Inactive 8(a) Set-Aside (FAR 19.8)

Radiation Oncology Peer Review Software Program RFI Page 3 of 51 Radiation Oncology Peer Review Software Program This is a request for information (RFI) only. The Department of Veterans Affairs (VA) h... Radiation Oncology Peer Review Software Program RFI Page 3 of 51 Radiation Oncology Peer Review Software Program This is a request for information (RFI) only. The Department of Veterans Affairs (VA) has a requirement to provide a robust peer review software program for quality assurance in radiation treatment planning. The vendor product should be a software as a service (SaaS) hosted on the vendor cloud environment. Vendor s peer review program must include a software module for anonymization of patient health information that will be deployed at each VA radiation oncology clinic. The software should have mechanisms to upload DICOM/DICOM-RT data to the vendor hosted cloud database for data archival. Peer review software viewer should be able to display the DICOM/DICOM-RT data and need to be zero foot print (HTML-5 based) that can work on any modern day web browser. The peer review viewer should be accessible via Internet or Cloud. Software will be used to provide remote peer-review services for the purpose of providing expert peer-reviews to radiation oncologists within VHA. It is also requested that the vendor respond to the following questions: Provide a brief summary of your technical approach (not to exceed 15 pages) for meeting the Product Description requirements for the Peer Review Software Program. Provide a cost estimate for the SaaS licensing and training. Please provide existing GSA schedule, NASA SEWP, and/or GWAC contract information in which you are a contract holder that can be utilized to procure these services. Please provide your company profile (to include, but not limited to, history, business size and socioeconomic category under North American Industry Classification (NAICS) 511210. This RFI is for planning purposes only and shall not be considered an Invitation for Bid, Request for Task Execution Plan, Request for Quotation or a Request for Proposal. Additionally, there is no obligation on the part of the Government to acquire any products or services described in this RFI. Your response to this RFI will be treated only as information for the Government to consider. You will not be entitled to payment for direct or indirect costs that you incur in responding to this RFI. This request does not constitute a solicitation for proposals or the authority to enter into negotiations to award a contract. No funds have been authorized, appropriated or received for this effort. The information provided may be used by the VA in developing its acquisition strategy and Product Desciption. Interested parties are responsible for adequately marking proprietary, restricted or competition sensitive information contained in their response. The Government does not intend to pay for the information submitted in response to this RFI. Responses are due by 2:30 pm EST, August 14, 2019 to Robert Geran (Robert.Geran@va.gov) Radiation Oncology Peer Review Software Program RFI Page 51 of 51 PerformanceWorkStatementTemplate_APR_10_2019 Page 1 of 59 Page 1 of 25 Product requirements High quality patient care is important to any medical discipline but is of particular concern in radiation oncology given the potential for serious harm in the event of a treatment-related error. Radiation treatment planning is a very complicated process with many safety aspects involved and with the increased application of more sophisticated technologies in radiation therapy, concerns have arisen about whether radiation is being used appropriately. Quality-assurance procedures must evolve with complex radiotherapy planning and delivery systems in order to ensure that consistently effective and safe therapy is delivered. The Veterans Health Administration (VHA) concurred with the Office of Inspector General (OIG) Health Inspection report, dated March 10, 2011, that there was a need for a robust physician peer review process related to all VHA radiotherapy programs. The Radiation Oncology Peer Review will give VA centers providing inhouse radiation oncology care the capability to seek prospective physician peer reviews online. The capability will enable VA radiation oncologists to consider treatment refinements and alternatives prior to radiation delivery for the safety of Veterans. The Contractor shall provide a Web-based software package to facilitate peer review of radiotherapy treatment plans to all 40 Radiation Oncology Service with the VA system. The contracted services shall include access to the application software hosted on the vendor cloud environment via internet explorer v10 or higher or google chrome based web browsers, training, documentation, and helpdesk support. The contract will be based on Software-as-a-Service (SaaS) subscription. The acceptance testing for this software will be performed based the American Assocication of Medical Physics recommendations in Task Group report # 53 - Quality assurance for clinical radiotherapy treatment planning (https://www.aapm.org/pubs/reports/rpt_62.pdf) The peer review software shall be accessible to all 40 VA Radiation Oncology clinics and will enable VHA radiation oncologists to seek treatment plan peer reviews on demand from any expert anywhere with Web access. The peer review software shall be FDA approved and will have no dependencies on or interfaces with other VA software systems. The software architecture shall allow prospective peer reviews of radiotherapy treatment plans by VA contracted nationally recognized experts in radiation oncology outside the VA. The contractor Peer Review Software-as-a-Service product shall be a hosted on the contractor cloud environment. This procurement will include one-year license with 2 option years for unlimited users, upgrades, technical support and training. 