The Federal Program Integrity and Fraud Prevention Act of 2025 adds a new section to Title 41 that requires the Attorney General to notify GSA when an individual is convicted of certain specified federal felonies tied to federal contracts, grants, loans, or other assistance. On notification, GSA must enter the individual as an excluded source in the System for Award Management (SAM) for a presumptive three‑year period; agency heads may grant written exemptions and must transmit those exemptions to Congress immediately.
This bill matters because it operationalizes an individual‑level, near‑automatic exclusion route in procurement law rather than relying solely on existing suspension and debarment procedures. The measure broadens the definition of “convicted” to capture pleas and deferred adjudications and creates near‑immediate compliance and screening obligations for federal procurement officials, contractor compliance teams, and GSA/DOJ operational units.
At a Glance
What It Does
The bill adds §4715 to Title 41 directing the Attorney General to notify GSA of covered felony convictions connected to federal awards; upon notification GSA must promptly enter a three‑year exclusion in SAM. Agency heads can issue written waivers but must send copies to Congress immediately.
Who It Affects
Federal procurement officials, GSA/SAM administrators, DOJ criminal units, contractor hiring and compliance teams, and individuals convicted (including those in deferred‑adjudication programs) of the listed federal offenses tied to federal funding.
Why It Matters
It creates a statutory shortcut for removing individuals from the federal awards ecosystem and names a broad set of fraud and financial crime statutes as automatic triggers, raising screening, background‑check, and program‑integrity implications across the federal supply chain.
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What This Bill Actually Does
The bill inserts a new statutory tool into federal procurement law: when an individual is convicted of certain enumerated federal felonies that arise out of an agency contract, grant, cooperative agreement, loan, or other financial assistance, the Attorney General must tell the General Services Administration (GSA). Once notified, GSA is required to enter that individual on the System for Award Management (SAM) Exclusions list for a three‑year prohibition on serving as a source for federal awards.
The text treats a range of courtroom outcomes as “convicted,” including accepted guilty pleas and deferred adjudication arrangements.
The statute names a long list of covered offenses — multiple fraud and financial crime provisions in Title 18 (for example, mail and wire fraud, bank fraud, bribery, false statements, identity crimes, money laundering, and similar offenses) and a provision of the Small Business Act — that will, when tied to federal funds, trigger this exclusion pathway. The exclusion is individual‑focused: it targets people rather than automatically debarring or suspending companies, though the law explicitly preserves agencies’ ability to pursue suspension, debarment, or civil remedies in parallel.Agency heads retain a narrow escape hatch: they may grant a written exemption for a particular individual, but the bill requires the agency head to transmit that written exemption to Congress immediately after the determination.
The law also instructs the Attorney General, in consultation with the GSA Administrator, to issue implementation guidance within one year — meaning DOJ and GSA will set operational rules for notification timing, data sharing, and how SAM entries should be handled.Practically, the provision forces changes in three operational areas. First, DOJ must build or use processes to identify qualifying convictions and notify GSA “in a timely manner.” Second, GSA must ensure SAM has procedures to accept, flag, and publish individual exclusions and link them to procurement vetting.
Third, contracting officers and contractor compliance teams will need to incorporate this new exclusion list into existing source‑selection and personnel screening workflows and reconcile it with FAR/2 CFR suspension and debarment authorities.
The Five Things You Need to Know
The bill creates a new §4715 in Title 41 that directs DOJ to notify GSA of qualifying convictions and requires GSA to enter a 3‑year exclusion in SAM for the individual.
The statute enumerates the triggering crimes by citation: 18 U.S.C. §§ 286, 287, 371, 641, 666, 1001, 1014, 1017, 1028, 1028A, 1030, 1031, 1040(a)(2), 1341, 1343, 1344, 1345, 1349, 1956, 1957, and section 16 of the Small Business Act (15 U.S.C. 645).
The bill defines “convicted” to include judgment, finding of guilt, acceptance of guilty or nolo contendere pleas, and deferred programs such as first‑offender or deferred adjudication where judgment was withheld.
Agency heads may waive the exclusion on a case‑by‑case basis, but the waiver must be in writing and a copy must be transmitted to Congress immediately after the determination.
The Attorney General, in consultation with GSA, must issue implementation guidance within one year of enactment to govern DOJ‑GSA notification and compliance with §4715.
Section-by-Section Breakdown
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Short title
Names the Act the “Federal Program Integrity and Fraud Prevention Act of 2025.” This is a standard drafting device but signals the bill’s focus on program integrity and fraud prevention as a statutory procurement tool.
