V-- Ambulance
SUBJECT: Ambulance Services DISCLAIMER: This Sources Sought is issued solely for information and planning purposes and does not constitute a solicitation. Neither unsolicited proposals nor any other k... SUBJECT: Ambulance Services DISCLAIMER: This Sources Sought is issued solely for information and planning purposes and does not constitute a solicitation. Neither unsolicited proposals nor any other kind of offers will be considered in response to this Sources Sought. Responses to this notice are not offers and will not be accepted by the Government to form a binding contract. Responders are solely responsible for all expenses associated with responding to this Sources Sought. All information received in response to this RFI that is marked Proprietary will be handled accordingly. Responses to the Sources Sought will not be returned. At this time, questions concerning the composition and requirements for a future Request for Quote will not be entertained. SUBJECT: The Department of Veterans Affairs is conducting market research in order to provide Ambulance services for the Beckley and Clarksburg, WV VA Medical Centers. The government anticipates awarding a Firm Fixed Price multiple award contract that will provide the support services listed within the below attachment. OBJECTIVE: See attachment. RESPONSE INSTRUCTIONS: Name and Address of Company Any small business designation as certified by the Small Business Administration A through description of experience in managing support requirements of this nature. CONTACT INFORMATION: Any questions related to this Sources Sought shall be directed to Caitlin Hippensteel at caitlin.hippensteel@va.gov. All information regarding Capabilities Statements or any other proprietary information relative to this Sources Sought shall be submitted via email to caitlin.hippensteel@va.gov no later than 3:00 pm EST on 4/11/2019 ATTACHMENT 1 Clarksburg STATEMENT OF WORK Purpose: The purpose of this requirement is to furnish 24-hour ambulance transportation service for the beneficiaries of the Louis A. Johnson VA Medical Center, Clarksburg, West Virginia. This will involve trips to and from any location within the Primary Service Area (PSA) of the Louis A. Johnson VA Medical Center and beyond, as appropriate. Trips are generally confined to within the PSA; however, they may encompass travel to points as far away as Pittsburgh, PA, or beyond, if necessary. TASKING: NUMBER OF PATIENTS: It is understood and agreed that only ONE patient will be transported on a trip unless specifically authorized or requested by the VA. When, pursuant to the Department of Veterans Affairs authorization, more than one patient is transported concurrently on a trip, reimbursement shall be made only at the rates contained in the schedule of costs for transporting a single patient. Regardless of the number of patients transported concurrently on a single trip, the Contractor shall be reimbursed for only the Base Rate (Item 1) for one trip. An Authorized official of the VA may, when in the best interest of the veteran, allow a relative or caregiver to accompany the veteran, but caregiver/relative will have to provide their own transportation home. WAITING TIME: For time lost in waiting at either or both ends of a trip due to causes beyond the Contractor s control, the Contractor will be reimbursed per quarter hour as quoted in the schedule for each quarter hour or fraction thereof in excess of one-quarter hour for the time reported to the designated VA personnel. If the pick-up point is other than the VA Medical Center; the Contractor will call the Travel Clerk first, (304) 623-3461 x3221or Transportation Assistant (304) 623-3461 x4154 during administrative hours (7:30AM through 4:00PM, Monday through Friday) or the Administrative Officer of the Day (AOD) at (304) 623-3461on duty during non-administrative hours (during evenings, nights, weekends, and holidays) as soon as it is anticipated that a delay may develop for which the Contractor expects to claim reimbursement. This call is only for the purpose of verifying the arrival time at the pick-up point and is not necessary if the Contractor anticipates no delay for which reimbursement will be claimed. The Contractor s failure to notify the travel section when waiting beyond the grace period shall result in non-payment for waiting time. COMPLETED TRIP: When ambulance service under the terms of this contract involves pick-up of a patient who is to be brought to this medical center or to another hospital and/or clinic for hospitalization or treatment, the trip will be considered complete when the patient is delivered by ambulance personnel to the admitting/evaluation unit, a specified ward or unit, or to the location specified at the time the trip is requested. NON-PICKUP OF PATIENT: When ambulance service involves a trip to or from this medical center, patient s residence or patient refusal, but due to unforeseen circumstances the patient is not available for pick-up, the Contractor will collect for the trip at the rates applicable under the schedule portion of this contract. The VA reserves the right to substitute patients in these instances to prevent the no-load situation. NON-ARRIVAL OF PATIENT: When ambulance service involves the pick-up of a patient scheduled to arrive by air and the ambulance driver finds such patient does not arrive as scheduled, the ambulance driver will contact the Travel Clerk, Supervisor, Patient Support Unit, or the AOD and inquire as to the status of the arrival. If appropriate, waiting time may be authorized for time lost in waiting in accordance with the rate applicable under the schedule of costs of this contract. If Contractor reported as scheduled and no patient is transported, Contractor will be reimbursed at the rates applicable under the schedule of costs of this contract. RATES: Rates will apply twenty-four hours per day seven days a week. Payment for mileage traveled beyond the county limits will be limited to One Way Only for the distance over which the patient is transported. Such mileage costs will be paid in addition to the applicable rate per trip for any trip entirely within the county limits. Trip mileage shall be determined by the latest edition of the Bing.Com Maps. The Contractor shall receive the base rate quoted in the schedule for all one-way trips ordered. The base rate shall constitute full compensation for one-way trips which do not exceed the mileage threshold as defined herein. The Contractor shall also receive reimbursement of mileage charges for any mileage less than the mileage threshold. The odometer reading at the time of the county line is crossed shall be provided and the odometer reading at the arrival of destination. MILEAGE: For all trips ordered under this solicitation Mileage Threshold is considered to be 50 miles one way. Any trips beyond 50 miles will be subject to mileage. Mileage must be documented on the trip sheet if claimed on the invoice. Allowable charges for mileage: Threshold areas of coverage shall not exceed 5% of the current standard Rand McNally Mileage Guide or its equivalent. Mileage is determined using Bing Maps. PAYMENT: Upon receipt of itemized statement payment will be processed. If itemized statement is not received a 5% penalty will be accessed based on the total monthly bill. Itemized statement includes date, patient s name, social security number, from and to mileage, ALS or BLS, oxygen, charges are to be broken down for each run, total charge each run, and total charge per month. TOLL CHARGES: It is agreed and understood that the prices quoted in the schedule do not include any ferry, bridge, tunnel, or road toll charges. Any such legitimate toll charges incurred shall be limited to one way only and shall be listed separately on the Contractor s invoice. If Contractor s place of business is located beyond the local telephone call zone of this medical center, Contractor agrees to provide a toll-free telephone number or will accept telephone orders for service on a collect basis. ORDERS FOR SERVICES: Personnel authorized by the Contracting Officer shall make requests for service by telephone or Fax. Confirmation of each telephone authorization shall be faxed as soon as possible following the call for service. Request for services will be made to the telephone number specified by the Contractor or to one back-up number in the event of no answer at the primary number specified. All contacts from the Contractor will be with the Travel Clerk at (304) 623-3461 x3221, Transportation Assistant (304) 623-3461 x4154 Mobility Manager (304) 623-3461 x3555 or the Administrative Officer of the Day (AOD) at (304) 623-3461 during non-administrative hours. A list of authorized ordering personnel shall be made available upon award of the contract. Employees may be added or deleted from the list during the term of the contract at the discretion of the Contracting Officer and the COR. The Contractor shall be notified of such changes as they occur. If the VA is unable to establish telephone contact with the Contractor for Basic Life Support (BLS) service within five (5) minutes or if the Contractor fails to furnish BLS ambulance service within a reasonable time, 30 minutes after receiving a request or within 30 minutes of the scheduled pick-up time, the VA reserves the right to obtain the service from another source and to charge the Contractor with any excess costs which may result there from. The VA will be the sole judge in determining when to order service from another source. In no instance will the Contractor be required to furnish more than six (6) ambulances at one time. Advanced Life Support (ALS) will be furnished for only life-threatening transport. If the VA is unable to establish telephone contact with the Contractor for life threatening Advanced Life Support (ALS) service within five (5) minutes at the numbers specified, or Contractor fails to furnish an ALS ambulance within thirty (30) minutes after receiving a request, the VA reserves the right to obtain service from another source and to charge the Contractor with any excess costs which may result. If, within five (5) minutes after receiving a request for ALS service, the Contractor determines they are unable to provide this service within thirty (30) minutes, the Contractor will contact the Harrison County EMS at 911 to respond to the call, providing them with the location and the need for an ALS unit. The Contractor will inform VA of their inability to meet the contractual needs and confirm they have contacted the Harrison County EMS to provide this service. The Contractor will furnish qualified Advanced Cardiac Life Support (ACLS) personnel who are competent to perform ACLS protocols. All ALS ambulance transfers will be staffed by at least one (1) currently licensed paramedic (EMT-P). 