Federal-award purchases — covered telecommunications and video surveillance (2 CFR 200.216 / Section 889)
Template version 2026-10-06 — adopted by: ____________________  effective: __________  owner: IT Procurement (owner); Grants Office (funding check); Compliance (oversight)

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.

STANDARDS SERVED
- 2 CFR 200.216 — prohibition on certain telecommunications and video surveillance services or equipment — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/section-200.216
- Section 889, FY2019 NDAA — covered entities (Huawei, ZTE, Hytera, Hikvision, Dahua) and their subsidiaries/affiliates — https://www.congress.gov/bill/115th-congress/house-bill/5515
- DoD Section 1260H list — Chinese military companies (context for federal contractors) — https://www.defense.gov/
- FCC Covered List — read on every Alpha Covenant receipt (producer as printed, covered equipment or service, date of inclusion) — https://www.fcc.gov/supplychain/coveredlist

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
1. 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.
2. 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.
3. 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.
4. 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.
5. 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.

MEASURES (findings reported monthly; the threshold for each is your protocol's)
- Pre-purchase coverage: in-scope purchases with a dated record and representation on file before PO ÷ in-scope purchases. Data: procurement system. Threshold: your protocol: ________
- FCC Covered List hand-read currency: days since the Covered List was last read and recorded. Data: record header. Threshold: your protocol: ________
- Inventory review: installed in-scope items reviewed in the last 12 months ÷ installed items. Data: inventory. Threshold: your protocol: ________
- Matches routed: printed-name matches routed to Counsel before purchase ÷ matches. Data: routing log. Threshold: your protocol: ________

RECORDS
- Per-purchase record + vendor representation — kept by IT Procurement — retention per 2 CFR 200.334 and HOSP-08
- Annual inventory review — kept by IT — retention same
- Counsel routing log — kept by Compliance — retention same

WHAT THIS PROCEDURE DOES NOT DECIDE
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.

CHANGE LOG (add a line for every change; keep superseded versions)
- 2026-10-06: First issue.
- ________: adopted/edited by ____________________

Source template: https://alphacovenantholdings.com/api/public-record/sop-templates/hosp-10-covered-telecom-889/html · Duty Sheets: https://alphacovenantholdings.com/api/public-record/duty-sheets · Our own procedures: https://alphacovenantholdings.com/api/trust/sops