Federal-award purchases — covered telecommunications and video surveillance (2 CFR 200.216 / Section 889)

Template version 2026-10-06 · for: 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) · adopted by organization effective date . Editable .txt · JSON

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

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.

Findings reported — computed from your own records; the threshold is your protocol's

Finding	Computed as	Data source	Threshold
Pre-purchase coverage	in-scope purchases with a dated record and representation on file before PO ÷ in-scope purchases	procurement system	your protocol
FCC Covered List hand-read currency	days since the Covered List was last read and recorded	record header	your protocol
Inventory review	installed in-scope items reviewed in the last 12 months ÷ installed items	inventory	your protocol
Matches routed	printed-name matches routed to Counsel before purchase ÷ matches	routing log	your protocol

Records

Record	Kept by	Retention
Per-purchase record + vendor representation	IT Procurement	per 2 CFR 200.334 and HOSP-08
Annual inventory review	IT	same
Counsel routing log	Compliance	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

Date	Change
2026-10-06	First issue.
date	adopted / edited by name

Other templates: 01 · 02 · 03 · 05 · 06 · 07 · 08 · 09 · 01 · Duty Sheets (one page per rule, generated on any receipt) · our own procedures · 2026-10-25