Automatic SAM exclusion for covered felony convictions
Establishes the core prohibition: individuals convicted of a “covered felony” arising out of federal awards must be identified as excluded sources in SAM. Practically, the subsection places a statutory obligation on DOJ to notify GSA and on GSA to enter a presumptive three‑year prohibition for such persons. The requirement applies to crimes connected to contracts, grants, cooperative agreements, loans, or other financial assistance, which makes the causal link between the offense and federal funding a jurisdictional trigger.
Agency waiver and congressional notice
Gives agency heads authority to exempt an individual from the exclusion if the agency head determines, in writing, that an exemption is warranted. The written exemption must be transmitted to Congress immediately. That combination—broad waiver power but immediate congressional reporting—creates a high‑visibility exception process that agencies will need to document carefully.
Definitions, including a broad definition of 'convicted'
Defines key terms: “agency” follows Title 5 definitions; “convicted” covers formal convictions as well as accepted pleas and deferred adjudication arrangements; and “covered felony” is a list of specified federal statutes (fraud, false statements, identity crimes, money laundering, bribery, certain computer crimes, and a Small Business Act provision). The inclusion of deferred and withheld judgments is a practical enlargement of the class of individuals who can be excluded.
Rules of construction preserving other remedies
Clarifies that nothing in §4715 prevents agencies from pursuing other criminal, civil, or administrative remedies, including suspension and debarment under existing FAR and 2 CFR authorities. It also states that subsection (b) does not affect other statutory or regulatory waiver authorities related to exclusions, preserving existing legal pathways while adding this statutory mechanism.
Update to chapter table of sections
Adds §4715 to the chapter table of sections in Title 41. This is a non‑substantive organizational step but ensures the new provision is indexed in statutory tables.
Guidance requirement
Requires the Attorney General, in consultation with the GSA Administrator, to issue guidance within one year for implementation and compliance with §4715. That guidance will be the practical rulebook for notification timing, data formats, confidentiality and privacy considerations, and how SAM entries should be made and maintained.
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Who Benefits
- Federal program and procurement offices — gain a statutory, individual‑level exclusion tool to remove people who commit fraud from participating in federal awards, improving program integrity.
- Taxpayers and program beneficiaries — benefit indirectly from a mechanism designed to reduce the risk that individuals who committed award‑related felonies will continue to access Federal funds.
- GSA and SAM managers — receive a clear statutory directive to maintain an individual exclusion feed, which standardizes a detection and removal pathway across agencies.
- Contractor compliance and risk teams — obtain a defined list and process to incorporate into pre‑award and personnel screening, reducing uncertainty about which offenses trigger exclusion.
Who Bears the Cost
- Contractors and subcontractors — face higher compliance and hiring costs to screen candidates and manage personnel churn when key employees become ineligible under SAM.
- Small businesses and firms relying on a small number of key personnel — may lose access to federal work if a single individual is excluded and the firm cannot quickly replace or restructure roles.
- DOJ and GSA operational units — must build processes and systems for timely conviction notifications, data sharing, and SAM record maintenance, creating administrative burdens and potential resource needs.
- Individuals subject to deferred adjudication or negotiated dispositions — may face exclusion even where courts withheld judgment, raising rehabilitation and employment‑access costs for those persons.
Key Issues
The Core Tension
The central dilemma is between strengthening program integrity by rapidly removing individuals convicted of award‑related felonies from the federal awards ecosystem and preserving proportionality, due process, and rehabilitation pathways for those individuals—especially when convictions include deferred or withheld judgments and agencies must make rapid, high‑stakes eligibility decisions with limited procedural guardrails.
The bill packs several implementation and policy challenges into a short statute. First, the decision to treat deferred adjudication and withheld judgments as “convictions” broadens the pool of individuals eligible for exclusion in ways courts or sentencing regimes may not have anticipated; agencies will need clear standards for when a judicial disposition truly “arises out of” a federal award.
Second, the statute overlaps with existing suspension and debarment authorities (FAR subpart 9.4 and 2 CFR part 180) without establishing how the new SAM entry should interact operationally with those processes — for example, whether an individual excluded under §4715 remains eligible for administrative appeals under those regimes, or how penalties and remedies stack.
Operationally, the statute expects timely and reliable data flows between DOJ and GSA but provides no funding or technical specifications; divergent practices across U.S. Attorneys’ offices could produce inconsistent notification timing. The immediate congressional notice requirement for waivers creates transparency but may politicize case‑by‑case decisions and disincentivize agencies from granting necessary exceptions.
Finally, the bill is silent on procedures for individuals to challenge an exclusion created under §4715 (timing of removal, appeals, or impact of expungement or vacated convictions), which creates legal and compliance uncertainty for employers and contracting officers.
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