1.1 SOFTWARE APPLICATION REQUIREMENTS The software shall meet the following general criteria: Users shall be able to securely upload & download imaging from modalities such as computerized tomography (CT), magnetic resonance (MR), secondary capture (SC), computer radiograph (CR), portal, and digitally-constructed radiograph (DRR) as well as radiation therapy data objects over the VA Intranet (Digital Imaging and Communication in Medicine (DICOM), scanned images, etc.). All DICOM dataset shall be securely submitted to the Contractor cloud-based RT PACS server. The system shall be automated such that the data is automatically registered and entered into the Radiotherapy Picture Archiving and Communication System (RT PACS) database. Patient confidentiality shall be maintained throughout the peer review process and anonymous case datasets and peer reviewers observations data cannot be accessed by an unauthorized user within or external to the system. Peer review cases submitted by the VA clinical providers need to be made immediately (within 1 hour) available for rapid review by the VA contracted nationally recognized experts in radiation oncology outside the VA. The Contractor shall provide tools to download all clinical data in the Contractor cloud RT-PACS server to a local archive in the VA. Data objects shall be editable with the support of data authoring and versioning (DAV) control. The peer review software shall be accessible to multiple simultaneous VA users at any given time. We estimate 40 user accounts and the same number of simultaneous users of this software. It is estimated that there will be up to 10,000 cases per year. Security is implemented by performing lossless compression and encryption on all data before transmission. Data shall also be stored both compressed and encrypted in the database as a further measure of security. The data exchange protocol employed throughout shall be secure hypertext transfer protocol (HTTPS) for all transfers. This enables transfer from most firewall-protected networks which typically allow HTTP and secure hypertext transfer protocol HTTPS data transfers Provide a User Manual detailing all user capabilities and functions with troubleshooting section on the use of software and transmission of planning data files to National Expert and transmission of planning data files to the program office representative. Deliverable: User Manual 1.2 SOFTWARE COMPONENTS The Peer Review software application shall satisfy the following software components requirement as illustrated in the figure from appendix A. All the below mentioned software components are illustrated in the figure from appendix A. Web-based secure object archiving system (Web based RT-PACS): The software shall support all DICOM Message Service Elements (DIMSE) listed in the table below and can read, write and analyze DICOM (including all radiotherapy information object definitions [IODs]) and flat files (Part 10 Format). The software application shall be able to accept data over secure HTTPS web services protocol DIMSE Services: Name Group Type C-STORE DIMSE-C operation C-GET DIMSE-C operation C-MOVE DIMSE-C operation C-FIND DIMSE-C operation C-ECHO DIMSE-C operation DICOM RT data viewer: The software shall have the infrastructure of comprehensive tools required for preparation, submission, auto-archiving, Web-based review, and retrieval of diagnostic images, treatment-planning images, and radiation therapy objects. The software shall have the features of auto anonymizing datasets before they are submitted for peer review. Also, the software shall have tools for calculating Dose Value Histograms (DVHs) and compositing doses from different trials of the patient. In addition to DICOM RT data the software shall be able to handle PDF attachments with the clinical cases for review. Data analytics: The Contractor shall provide data analytic tools and dashboards to quantitatively evaluate the quality of treatment plans. The data analytics tool shall have interactive dashboards to view aggregated data from peer review results and treatment plans over time. Data anonymizer: Template based anonymization tools shall be provided by the Contractor to remove any PHI/PII from the DICOM/DICOM-RT datasets before they are uploaded to the Contractor hosted cloud RT-PACS. The template-based anonymization shall have custom anonymization schemes to be applied automatically to the incoming treatment plan data. Upon anonymization the DICOM and clinical data shall be encrypted using Federal Information Processing Standards-140/2 (FIPS-140/2) supported encryption protocols. The Peer review software application shall be seamlessly interoperable with radiotherapy planning and oncology information systems that comply with the DICOM and Integrating the Healthcare Enterprise Radiation Oncology (IHE-RO) standards & specifications 1.3 SOFTWARE APPLICATION DATA SECURITY REQUIREMENTS 1.3.1 DATA SECURITY The software shall meet the following data security criteria: The software capability shall include a secure (access to patient data) and unsecure (access to general information regarding the functionalities of software) section. Access to secure section shall be divided into multiple levels, based on the privilege level assigned to a user. The privilege level shall be assigned based on the need of a user to view clinical data submitted to the RT servers. Each expert reviewing cases will have access to data submitted for his/her domain only. The software shall ensure end-users have access to only their data. Each user will have to register once with the software server and get a user name and user password. Before an account is activated, the software shall send a notification to a VA system administration requesting user credentials verification. Access to data shall be hierarchical. Browsers and Web services shall use a Secure Socket Layer (SSL) for secure communication. The RT servers shall exchange a public key certificate with client applications. The key certificate shall be published for the domain and signed by a certificate authority; the client application (browser) establishes an encrypted connection between itself and the RT servers. Once a user logs in, a unique session shall be created on the server memory. This session shall expire after a specified time if there is no activity on the software. Thus, if the user computer is left unattended, the session data cannot be accessed after the expired time by others. In addition, presentation of each dynamic page depends on this unique session. The Contractor shall coordinate with applicable VA stakeholders for an Authority to Operate (ATO) to interface the hosted environments to the VA Network. The Contractor shall provide all Assessment and Authorization (A&A) support and documentation required to achieve and maintain full A&A certification using the process specified in the FedRAMP Program Requirements. Be fully responsible and accountable for ensuring compliance with all HIPAA, Privacy Act, Federal Information Security Management Act (FISMA), National Institute of Standards and Technology (NIST), Federal Information Processing Standards (FIPS), and VA security and privacy directives and handbooks. This includes conducting compliant risk assessments, routine vulnerability scanning, continuous monitoring, system patching and change management procedures, and the completion of an acceptable contingency plan for each system. The contractor s security control procedures must be equivalent, to those procedures used to secure VA systems. Ensure adequate security controls for collecting, processing, transmitting, and storage and removal of Personally Identifiable Information (PII) and Personal Health Information (PHI), as determined by the VA Privacy Service, must be in place, tested, and approved by VA prior to hosting, operation, maintenance, or use of the information system, or systems by or on behalf of VA. Ensure these security controls are to be assessed and stated within the Privacy Impact Assessment (PIA) and if these controls are determined not to be in place, or inadequate, a Plan of Action and Milestones (POA&M) shall be submitted and approved prior to the collection of PII and PHI. The Contractor shall be responsible for generating the A&A ATO Package that includes the following security documentation IAW Appendix C Authorization Requirements SOP: System Security Plan (SSP), Risk Assessment (RA), Incident Response Plan (IRP), Information Security Contingency Plan (ISCP), Disaster Recovery Plan (DRP), Configuration Management Plan (CMP), Interconnection Security Agreement/Memorandum of Understanding (ISA/MOU), Additional system description/and diagrams required by VA to gain access to VA network and receive an Authority to Operate (ATO).  1.3.2 ASSESSMENT, AUTHORIZATION, and CONTINUOUS MONITORING The information system solution selected by the Contractor shall comply with the Federal Information Security Management Act (FISMA). The Contractor shall comply with FedRAMP requirements as mandated by Federal laws and policies, including making available any documentation, physical access, and logical access needed to support this requirement. Following guidance from the Federal CIO, VA will utilize existing JAB ATO or agency ATO issued by another agency as a starting point for FedRAMP requirements. If neither of those exist, VA will sponsor FedRAMP ATO. VA will be using the FedRAMP baselines as a starting point, since they are specifically tailored for cloud services. The Contractor shall, where applicable, assist with the VA Authority to Operate (ATO) Process to help achieve agency authorization of the cloud service or migrated application. The Contractor shall afford VA access to the Contractor s and Cloud Service Provider s facilities, installations,technical capabilities, operations, documentation, records, and databases. If new or unanticipated threats or hazards are discovered by either VA or the Contractor, or if existing safeguards have ceased to function, the discoverer shall immediately bring the situation to the attention of the other party The Contractor shall not release any data without the consent of VA in writing. All requests for release must be submitted in writing to the COR/CO. Other considerations: Trusted Internet Connection (TIC) Include TIC requirements for SaaS that interfaces with VA systems, SaaS must meet all VA Security requirements for non-SaaS. Include Addendum A Additional VA Requirements, Consolidated Deliverables: A&A ATO Package Plan of Action and Milestones 1.3.3 PEER REVIEW APPLICATION - FedRAMP REQUIREMENT The Peer Review application shall be hosted on a FedRAMP-Low certified cloud solution. The Contractor shall provide a copy of the certificate issued granting Authority to Operate the cloud provider that is hosting the Peer Review application. The Contractor shall maintain its security authorization throughout the contract period of performance. Deliverable: A. FEDRAMP Low Certification 1.4 TRAINING AND TRAINING DOCUMENTS/MATERIALS The Contractor shall provide two virtual Instructor led training sessions (on skype or webex) with the approximately 200 users on the operations and functionality of the software including a troubleshooting section. The training shall also include procedures to submit radiotherapy treatment plans to the Contractor cloud RT-PACS server. The Contractor shall deliver the PowerPoint Training Slide Deck. The Contractor shall record the training session and provide a copy of the recorded training session playable on MS Windows10 environment. The Contractor shall coordinate with the COR to schedule the training sessions to be completed prior to software going operational. The Contractor shall conduct quarterly virtual software update webinar sessions (via skype/webex) to approximately 100 users in the VA. The Contractor shall deliver the Quarterly webinar PowerPoint Training Slide Deck. The Contractor shall record the Quarterly webinar training session and provide a copy of the recorded training session playable on MS Windows10 environment. The Contractor shall coordinate with the COR to schedule the Quarterly webinar training sessions with the COR. Deliverables: PowerPoint Training Slide Deck and Video. Quarterly Webinar PowerPoint Training Slide Deck and Video. 1.5 HELP DESK SUPPORT The Contractor shall provide Help Desk support to Users in resolving problems encountered using the Radiation Oncology Peer Review software. The Help Desk support shall include users access to live chat, email, toll free telephonic support. The support shall be available Monday through Friday 8 AM to 8 PM Eastern Time. The Contractor shall maintain a Help Desk trouble ticket log. The trouble ticket log shall log the date and time of the original help desk request, date and time of initial response, detailed description of action(s) taken, including date and time of each action, name of technician, and date and time of final resolution. 1.6 CONTRACT AWARD MEETING The contractor shall not commence performance on the tasks in this Product Description until the CO has conducted a kick off meeting or has advised the contractor that a kick off meeting is waived. 1.7 CONTRACTOR PROJECT MANAGEMENT PLAN The Contractor shall deliver a Contractor Project Management Plan (CPMP) that lays out the Contractor s approach, tasks, subtasks, timeline and tools to be used in execution of the contract.  The CPMP should take the form of both a narrative and graphic format that displays the schedule, milestones, risks and resource support.  The CPMP shall also include how the Contractor shall coordinate and execute planned, routine, and ad hoc data collection reporting requests as identified within the Product Description (PD). The initial baseline CPMP shall be concurred upon and updated in accordance with Section B of the contract. The Contractor shall update and maintain the VA PM approved CPMP throughout the PoP. Deliverable: Contractor Project Management Plan 1.8 Monthly status briefing The Contractor shallsubmit monthly status reports to present previous month activities, open issues, risk and mitigation actions, issues closed and Help Desk activities from the trouble ticket log. The contractor status report should include any action items from the pervious month s status report. Deliverable: Monthly Status reports NOTICE OF THE FEDERAL ACCESSIBILITY LAW AFFECTING ALL INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) PROCUREMENTS (SECTION 508) On January 18, 2017, the Architectural and Transportation Barriers Compliance Board (Access Board) revised and updated, in a single rulemaking, standards for electronic and information technology developed, procured, maintained, or used by Federal agencies covered by Section 508 of the Rehabilitation