Alpha Covenant Holdings · Duty Sheet · generated 2026-10-25 16:55 UTC · free · all sheets

FAR 52.204-25 / 52.204-24 / 52.204-26 — Section 889 covered telecommunications: the public record beside the offeror's representation

Applies to: Federal primes flowing Section 889 down to subcontractors; contracting officers reviewing the SAM representation before award · Rule text: https://www.acquisition.gov/far/52.204-25

The question the rule asks

Section 889 of the FY2019 NDAA, as implemented at FAR 52.204-25, prohibits contracting for covered telecommunications equipment or services (Huawei, ZTE, Hytera, Hikvision, Dahua and their affiliates, and anything the FCC adds to its Covered List). FAR 52.204-26 requires the offeror to represent in SAM whether it provides or uses covered equipment, after a reasonable inquiry.

The party this sheet is about

Wellpath LLC · keys supplied: UEI JL99G1YPJKK9 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_3aca9817c6c347f7 · read 2026-10-25 16:55:54 UTC · SHA-256 c53c0d1c6ff72825719e1d722ba4709ce3129ca5442309f44376ba8223d5d30f · verify: https://alphacovenantholdings.com/r/r_3aca9817c6c347f7

The official files that answer it, as read on that date

Source	Role	State	Records	What it printed
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directly	answers the question	answered	0	0 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
DoD Section 1260H list (Chinese military companies operating in the United States) — entities and the statutory basis as published in the latest Federal Register notice of designation	answers the question	answered	0	0 DoD Section 1260H entries (name or alias as the notice prints it) under this exact printed name
SAM.gov Exclusions — Public Extract V2 (GSA, daily)	supporting	answered	0	No entry under this exact name/UEI in the SAM extract fetched 2026-10-24 (SAM_Exclusions_Public_Extract_V2_26297.ZIP).
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)	supporting	answered	0	No entry under this exact name or listed alias on the SDN list fetched 2026-10-24.
UFLPA Entity List (FLETF, 19 U.S.C. 4681) — complete list as published in the appendix to the latest Federal Register notice	supporting	answered	0	0 UFLPA Entity List entries (name or alias as the FLETF prints it) under this exact printed name
FARA active registrants (DOJ Foreign Agents Registration Act eFile — registrants with an active registration, as the API prints them)	supporting	answered	0	0 active FARA registrations under this exact printed name
USAspending.gov (recipient name equals this name)	supporting	answered		1 registered recipient(s) equal this name; 24 active prime award(s), $3,830,809 obligated

What to record in the file

The representation itself is the offeror's own statement in SAM — it is not on any public file this platform reads and this sheet does not make it for you. What the sheet records: the Consolidated Screening List read (BIS Entity List, where the named manufacturers and many affiliates are listed) with its file date, the SAM exclusions and registration rows for the subcontractor, and the UFLPA Entity List read. The FCC Covered List is not read here (fcc.gov answers programs with HTTP 403); read it at the official page and write the date beside this receipt.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections