D--VISN 8 Live Data PeriOp
Surgical Workflow Planning System for VISN 8 Network Page 14 of 33 Department of Veterans Affairs (VA) Technology Acquisition Center (TAC) is seeking information concerning the availability of capable... Surgical Workflow Planning System for VISN 8 Network Page 14 of 33 Department of Veterans Affairs (VA) Technology Acquisition Center (TAC) is seeking information concerning the availability of capable contractors to provide all software, hardware and services to fully implement a surgical workflow planning system to Veterans Integrated Service Network 8 (VISN 8). VISN 8 already implemented LiveData PeriOp/DSS in three of eight VA Medical Centers (VAMC s) located in Tampa, Orlando, and Miami. VA now requires continued maintenance for the three sites with a deployed system and new implementation for the remaining five VAMCs in VISN 8 or the ability to transition to a new surgical workflow planning system for all VISN 8 VAMC s. The VA is seeking sources capable of providing installation, configuration, testing, training, warranty, hosting maintenance, and deploying the system. This is a request for information (RFI) only. Do not submit a proposal or quote. 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. 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. If interested, please provide the following: 1. A capabilities statement that addresses the questions below by Monday, October 28, 2019. If additional information is required by VA to determine a contractor s capability to provide the full requirement and the economic feasibility of the information provided, additional information may be requested later. A draft version of the requirement is below. Please direct all responses to Joe Jones, joseph.jones6@va.gov and Debra Clayton, debra.clayton2@va.gov. 2. Rough Order of Magnitude (ROM) estimate to include pricing models that would be most advantageous to the Government; 3. Breakout of software, hardware and services necessary for the installation of system; 4. Describe the options for hosting your system 5. Provide timeline for how long it will take to install the solution at all required VISN 8 sites. VA anticipates a phased, sequential installation 6. With respect to training on your solution, provide your recommendations as to when training should occur; format (i.e, virtual or face to face); frequency; and identify for which functional roles training is recommended. 7. Any Contract Vehicle of which you are a part that can be used to acquire your solution as well as the company business size and status for each vehicle as designated by the NAICS 541519 and the U.S. Small Business Administration (i.e., Large Business, Small Business, Service-Disabled Veteran Owned Small Business, Small Disadvantaged Business, Women-Owned Small Business, Hub Zone Small Business, etc.) PRODUCT REQUIREMENTS Currently three of eight Department of Veterans Affairs Medical Centers (VAMC) in the Veterans Integrated Service Network (VISN) 8 Health Care Systems (Tampa, Orlando, and Miami) are using Document Storage Systems LiveData PeriOp Surgical Workflow Planning System. The LiveData PeriOp Surgical Workflow Planning Solution is a Veterans Health Information Systems and Technology Architecture (VistA)-integrated, graphical user interface designed to provide a constant integrated view of patient status in real-time, manage perioperative complexity, improve team communication, enhance patient safety, and improve operational efficiency by streamlining documentation and updating Veterans Health Information Systems and Technology Architecture (VistA). VA now requires continued maintenance for the three sites (Tampa, Orlando, and Miami) with a deployed system and new implementation for the remaining five VAMCs in VISN 8. The Contractor shall provide all software, hardware and services to fully implement a surgical workflow planning system solution that meets the salient characteristics of section 1.1 for the following five sites: West Palm Beach VAMC POC: Dr. Ernest Shwayri Address: West Palm Beach VAMC 7305 N. Military Trail West Palm Beach, FL 33410 Voice: 561-422-7341 E-mail: Ernest.Shwayri@va.gov Go live date: 30 days after award Ready for VA use within 60 DAC Malcom Randall VAMC (Gainesville, FL) Name: TBD Address: Malcolm Randall VAMC 1601 S.W. Archer Rd. Gainesville, FL 32608 Voice: xxxxxxx E-mail: xxxxxxx Go live date: 60 days after award Ready for VA use within 120 DAC Lake City VAMC Name: TBD Address: Malcolm Randall VAMC 1601 S.W. Archer Rd. Gainesville, FL 32608 Voice: xxxxxxx E-mail: xxxxxxx Go live date: 90 days after award Ready for VA use within 180 DAC C.W. Bill Young VAMC (Bay Pines, FL) Name: Dr. Cynthia Fisher Address: C.W. Bill Young VAMC 10000 Bay Pines Blvd. Bay Pines, FL 33744 Voice: 727-398-6661 E-mail: Cynthia.Fisher@va.gov Go live date: 120 days after award Ready for VA use within 240 DAC San Juan VAMC Name: Dr. Norma Santiago Address: San Juan VAMC 10 Casia St. San Juan, Puerto Rico 00921-3201 Voice: 787-614-5162 E-mail: norma.santiago@va.gov Go live date: 150 days after award Ready for VA use within 240 DAC PERIOD OF PERFORMANCE The Contractor shall install the surgical workflow planning system within 12-month base period including installation, configuration, testing, training, warranty and maintenance. Four 12-month option periods are needed for continued training as well as warranty and maintenance. INSTALLATION AND CONFIGURATION The Contractor shall provide the following installation services: Conduct site surveys of each of the designated locations within thirty (30) days following contract award. Each site survey shall include all electrical and IT cable drops necessary. Provide an Implementation Plan that addresses each site and is based on the findings from the site surveys and shall be submitted with within 10 business days after all site surveys have been completed. Complete installation of each display board workstation: Mounting of monitor and associated PC Any necessary Data line pulls Any necessary electrical work required to power monitor and associated PC Configure the system including interface testing with VISTA/CPRS, with the following documentation: Kits built for VistA Interfaces Patch descriptions Test scripts Installation guides Implementation and back out plans Configure the pre-operative events display information including: Work with the VHA clinical staff to document pre-operative milestones and process flow for each of the milestones. Map VistA/CPRS data elements to pre-operative milestones and document milestone completion criteria. Document criteria for marking a patient ready for transport to Operating Room for planned surgical procedure. Setup alert conditions and appropriate notification mechanism. Setup access control for access to Pre-Op milestone completion. Identify locations where read-only Pre-Op dashboard displayed for use by perioperative staff. Configure the Operating Room events display information including: Work with the VHA clinical staff to document clinical process flow Verify mapping of VistA/CPRS data elements to display board. Verify mapping of Anesthesia data elements to display board. Configure display board to accept data from physiological monitors Configure site-specific checklists. Configure the Scheduling events display information including: Work with hospital s perioperative staff to configure site-specific color key Identify locations where read only OR-Schedule dashboard will be displayed for use by perioperative staff Define dashboard configuration for each of the locations. Define access control list for users who can modify the day of surgery schedule Define application URL and mechanism to deploy URL for use by authorized users. Configure the Family Waiting display information including: Work with hospitals perioperative staff to configure Identify locations where display monitor will be located for use by patients loved ones. Define display board workstation configuration for each of the locations. Configure the Analytics Package: Configure predefined reports Configure analytic cube to host data for above reports Define access control list for users who can access these reports Define application deployment method for authorized users. 9) Integrate software solution: a) VistA integration is required INTEGRATION WITH VISTA. The Contractor s solution shall be integrated with VistA using the Health Level Seven (HL7) interface engine. HL7 interface engine transmits information from VistA to the Contractor s solution based on HL7 events. The HL7 framework shall also enable the Contractor s solution to send vendor-selected HL7 data to VistA. The Contractor s solution shall not store data. VistA data accessed shall be stored in the Veterans Health Information Systems and Technology Architecture (VistA) only. TESTING. The Contractor shall provide test plans/procedures (TPP) document that includes procedures for testing each system requirement/salient characteristic and coordinate with the sites to and perform a User Acceptance Testing (UAT). The Contractor shall perform testing of the system prior and consider testing successful and the product ready for UAT when the test procedures demonstrate that the system meets the salient characteristics/requirements of section 1.1. TRAINING. The Contractor shall provide onsite training for the system approximately 21 days before the UAT. Training shall include: Clinical applications training for super-users, nurses, physicians, and other clinical staff shall be provided onsite during go-live Training shall be provided on the user interface, application, and its features Training shall provide super-users and end-users with the capability of being self-sufficient in operating the system by the end of the training session. Provide quick notes or reference guides during on-site training during the Go Live Training. Technical Training on an as-needed basis during the life of the contract. Provide technical training for maintenance and service for technical personnel at each site/regional OI&T and/or Biomedical personnel. Training shall include the following topics: Commissioning and preventative maintenance Troubleshooting Server maintenance and backup procedures Provide technical training for configuration of each interface Provide technical training for configuration of each type of display board Workstation WARRANTY. The Contractor shall provide a standard 12-month warranty that covers the system for any hardware/software issues that arise within the warranty period. MAINTENANCE. The Contractor shall provide maintenance for eight VAMC s total (five listed above and three existing (Tampa, Orlando, and Miami) where LiveData Periop is currently installed) of the system to include any hardware, hosting environment, and any software updates, upgrades, and new releases. The Contractor shall provide a help desk phone number for VA to call to notify the Contractor of any issues with the system. The Contractor shall respond within two hours of receipt of VA s call. The Contractor shall complete troubleshooting and repair of the issue(s), making the system once again available to VA users, within 4 hours of receipt of VA call. ITEM 1 SALIENT CHARACTERISTICS The Contractor shall provide a surgical workflow planning system that meets the following salient characteristics: Collect procedure specific data (start/stop times, anesthesia times, room open/room closed, first case starts, turnaround time, OR utilization, OR block time, overtime, out of block utilization, surgeon/anesthesia arrival time). Collect data from the OR, e.g. "Time Out ". Collect data required by the VA's National Surgery Office (VASQIP). Data will be collected by the system but then reported by VA in to SCIP and VASQIP. Example data includes: Prophylactic antibiotic received within 1 hour prior to surgical incision and Prophylactic antibiotic selection for surgical patients. Display overall information on the perioperative process and progress of the patient through the processing the OR on multiple screens (OR desk, SPS, patient s family waiting room, Chief of Surgery's office, OR nurse manager's office, Surgery suite, etc.) and for multiple audiences in order to maintain privacy requirements when/where necessary. Have the capability to schedule patients for surgery. Have the ability for HL7 bi-directional integration with VistA. Have a schedule board view and allow for drag and drop to reschedule patients on any day of surgery. Have an appointment book view that can display if a given surgery schedule block is at capacity or not. Have a means to allocate and track surgery services scheduling block by day of the week and by operating room. Have a means to edit master block schedule to maximize utilization of operating rooms. 10 Have the ability to create a surgery case by entering in specific patient, procedure, staff and operating room data. Have a means to create surgical patients pre-operative work up and track its completion. Anonymize patient information and align with HIPAA regulations. Include a report generator that documents: Pre-operative events. Total time to complete Pre-Op prep/checklist process Total length of stay in Pre-Op Order in which the Pre-Op prep/checklist was completed Time to complete each Pre-Op Checklist item Time Patient occupied Pre-Op bed/bay after Pre-Op checklist was completed Operating room events. Time into OR / Time out of OR Total Anesthesia time (Induction to time out of OR) Operative Time (Incision time to close time) Turnover time OR Block Utilization by Surgeon (Percentage of OR time utilized as compared to OR time allocated/blocked for a given surgeon) OR Block Utilization by Service (Ortho, Urology, General, etc...) Time out procedure time (Time safety checklist is started to time safety checklist has been completed). Scheduled events. Total number of ORs anticipated and actually running each day Total number of patients on the surgery waiting list Provide capability for users to generate/create ad-hoc user reports. The reports would use the measures listed in item 13 but be customizable by the facilities. No additional measures, other than those listed above are required to be included in the ad-hoc reports. OPTIONAL TASK There is an optional task that may be exercised for surgical workflow planning systems proposed by industry other than LiveData PeriOp. If a solution other than LiveData PeriOp is proposed and awarded for the five sites listed, the Contractor shall incorporate that solution and perform all tasks listed under 1.0 at the following existing three VAMC sites: Tampa, Orlando, and Miami. GRAY MARKET GOODS The Contractor must provide only new equipment and new parts for the required products described herein; no used, refurbished, or remanufactured equipment or parts shall be provided under any circumstances. Absolutely no Gray Market Goods or Counterfeit Electronic Parts shall be provided. Gray Market Goods are defined as genuine branded goods intentionally or unintentionally sold outside of an authorized sales-territory or by non-authorized dealers in an authorized territory. All equipment shall be accompanied by the Original Equipment Manufacturers (OEM s) warranty. Counterfeit Electronic Parts are defined as unlawful or unauthorized reproduction, substitution, or alteration that has been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified electronic part from the original manufacturer, or a source with the express written authority of the original manufacturer or current design activity, including an authorized aftermarket manufacturer. Unlawful or unauthorized substitution includes used electronic parts represented as new, or the false identification of grade, serial number, lot number, date code, or performance characteristics. 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 COMPATIBILITY 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 The Contractor shall comply with Sections 524 and Sections 525 of the Energy Independence and Security Act of 2007; Section 104 of the Energy Policy Act of 2005; Executive Order 13834, Efficient Federal Operations , dated May 17, 2018; Executive Order 13221, Energy-Efficient Standby Power Devices, dated August 2, 2001; and the Federal Acquisition Regulation (FAR) to provide ENERGY STAR®, Federal Energy Management Program (FEMP) designated, low standby power, and Electronic Product Environmental Assessment Tool (EPEAT) registered products in providing information technology products and/or services. The Contractor shall ensure that information technology products are procured and/or services are performed with products that meet and/or exceed ENERGY STAR, FEMP designated, low standby power, and EPEAT guidelines. The Contractor shall provide/use products that earn the ENERGY STAR label and meet the ENERGY STAR specifications for energy efficiency. Specifically, the Contractor shall: Provide/use ENERGY STAR products, as specified at www.energystar.gov/products (contains complete product specifications and updated lists of qualifying products). Provide/use the purchasing specifications listed for FEMP designated products at https://www4.eere.energy.gov/femp/requirements/laws_and_requirements/energy_star_and_femp_designated_products_procurement_requirements . The Contractor shall use the low standby power products specified at http://energy.gov/eere/femp/low-standby-power-products. Provide/use EPEAT registered products as specified at www.epeat.net. At a minimum, the Contractor shall acquire EPEAT® Bronze registered products. EPEAT registered products are required to meet the technical specifications of ENERGY STAR, but are not automatically on the ENERGY STAR qualified product lists. The Contractor shall ensure that applicable products are on both the EPEAT Registry and ENERGY STAR Qualified Product Lists. The Contractor shall use these products to the maximum extent possible without jeopardizing the intended end use or detracting from the overall quality delivered to the end user. The following is a list of information technology products for which ENERGY STAR, FEMP designated, low standby power, and EPEAT registered products are available: Computer Desktops, Laptops, Notebooks, Displays, Monitors, Integrated Desktop Computers, Workstation Desktops, Thin Clients, Disk Drives Imaging Equipment (Printers, Copiers, Multi-Function Devices, Scanners, Fax Machines, Digital Duplicators, Mailing Machines) Televisions, Multimedia Projectors This list is continually evolving, and as a result is not all-inclusive. 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. POSITION/TASK RISK DESIGNATION LEVEL(S) Position Sensitivity and Background Investigation Requirements by Service Task/Item Number Service Task/ Item Number Tier1 / Low Risk Tier 2 / Moderate Risk Tier 4 / High Risk 1.1 1.2 1.3 The Tasks identified above and the resulting Position Sensitivity and Background Investigation requirements identify, in effect, the Background Investigation requirements for Contractor individuals, based upon the tasks the particular Contractor individual will be working. The submitted Contractor Staff Roster must indicate the required Background Investigation Level for each Contractor individual based upon the tasks the Contractor individual will be working, in accordance with their submitted proposal. INFORMATION SECURITY CONSIDERATIONS: The Assessment and Authorization (A&A) requirements do not apply and a Security Accreditation Package is not required All VA sensitive information shall be protected at all times in accordance with local security field office System Security Plans (SSP s) and Authority to Operate (ATO) s for all systems/LAN s accessed while performing the tasks detailed in this Product Description. A prohibition on unauthorized disclosure: 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 the 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). A requirement for data breach notification: Upon discovery of any known or suspected security/privacy incidents, or any unauthorized disclosure of sensitive information, including that contained in system(s) to which the Contractor/Subcontractor has access, the Contractor/Subcontractor shall immediately notify the COR and simultaneously, the designated ISO, and Privacy Officer for the contract. The term security incident means an event that has, or could have, resulted in unauthorized access to, loss or damage to VA assets, or sensitive information, or an action that breaches VA security procedures. See VA Handbook 6500.6, Appendix C, paragraph 6.a. A requirement to pay liquidated damages in the event of a data breach: In the event of a data breach or privacy incident involving SPI the contractor processes or maintains under this contract, the contractor shall be liable to VA for liquidated damages for a specified amount per affected individual to cover the cost of providing credit protection services to those individuals. However, it is the policy of VA to forgo collection of liquidated damages in the event the Contractor provides payment of actual damages in an amount determined to be adequate by the agency. Based on the determinations of the independent risk analysis, the Contractor shall be responsible for paying to VA liquidated damages in the amount of $37.50 per affected individual to cover the cost of providing credit protection services to affected individuals consisting of the following: Notification; One year of credit monitoring services consisting of automatic daily monitoring of at least 3 relevant credit bureau reports; Data breach analysis; Fraud resolution services, including writing dispute letters, initiating fraud alerts and credit freezes, to assist affected individuals to bring matters to resolution; One year of identity theft insurance with $20,000.00 coverage at $0 deductible; and Necessary legal expenses the subjects may incur to repair falsified or damaged credit records, histories, or financial affairs A requirement for annual security/privacy awareness training: Before being granted access to VA information or information systems, all Contractor employees and Subcontractor employees requiring such access shall complete on an annual basis either: (i) the VA security/privacy awareness training (contains VA security/privacy requirements) within 1 week of the initiation of the contract, or (ii) security awareness training provided or arranged by the contractor that conforms to VA s security/privacy requirements as delineated in the hard copy of the VA security awareness training provided to the Contractor. If the Contractor provides their own training that conforms to VA s requirements, they will provide the COR or CO, a yearly report (due annually on the date of the contract initiation) stating that all applicable employees involved in VA s contract have received their annual security/privacy training that meets VA s requirements and the total number of employees trained. See VA Handbook 6500.6, Appendix C, paragraph 9. A requirement to sign VA s Rules of Behavior: Before being granted access to VA information or information systems, all Contractor employees and Subcontractor employees requiring such access shall sign on annual basis an acknowledgement that they have read, understand, and agree to abide by VA s Contractor Rules of Behavior which is attached to this contract. See VA Handbook 6500.6, Appendix C, paragraph 9, and Appendix D. Note: If a medical device vendor anticipates that the services under the contract will be performed by 10 or more individuals, the Contractor Rules of Behavior may be signed by the vendor s designated representative. The contract must reflect by signing the Rules of Behavior on behalf of the vendor that the designated representative agrees to ensure that all such individuals review and understand the Contractor Rules of Behavior when accessing VA s information and information systems. 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 tho...
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