Act of 1973, as well as our guidelines for telecommunications equipment and customer premises equipment covered by Section 255 of the Communications Act of 1934. The revisions and updates to the Section 508-based standards and Section 255-based guidelines are intended to ensure that information and communication technology (ICT) covered by the respective statutes is accessible to and usable by individuals with disabilities. SECTION 508 INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) STANDARDS The Section 508 standards established by the Access Board are incorporated into, and made part of all VA orders, solicitations and purchase orders developed to procure ICT. These standards are found in their entirety at: https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines. A printed copy of the standards will be supplied upon request. Federal agencies must comply with the updated Section 508 Standards beginning on January 18, 2018. The Final Rule as published in the Federal Register is available from the Access Board: https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule. The Contractor shall comply with 508 Chapter 2: Scoping Requirements for all electronic ICT and content delivered under this contract. Specifically, as appropriate for the technology and its functionality, the Contractor shall comply with the technical standards marked here: E205 Electronic Content (Accessibility Standard -WCAG 2.0 Level A and AA Guidelines) E204 Functional Performance Criteria E206 Hardware Requirements E207 Software Requirements E208 Support Documentation and Services Requirements COMPATABILITY WITH ASSISTIVE TECHNOLOGY The standards do not require installation of specific accessibility-related software or attachment of an assistive technology device. Section 508 requires that ICT be compatible with such software and devices so that ICT can be accessible to and usable by individuals using assistive technology, including but not limited to screen readers, screen magnifiers, and speech recognition software. ACCEPTANCE AND ACCEPTANCE TESTING Deliverables resulting from this solicitation will be accepted based in part on satisfaction of the Section 508 Chapter 2: Scoping Requirements standards identified above. The Government reserves the right to test for Section 508 Compliance before delivery. The Contractor shall be able to demonstrate Section 508 Compliance upon Deliverables resulting from this solicitation will be accepted based in part on satisfaction of the Section 508 Chapter 2: Scoping Requirements standards identified above. The Government reserves the right to test for Section 508 Compliance before delivery. The Contractor shall be able to demonstrate Section 508 Compliance upon delivery. INFORMATION TECHNOLOGY USING ENERGY-EFFICIENT PRODUCTS N/A GENERAL REQUIREMENTS VA TECHNICAL REFERENCE MODEL The Contractor shall support the VA enterprise management framework. In association with the framework, the Contractor shall comply with OI&T Technical Reference Model (VA TRM). The VA TRM is one component within the overall Enterprise Architecture (EA) that establishes a common vocabulary and structure for describing the information technology used to develop, operate, and maintain enterprise applications. Moreover, the VA TRM, which includes the Standards Profile and Product List, serves as a technology roadmap and tool for supporting OI&T. Architecture & Engineering Services (AES) has overall responsibility for the VA TRM. ADDENDUM B VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE APPLICABLE PARAGRAPHS TAILORED FROM: THE VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE, VA HANDBOOK 6500.6, APPENDIX C, MARCH 12, 2010 GENERAL Contractors, Contractor personnel, Subcontractors, and Subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS A Contractor/Subcontractor shall request logical (technical) or physical access to VA information and VA information systems for their employees, Subcontractors, and affiliates only to the extent necessary to perform the services specified in the contract, agreement, or task order. All Contractors, Subcontractors, and third-party servicers and associates working with VA information are subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for Contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations, Security, and Preparedness is responsible for these policies and procedures. Contract personnel who require access to national security programs must have a valid security clearance. National Industrial Security Program (NISP) was established by Executive Order 12829 to ensure that cleared U.S. defense industry contract personnel safeguard the classified information in their possession while performing work on contracts, programs, bids, or research and development efforts. The Department of Veterans Affairs does not have a Memorandum of Agreement with Defense Security Service (DSS). Verification of a Security Clearance must be processed through the Special Security Officer located in the Planning and National Security Service within the Office of Operations, Security, and Preparedness. Custom software development and outsourced operations must be located in the U.S. to the maximum extent practical. If such services are proposed to be performed abroad and are not disallowed by other VA policy or mandates (e.g. Business Associate Agreement, Section 3G), the Contractor/Subcontractor must state where all non-U.S. services are provided and detail a security plan, deemed to be acceptable by VA, specifically to address mitigation of the resulting problems of communication, control, data protection, and so forth. Location within the U.S. may be an evaluation factor. The Contractor or Subcontractor must notify the CO immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the Contractor or Subcontractor s employ. The CO must also be notified immediately by the Contractor or Subcontractor prior to an unfriendly termination. VA INFORMATION CUSTODIAL LANGUAGE Information made available to the Contractor or Subcontractor by VA for the performance or administration of this contract or information developed by the Contractor/Subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of VA. This clause expressly limits the Contractor/Subcontractor's rights to use data as described in Rights in Data - General, FAR 52.227-14(d) (1). VA information should not be co-mingled, if possible, with any other data on the Contractors/Subcontractor s information systems or media storage systems in order to ensure VA requirements related to data protection and media sanitization can be met. If co-mingling must be allowed to meet the requirements of the business need, the Contractor must ensure that VA information is returned to VA or destroyed in accordance with VA s sanitization requirements. VA reserves the right to conduct on site inspections of Contractor and Subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures are in compliance with VA directive requirements. Prior to termination or completion of this contract, Contractor/Subcontractor must not destroy information received from VA, or gathered/created by the Contractor in the course of performing this contract without prior written approval by VA. Any data destruction done on behalf of VA by a Contractor/Subcontractor must be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management and its Handbook 6300.1 Records Management Procedures, applicable VA Records Control Schedules, and VA Handbook 6500.1, Electronic Media Sanitization. Self-certification by the Contractor that the data destruction requirements above have been met must be sent to the VA CO within 30 days of termination of the contract. The Contractor/Subcontractor must receive, gather, store, back up, maintain, use, disclose and dispose of VA information only in compliance with the terms of the contract and applicable Federal and VA information confidentiality and security laws, regulations and policies. If Federal or VA information confidentiality and security laws, regulations and policies become applicable to VA information or information systems after execution of the contract, or if NIST issues or updates applicable FIPS or Special Publications (SP) after execution of this contract, the parties agree to negotiate in good faith to implement the information confidentiality and security laws, regulations and policies in this contract. The Contractor/Subcontractor shall not make copies of VA information except as authorized and necessary to perform the terms of the agreement or to preserve electronic information stored on Contractor/Subcontractor electronic storage media for restoration in case any electronic equipment or data used by the Contractor/Subcontractor needs to be restored to an operating state. If copies are made for restoration purposes, after the restoration is complete, the copies must be appropriately destroyed. If VA determines that the Contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be sufficient grounds for VA to withhold payment to the Contractor or third party or terminate the contract for default or terminate for cause under Federal Acquisition Regulation (FAR) part 12. If a VHA contract is terminated for cause, the associated Business Associate Agreement (BAA) must also be terminated and appropriate actions taken in accordance with VHA Handbook 1600.05, Business Associate Agreements. Absent an agreement to use or disclose protected health information, there is no business associate relationship. The Contractor/Subcontractor must store, transport, or transmit VA sensitive information in an encrypted form, using VA-approved encryption tools that are, at a minimum, FIPS 140-2 validated. The Contractor/Subcontractor s firewall and Web services security controls, if applicable, shall meet or exceed VA minimum requirements. VA Configuration Guidelines are available upon request. Except for uses and disclosures of VA information authorized by this contract for performance of the contract, the Contractor/Subcontractor may use and disclose VA information only in two other situations: (i) in response to a qualifying order of a court of competent jurisdiction, or (ii) with VA prior written approval. The Contractor/Subcontractor must refer all requests for, demands for production of, or inquiries about, VA information and information systems to the VA CO fo...