5 years of experience providing ALS ambulance service is required RESPONSE TIME: The Contractor shall maintain at a minimum, a 95% compliance rate on response to pick-up or deliver during the contract year. If the Contractor fails to provide service within the time frames specified herein, the Government reserves the option of either obtaining service from an alternate source and charging the Contractor with any excess costs there from (see 9c and 9d above), or assessing a fee for each late pick-up. Compensation will be obtained by deducting the applicable amount from Contractor s invoice as specified below: Minutes Late Deduction 15 to 30 25% of trip value* 31 to 45 50% of trip value* 46 to 60 75% of trip value* 61 or more Trip shall be at no cost to VA *Trip value is the total of the basic trip plus any additional mileage, if applicable, for the scheduled trip. Contractor shall provide a monthly report to the Transportation Assistant which identifies each request for service by patient name, time of receipt of call, whether BLS or ALS unit requested, time of arrival, and time elapsed from receipt of call and time of arrival. Other pertinent information as necessary may be included. This report, in conjunction with VA records, shall be used for calculation of late fees to be deducted from Contractor s invoice, if applicable. REPORTING REQUIREMENTS: For all scheduled appointments for patients entrance to the building will be in the Emergency Room entrance. Direct admissions will enter through the emergency entrance. Ambulance personnel will stop at the Emergency Department desk to let the clerk and nurse know the patient has arrived and to get any additional instructions. Emergent patients will enter the emergency entrance and need to have a warm hand-off to VA clinicians or designees. HARRISON COUNTY LIMITS: Harrison County limits, for the purpose of this contract, are defined as follows: That area that falls within Harrison County, West Virginia, as indicated on the official maps of the State of West Virginia. GOVERNMENT OWNED EQUIPMENT OR SUPPLIES: Any and all government equipment, linens, etc., taken with patients must be returned. The Contractor shall furnish all linens, blankets, and supplies. The VA Medical Center will not participate in a linen exchange program or any supply exchange program. The Contractor shall not be permitted to borrow medical equipment from the Medical facilities. The Contractor shall provide all medications required while in transport, sheets, and blankets and other equipment and supplies required for use while in transport, for direct patient care. Contractor shall at no time and under any circumstances exchange supplies, equipment, and/or medications with the VA. RECORDS: At the option of the Government, the Contractor may be required to transport records with patients from station to station. INCIDENT REPORT: Should an incident and/or accident occur involving the welfare of a beneficiary, the Contractor shall immediately notify the Travel Clerk, Supervisor, or the Administrative Officer (AOD) during evenings, nights, weekends, and holidays. This notification will be made by telephone within one (1) hour. A written report of the incident shall be filed with the Travel Clerk or the Contracting Officer s Representative by the close of business the next business day. The VA reserves the right to conduct patient satisfaction surveys to insure quality service is being provided. A copy of any survey will be provided to the contractor. PATIENT WELFARE AND ABUSE a. The contractor shall be held responsible for patient welfare during transport. The contractor shall be held responsible for patient and/or Government property during transport. Any damaged or lost wheelchairs, walkers, crutches or personal belongings will be replaced by the contractor at no additional cost to the Government or beneficiary. b. The Government requires the contractor to exercise extreme caution and care in the handling of patients. Any abuse of patients will be grounds for default action or Termination of the contract. c. In the event a patient's condition worsens during transport, the Contractor shall transport the patient to the closest facility appropriate for the required care and notify the Travel Clerk, Transportation Assistant, or AOD if during evenings, nights, weekends, and holidays. In the event a patient should expire during transport the Contractor shall notify the Travel Clerk, Transportation Assistant, or AOD if during evenings, nights, weekends, and holidays and return to the VA Medical Center Emergency Room. JOINT COMMISSION STANDARDS: Where the solicitation does not require Joint Commission accreditation or other regulatory body requirements, the Contractor must perform the required work in accordance with the Joint Commission standards. A copy of these standards may be obtained from the Joint Commission, One Renaissance Blvd., and Oakbrook Terrace, IL 60181. VEHICLES: Ambulance used under this contract shall be licensed and shall meet the minimum vehicle requirements as mandated by the West Virginia Department of Transportation. AMBULANCE MEDICAL EQUIPMENT: Each emergency medical care vehicle will have patient compartment facilities, oxygen and suction systems and equipment, environmental climate equipment, communications equipment, and any additional systems, equipment, accessories, and supplies as required by the State of West Virginia. Each advanced life support (ALS) vehicle will have certified paramedics, patient compartment facilities, oxygen, heart monitor, suction systems, and intravenous IV equipment, environmental climate equipment, communications equipment, and any additional systems, equipment, accessories, and supplies as required by the State of West Virginia. PATIENT RIGHTS: The Contractor shall be courteous to VA beneficiaries and shall not smoke/vape while transporting patients. Patients may bring a reasonable amount of belongings such as a personal suitcase. MISCELLANEOUS: At no time will the Contractor leave vehicles on VA premises unless a pick-up or delivery is in process. Once a patient has been removed from vehicle and properly secured with Emergency personnel, the running vehicle will be removed from the Emergency Department exit door to prevent environmental hazards due to exhaust fumes. Contractor employees shall conduct themselves in a business-like manner at all times while on VA premises and while transporting patients. When transporting patients to or from Medical facilities, the driver, acting for the Contractor will ensure that the patient s luggage, medical records, medications, and prosthetic devices are properly accounted for and delivered with the patient as required. Contractor shall provide a Run Sheet as part of the patient s permanent record. This Run Sheet shall include a record of the patient s vital signs, medications used, oxygen use, patient s emotional attitude, and any changes in the patient s condition. The list stated here shall not be construed to be as all-inclusive; the Contractor shall provide all pertinent information. CONFIDENTIALITY: Protects printed and sensitive data in accordance with the provisions of the Privacy Act of 1974 and other applicable laws. Protects the data from unauthorized release or from loss and alterations. TRAINING 1. To be eligible to perform under this contract, each contract employee must meet the minimum training required outline below and minimum contractor furnished training outlined in paragraph (2) (c), (1) Through (8). 2. Contractor Furnished Training. (a)The Contractor shall submit to the Contracting Officer written certification that each contract employee has been trained in the subject areas outlined in paragraph C prior to assignment under this contract. For replacement or new employees documentation of prior training must be submitted or the individual contract employee must complete the required training before being employed in support of this contract. (b)All formal training required shall be administered (i.e., taught, presented) by persons who are certified as being qualified to instruct or teach, the specific subjects or topics required. Certification to instruct the specific subject shall be in the form of a certificate issued by an accredited institution of learning (school, college, university), a governmental (Federal, State, County, etc.) educational certification body (agency, board, commission), or by documentation that the person instructing has sufficient experience in/with the subject to be able to instruct the subject in an authoritative, practical and current manner. (c) In addition to the formal training, the Contractor shall provide 16 hours of orientation training for each employee fourteen (14) days after his or her initial assignment to duty. This orientation may be accomplished while the employees are on duty. The Contractor shall certify to the COR as to the completion of the orientation for each employee within 45 days following assignment to duty. The follow-up orientation should include the following subjects and instructional time periods as well as other subjects as may be required: (1)Accident and incident reporting (2 hours) (2)Safe operation of emergency vehicles (2 hours) (3)Quality Assurance (2 hours) (4)Fire and emergency preparedness planning (2 hours) (5)Handling patient complaints (1 hour) (6)Infection control (2 hours) (7)Universal precautions (policy and procedure) (2 hours) (8)Safety and occupational health procedures (3 hours) 3. Contractor Furnished Training - The Contractor shall submit to the Contracting Officer written certification of the follow-up orientation. 4. The EMT/Paramedics must be enrolled in 'refresher" continuing education, or advanced training programs as required by the local or state government entity in which the service is rendered to veterans or, a yearly basis. Such "refresher" training must be equivalent to that developed by the Department of Transportation or National Highway Safety Administration. Evidence of successful completion for "refresher" training must be provided to the Contracting Officer for inspection. 5. Contractors must complete training courses VA Privacy and Information Security Awareness and Rules of Behavior and HIPAA and Privacy Training on an annual basis while performing under this contract. All documentation must be submitted to the Contracting Officer Representative. PERSONNEL REQUIREMENTS: Minimum of two (2) years experience Minimum Qualifications Standards (1) Contractor Education/Experience: Possess a high school education or equivalency, and have two (2) years of experience demonstrating the ability to meet and deal with the general public, to read, understand and apply printed rules, detailed orders, instructions, and training materials; to maintain pose and self- control under stress; and to construct and write clear, concise, accurate and detailed reports as determined by successful, high level of performance with other customers. Any type of military service may be credited toward meeting the requirements. In lieu of the above, each employee shall have two years of relevant education at a residency school above the high school level, or any combination of relevant education above the high school level and relevant experience totaling two (2) years. (2) Drivers: (a) Education/Experience: Possess a high school education or equivalency, and have two (2) years of experience demonstrating the ability: to meet and deal with the general public; to read, understand and apply printed rules, detailed orders, instructions, and training materials: to maintain pose and self-control under stress; and to construct and write clear, concise, accurate and detailed reports as determined by successful, high level of performance with other clientele. (b) Possesses a valid West Virginia operator's license issued by the State of West Virginia, has not, within the last three years, been convicted of reckless driving or driving under the influence of alcohol or controlled substances and has not had a driver s license suspended under the point system issued by the state. Possess a valid American Red Cross standard first aid and personal safety course card or its equivalent. Drivers must provide full name, date of birth, and social security number to VA prior to operating vehicles with VA beneficiaries. Proof in the form of a current certificate that such first aid training has been successfully completed must be available upon request. (c) Possess a working knowledge of route specific to the area and knowledge of the nearest hospital available. (d) Contractor must provide an annual statement that drivers are screened, trained and competent to safely transport patients. This annual statement of driver competency must include any advanced certifications, such as Advanced Cardiac Life Support or specialized training to assist and secure patients by stretcher or wheelchair. (3) Attendants-Emergency Medical Technician (EMT) and Paramedics Prices quoted in the schedule shall include the services of a minimum of two (2) Emergency- Medical Technicians (EMTs) for BCLS and a minimum of one EMT and one Paramedic for every ACLS Service. In the event the VA Medical Center determines it necessary for the patient to have more than one ACLS attendant at bed side during transport, the Contractor must provide the additional attendant. In the event that the patient being transported requires mechanical ventilation, and the Contractor is responsible for his or her own mechanical ventilator and the care of the patient during transport. In the event that the patient being transported requires accompaniment by an RN, and the Contractor does not supply the RN, an RN will accompany the patient during transport. The RN's responsibilities during transport will be clearly outlined in written physician orders. In the event of emergency the care of the patient in transport will be the responsibility of the EMT/Paramedic. EMT's and Paramedics must provide full name, date of birth and Social Security Number to VA prior to assignments on vehicles with VA Beneficiaries. Paramedics in addition to b (2) (a) above will be licensed in advanced and basic life support and having completed an appropriate training course in the last two years. Attendant should have a minimum of four hours of training in crisis intervention (documented), since some of the patients requiring an attendant will be a psychiatric patient. An attendant will always be required for stretcher patients strictly for their safety during the trip and help during transfer to and from van. EMT's in addition to b (2) (a) above licensed in basic life support and having completed an appropriate training course in the last two years. (4) Age: Contractor and employees performing work under this contract shall be a minimum of eighteen (18) years of age or as required by local laws. (5) Health and Physical Fitness Requirements: (a) All employees assigned by the Contractor to work under this contract shall be physically able to perform all general duties, functions and activities; shall be free from any communicable disease, shall be in good general health without physical defects or abnormalities which would interfere with the performance of these duties, shall possess binocular vision correctable to 20/30 (Snellen), shall be free of color blindness, and be capable of hearing ordinary conversation at 15 feet with either ear without benefit of a hearing aid. Certify under oath that he is not addicted to alcohol or any controlled substances. Physical examination report to describe above requirements for each driver shall be provided upon request. (b) All employees shall be literate and able to communicate (speak) with clients in English to the extent of reading and understanding printed regulations, detailed written orders, training instructions and material, and