Think Only DOJ Can Debar You? Think Again—Here’s Who Can Actually Block You from Federal Contracts or Grants
If you’ve received a notice about potential debarment, one of the first questions you’re likely asking is: Who exactly has the authority to do this? You may be surprised to learn that many different federal agencies have the power to suspend or debar individuals and companies from participating in federal programs or contracts.
Whether you’re a contractor, grantee, or even an individual consultant, it’s critical to understand who can issue a debarment—and how to respond. At National Security Law Firm (NSLF), we defend clients nationwide against all types of debarment actions.
In this guide, we break down which federal agencies can debar you, what that process looks like across agencies, and how to protect your future.
What Is Debarment?
Debarment is an administrative exclusion—not a criminal punishment—that prevents you from doing business with the federal government. It can apply to contracts, grants, loans, cooperative agreements, and more.
It is typically issued by a federal agency’s Suspending and Debarring Official (SDO) under:
- FAR Subpart 9.4 (for procurement)
- 2 C.F.R. Part 180 (for nonprocurement)
Which Agencies Can Debar You?
Here’s a breakdown of some of the most common federal agencies that issue debarments:
1. Department of Defense (DoD)
DoD has a highly active debarment program. They can debar:
- Defense contractors and subcontractors
- IT firms, logistics providers, manufacturers
Common grounds:
- Procurement fraud
- False Claims Act violations
- Security breaches
2. Department of Homeland Security (DHS)
DHS oversees immigration, border security, and cybersecurity. Its components—like FEMA and ICE—regularly issue debarments.
Common targets:
- Disaster recovery contractors
- Security vendors
- Construction companies
3. Department of Health and Human Services (HHS)
HHS can debar:
- Healthcare providers
- Pharmaceutical companies
- Research institutions
Common reasons:
- Medicare/Medicaid fraud
- Misuse of grant funds
- Scientific misconduct in research
4. Small Business Administration (SBA)
The SBA may debar:
- 8(a) program participants
- HUBZone businesses
- Loan recipients
Grounds for action:
- Misrepresentation of small business status
- Defaulting on SBA loans
- Violations of program terms
5. Department of Veterans Affairs (VA)
The VA issues debarments involving:
- Healthcare providers
- Veteran-owned small businesses
Common issues:
- False claims
- Unethical conduct in healthcare delivery
- Service-disabled veteran-owned business fraud
6. Environmental Protection Agency (EPA)
EPA can debar:
- Environmental contractors
- Clean-up firms under Superfund
- Nonprofits and municipalities
Frequent reasons:
- Environmental law violations
- Performance failure
- Misuse of grants or cooperative agreements
7. General Services Administration (GSA)
GSA serves as a centralized procurement agency and can debar for issues related to federal supply schedules, real estate, and tech services.
What’s the Process Like Across Agencies?
Each agency has its own internal procedures, but the core steps are similar:
- Investigation or referral (often from IG, DOJ, or internal audit)
- Notice of Suspension or Proposed Debarment issued by the SDO
- 30-day window to respond with evidence and mitigation
- Optional oral presentation or negotiation
- Final decision: debarment, administrative agreement, or no action
Can One Agency’s Debarment Affect Others?
Yes. Many agencies honor each other’s debarments through a system called reciprocal exclusion. Once you’re listed on SAM.gov Exclusions, all federal agencies may bar you from receiving contracts or assistance.
That’s why even a “small” debarment can have huge ripple effects.
How Much Does a Debarment Defense Lawyer Cost?
At NSLF, we believe legal defense should be clear and affordable. That’s why we offer flat-fee pricing:
- $5,000: Written-only response package (review, strategy, submission)
- $7,500: Hearing representation (if required, most (but not all) cases do not require a hearing) (includes travel)
We also offer legal financing through Pay Later by Affirm, allowing you to break up fees over 3–24 months.
Why Choose NSLF?
We are a national leader in debarment defense—and we’ve helped clients respond to actions by nearly every major federal agency. Clients trust us because we offer:
- 4.9-star Google reviews
- Attorneys who are former federal prosecutors, agency lawyers, and military JAGs
- Deep experience with agency culture and legal strategy
- Based in Washington, DC, where many SDOs are located
- Weekly Attorney Review Board meetings for added brainpower
- Experience with overlapping legal issues: FOIA, security clearance, employment law
- We hold security clearances and work on classified matters when needed
- Founded by disabled veterans, mission-driven to protect careers and businesses
We defend contractors, grantees, researchers, healthcare providers, universities, and more.
Additional Resources
Looking for more guidance? Our Debarment Defense Practice Page is your go-to starting point.
There, you’ll find a variety of helpful resources covering everything from the most common mistakes that lead to debarment, to the legal strategies that actually work in defending against it. We also share insights on how our attorneys build strong defenses, what steps you can take to improve your chances of success, and how to maximize the outcome of your case.
Whether you’re just learning about the process or actively fighting a proposed debarment, we’ve got you covered.
Don’t Let One Notice Ruin Your Federal Career—Take Action Now
Every agency has its own process, and every debarment case is different—but the window to respond is always short. If you’ve been contacted by any federal agency about a proposed debarment, you need to act now.
NSLF can help you identify the issues, draft a powerful response, negotiate directly with the SDO, and protect your future.
Book a free consultation right now—no receptionist, no delay. Just pick a time online and speak directly with an attorney.
