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Understanding Procurement-Based Suspension and Debarment in Federal Contracting
Holland & Knight – Federal contractors face few threats more serious than suspension or debarment. This exclusionary action has become more prevalent during the Trump Administration. For example, at the end of 2025, the U.S. Small Business Administration (SBA) suspended nearly 7,000 Minnesota borrowers for “suspected fraudulent activity.” A few weeks later, the U.S. Department of War announced a review of small business set-aside contractors of more than $20 million. Understanding the procurement suspension and debarment regime is crucial for contractors to protect their eligibility for federal contracts and avoid exclusion that can have immediate and long-lasting business consequences.