shall be able to compose reports which convey complete information. The Contractor is to certify the ability of all employees designated to provide service for this contract. When a patient is transported with any VA owned equipment the equipment shall be returned to the respective VA Medical Center within 24 hours in the same condition as it was released at no addition cost to the Government. CONTRACTOR PROCEDURES FORMS AND REPORTS: Evidence of insurance coverage in the amount stated must be submitted prior to contract award. The contractor must maintain a record of the following procedures, reports, etc. and forward this information upon request if updated information is required after contract award. List of all vehicles, inspection reports of vehicles, driver s licenses, DOT permits, and other applicable licenses. Education training records of contractor employees, orientation, and ongoing training. Written operating plan and procedures for: Accident and incident reporting Safe operation of vehicles Quality Assurance Equipment maintenance and management Fire and emergency preparedness planning Handling patient complaints Infection Control Universal precautions (policy and procedures) Safety and occupational health procedures Emergency procedures to be followed in case of break down when in route. Patient confidentiality, HIPAA/Privacy Act HOURS OF OPERATION AND HOLIDAYS OBSERVED: Normal Medical Center working hours is Monday through Friday 8:00AM to 4:30PM. Off duty hours Friday through Monday, weekends and holidays; however, the contractor is required to provide service 24 hours a day, 7 days a week, including normal duty hours and off duty hours, weekends and holidays. The ten holidays observed by the Federal Government are: New Year s Day, Dr. Martin Luther King s Birthday, Presidents Day, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving, Christmas, and any other day specifically declared by the President of the United States to be a national holiday. Pricing remains the same for holiday transportation. DEFINITIONS: Basic Life Support (BLS): the level of medical care which is used for patients with life threating injuries or illnesses until they can be given medical care at a hospital. BLS is generally used in the pre-hospital setting, and can be provided without medical equipment (IAW Specification KKK-A-1822C). Advanced Life Support (ALS): S set of life-saving protocols and skills that extend BLS to further support the circulation and provide an open-airway and adequate ventilation (breathing) (must be IAW Specification KKK-A-1822C). Capabilities for, but not limited to, Endotracheal Intubation, IV therapy, Cardiac Monitoring, Defibrillation, and Intravenous and Cardiac Drug Therapy. Wheelchair Van: a van capable of transporting a wheelchair bound patient with a driver and attendant that shall assist the patient as necessary; including but not limited to entering and exiting vehicles, entering locating and checking into appointments upon arrival at destination. Minivan: Van capable of transporting a patient that is mostly ambulatory with the driver assisting the patient as necessary; including but not limiting to entering and exiting vehicles; entering, locating and checking into appointments upon arrival at destination. Contracting Officer s Representative (COR) Administrative Officer on Duty (AOD) PERIOD OF PERFORMANCE: The period of service for the base year Line Item 0001 of this contract shall commence on the date of award and continue for twelve (12) months, unless terminated earlier pursuant to the terms of this contract. The contract also includes four (4) additional twelve (12) month option periods to extend the contract if exercised by the Government. BECKLEY STATEMENT OF WORK GENERAL INFORMATION 1. Title of Project: Ambulance Service 2. Scope of Work: Requesting a base (4/1/19-9/30/19) plus 4 contract for ambulance service as follows: Contractor to furnish all personnel and equipment to provide emergent and non-emergent, basic and advanced life support ambulance service, twenty-four (24) hours per day, three hundred sixty-five days per year, to beneficiaries of the Department of Veterans Affairs Medical Center (VAMC) 200 Veterans Avenue, Beckley, WV 25801, in accordance with all terms, conditions, provisions, and referenced materials of this solicitation for a base year (one year from date of award), with four additional one-year option periods, subject to continued need and availability of funds. The VAMC Beckley, WV, area of coverage includes the following counties in West Virginia: Clay, Fayette, Greenbrier, McDowell, Mercer, Monroe, Nicholas, Pocahontas, Raleigh, Summers, and Wyoming, and Tazewell, VA. The intent is to have an all inclusive price to the greatest extent possible without including costly items that would drive the price up for routine transports. Therefore, contractor must indicate service and supplies included in per trip price for Basic and Advance Support and furnish price schedule, as separate attachment, for any services/equipment not included. The VA will consider these "extras" in evaluation for best price. All bid prices are for loaded miles only. All trips made by the contractor for VAMC beneficiaries which will be paid by the VAMC, whether or not they are initiated...
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