records, not estimated losses.
Net obligations involved is the sum of the cited matches' obligations (commitments recorded on USAspending.gov). It is the scale of the records to review, not an estimate of loss, improper payment or recoverable money; totals across recommendations can overlap.
Risk overview
Eligibility, exclusion and registration requirements (38 U.S.C. 8127, FAR 9.405, FAR 4.1102) apply at award; an unexplained gap is a question for the contract file, and any resulting improper payment would be reportable under the Payment Integrity Information Act.
The later a gap is found, the harder it is to remedy through options, terminations or recoveries.
Awards to ineligible or excluded parties in veteran programs draw sustained oversight attention.
Justification & audit trail
1 cited match · $60K in net obligations involved
The dataset shows 1 VA awards first actioned inside a SAM.gov exclusion period for the same party (1 matched by UEI, 0 by name and state only), totalling $60K. Awards to excluded parties require a written compelling-reason determination; name-only matches may be different firms. The recommendation is grounded in 1 pattern-detector match across the VA award data. Each cited match links back to specific source records, so every dollar in the headline can be re-added from them. Dollars are obligations on the cited records, not estimated losses.
- match_basisUEIsource: sam.exclusion
- exclusion_period1989-10-24 → indefinitesource: sam.exclusion
- obligated_total$60Ksource: app.award_current
| Source | Row | Field | Value |
|---|---|---|---|
| sam.exclusion | CONT_AWD_VA553EXPRESSPROSACTONRENTALSFY11_3600_-NONE-_-NONE- | match_basis | UEI |
| sam.exclusion | CONT_AWD_VA553EXPRESSPROSACTONRENTALSFY11_3600_-NONE-_-NONE- | exclusion_period | 1989-10-24 → indefinite |
| app.award_current | CONT_AWD_VA553EXPRESSPROSACTONRENTALSFY11_3600_-NONE-_-NONE- | obligated_total | 60,000 |
Timeline & dependencies
- D+14Audit committee briefed
- D+45Evidence pack assembled
- D+90Decision recorded
Calibrated next steps
- 01For UEI matches, locate the compelling-reason determination in the contract file or document why the exclusion did not apply.
- 02For name-only matches, confirm or rule out identity using CAGE code and address before any further action.