{"id":"hosp-10-covered-telecom-889","version":"2026-10-06","stamp":"Template. Written against the public text of the standard cited; the organization adopts, edits and owns it as its protocol. Every threshold, identity, hold or disclosure decision belongs to the organization. We report the findings against the protocol — counts, dates, states — nothing more. Not legal advice, not a compliance determination, not a consumer report.","title":"Federal-award purchases — covered telecommunications and video surveillance (2 CFR 200.216 / Section 889)","org":"Hospitals, universities and public-health agencies spending federal-award funds on telecom, network or surveillance equipment and services","owner_role":"IT Procurement (owner); Grants Office (funding check); Compliance (oversight)","scope":"Every purchase of telecommunications or video surveillance equipment or services, and systems that use them as substantial or essential components, where any federal-award funds are used.","frequency":"Before each covered purchase; annually for existing inventory.","procedure":["Identify the manufacturer and the service provider of record for the purchase, and the funding source (federal award or not). Only federal-award-funded purchases are in scope for 200.216; the organization may choose to apply it to all.","Obtain a dated record of the manufacturer's exact printed name against the DoD 1260H list, the Consolidated Screening List, the UFLPA Entity List and SAM exclusions; read the FCC Covered List by hand and record the date and the entries checked, because it is not published in machine-readable form.","Obtain the vendor's written representation on covered telecommunications (FAR 52.204-26 style) and file it beside the dated record. The record shows printed-name rows; the representation is the vendor's; the determination that equipment is or is not 'covered' is the organization's.","Annual inventory: list installed telecom and surveillance equipment by manufacturer with the funding source; re-run the printed-name read; document any item under review.","Where a printed name matches a listed entity or a subsidiary named in a list notice, route to Counsel and the Grants Office before purchase or continued use."],"not_decided":"Whether equipment is 'covered', whether a component is 'substantial or essential', and whether a purchase may proceed — the organization and counsel decide. Printed-name rows are candidates for that review.","changes":[["2026-10-06","First issue."]],"standards":[{"standard":"2 CFR 200.216 — prohibition on certain telecommunications and video surveillance services or equipment","url":"https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/section-200.216"},{"standard":"Section 889, FY2019 NDAA — covered entities (Huawei, ZTE, Hytera, Hikvision, Dahua) and their subsidiaries/affiliates","url":"https://www.congress.gov/bill/115th-congress/house-bill/5515"},{"standard":"DoD Section 1260H list — Chinese military companies (context for federal contractors)","url":"https://www.defense.gov/"},{"standard":"FCC Covered List — read on every Alpha Covenant receipt (producer as printed, covered equipment or service, date of inclusion)","url":"https://www.fcc.gov/supplychain/coveredlist"}],"measures":[{"measure":"Pre-purchase coverage","computed_as":"in-scope purchases with a dated record and representation on file before PO ÷ in-scope purchases","data_source":"procurement system","threshold":"set by your protocol; the finding is the number"},{"measure":"FCC Covered List hand-read currency","computed_as":"days since the Covered List was last read and recorded","data_source":"record header","threshold":"set by your protocol; the finding is the number"},{"measure":"Inventory review","computed_as":"installed in-scope items reviewed in the last 12 months ÷ installed items","data_source":"inventory","threshold":"set by your protocol; the finding is the number"},{"measure":"Matches routed","computed_as":"printed-name matches routed to Counsel before purchase ÷ matches","data_source":"routing log","threshold":"set by your protocol; the finding is the number"}],"records":[{"record":"Per-purchase record + vendor representation","kept_by":"IT Procurement","retention":"per 2 CFR 200.334 and HOSP-08"},{"record":"Annual inventory review","kept_by":"IT","retention":"same"},{"record":"Counsel routing log","kept_by":"Compliance","retention":"same"}]}