The Second Interim Rule implementing Section 889, Part 2 becomes effective October 26, 2020. Section 889 Part B prohibits any executive agency from entering into, extending, or renewing a contract with an entity that uses any equipment, system, or services that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. This second interim rule requires contractors to represent annually in the System for Award Management ( whether they or their employees use any prohibited equipment.

To come into compliance, government contractors need to evaluate the extent to which the company or its employees are engaged in prohibited conduct and implement new compliance policies. PilieroMazza developed a compliance assistance program to help contractors in this regard and also satisfy a contractors’ Code of Business Ethics and Conduct requirements.

PilieroMazza’s 889 Compliance Assistance Program includes:

• Code of Business Ethics and Compliance updated with Section 889 Compliance;
• Ethics and Compliance Training and accompanying workbook;
• sample employee certification; and
• sample standard operating procedure.

If you are interested in learning more, please contact Sheryl Miller at 202.878.2742 or [email protected].