Section 889 of the 2019 National Defense Authorization Act (Pub. L. 115-232) (Section 889) imposes on the federal government and its contractors and awardees prohibitions related to the procurement and use of certain “covered” telecommunications equipment and services. Section 889 subjects GW to new compliance obligations, which directly affect what GW is allowed to charge to federal contracts and assistance awards (grants and cooperative agreements). A separate communication addressing Section 889 in more detail was issued to the GW research community.
Section 889 requires GW to conduct a “reasonable inquiry” to determine whether it complies. The following questionnaire can be used to help you assess:
- Whether GW has procured or obtained“covered telecommunications equipment or services” as a substantial or essential component of any system, or as critical technology as part of any system under any GW federal contracts, grants, or cooperative agreements (including subawards or through a subcontractor that may use the covered equipment or services);
- Whether GW uses “covered telecommunications equipment or services” as a substantial or essential component of any system, or as critical technology as part of any system in its day-to-day operations, whether or not related to a specific federal award.
Responses to this questionnaire are solely for GW’s use and will not be shared except for the purpose of complying with federal regulation. Your response should be accurate as of the date the form is completed, and should take into account any existing and/or new, proposed, or planned use or agreement, contract, or purchase order for the procurement or use of covered equipment or services whether or not the procurement or use relates to a federally funded grant, contract, or cooperative agreement. If you are not sure whether a relationship, grant or contract, or piece of equipment qualifies under the definitions below, please contact [email protected].
In answering this survey, please refer to the following definitions:
“Covered telecommunications equipment or services” are telecommunications and/or video surveillance equipment or services produced by:
“Critical Technology” is:
Based on information in your possession or your personal knowledge, please answer the following questions: