I recently co-authored an article with my former colleagues at Crowell & Moring, Angela Styles, Peter Eyre and Jason Crawford, reviewing how a notice of proposed debarment under the procurement regulations came to have the same impact as a suspension. In the article we suggest that agencies increase the use of show cause notices, and that consideration be given to amending the procurement regulations so that a notice of proposed debarment no longer triggers a government-wide exclusion.
The article, “How Proposed Debarment Became Equal to Suspension,” was published on February 2 on Law360.