On March 31, 2015, the Interagency Suspension and Debarment Committee (“ISDC”) released its report to Congress detailing federal suspensions and debarment actions for fiscal year 2014. From 2013 to 2014, federal agencies in aggregate increased their use of exclusion actions. The number of persons and entities proposed for debarments jumped from 2,229 to 2,241, and suspensions increased from 887 to 1,009. Even after considering the ISDC’s counting conventions, the numbers show an upward trend in agency enforcement.

Although the ISDC notes that the overall number of suspensions and debarments is not a measure of success, the increase in enforcement correlates with the improvement of agency suspension and debarment programs. The ISDC report cites the Government Accountability Office’s findings, which indicate newly active suspension and debarment programs within six agencies. Intra-agency referrals to suspending and debarring officials are more effectively supported now than they have been in the past.

The ISDC also articulated the steps it plans to undertake to strengthen agency suspension and debarment programs, including:

  • Adding a third vice chair to the ISDC to increase agency involvement
  • Liaising with the Council of Inspectors General for Integrity and Efficiency
  • Emphasizing training on suspension and debarment practices, with a view toward promoting greater procedural consistency
  • Helping agencies consider the use of administrative agreements, as an alternative to suspension and debarment
  • Making outreach efforts with congressional staffers, industry, academia, and public interest groups
  • Improving ISDC’s new public website

Given these trends, federal contractors should ensure that their compliance efforts meet the pace of enforcement.