Amendment to add business associate agreement
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Page 4 of 20 DESCRIPTION/STATEMENT OF WORK DESCRIPTION/STATEMENT OF WORK: Scope: The contractor shall provide medical transcription services for the Department of Veterans Affairs Eastern Kansas Healt... Page 4 of 20 DESCRIPTION/STATEMENT OF WORK DESCRIPTION/STATEMENT OF WORK: Scope: The contractor shall provide medical transcription services for the Department of Veterans Affairs Eastern Kansas Health Care System, Leavenworth VA Medical Center, Topeka VA Medical Centers, Community Based Outpatient Clinics under both Medical Centers (here after referred to as Eastern Kansas Health Care System in strict accordance with this contract. Medical transcription services shall be provided on an as-needed basis (24/7) for dictated material that includes a high incidence of technical terminology and requires a comprehensive knowledge of the specialized vocabulary particular to a wide variety of medical fields. Material is dictated by many different clinicians, requiring adaptation to various accents, speech, tone, voice, volume, delivery, pronunciations and enunciations. The contractor must be able to adapt to monthly staff changes in various medical specialties. Contractor will transcribe reports utilizing headers and footers (Attachment 1). Contractor will also transmit and/or upload completed reports to Eastern Kansas Health Care System Center using transmission and batch protocols provided by Eastern Kansas Health Care System. Contractors may utilize speech engines at their facilities in performance of this contract. 2. Systems: Contractor shall transcribe medical dictation in a variety of computer generated and/or formatted reports, letter perfect and ready for the physician s signature. Dictations to be transcribed by the Contractor include, but are not limited to: Inpatient Progress Notes, History and Physicals, Operation and Procedure Reports, Radiology and Nuclear Medicine Reports, Outpatient Progress Notes, Consultation Reports (Consults), Discharge and Interim Summaries, Compensation and Pension Exams (C&P), Stats and other miscellaneous reports as directed by Health Information Management System (HIMS) and/or Diagnostic Imaging personnel. Contractor will use their own equipment while providing services to Eastern Kansas Health Care System. Contractor will be provided access to these systems. For Recorded Consents, the contractor s equipment will be utilized. This will require capabilities to allow for teleconferencing with multiple people for conferences or meetings. A minimum of three (3) lines available for the physician, family, and facility administrative staff to conduct proceedings as needed. 3. Term: These services are required for one (1) base year, with the option to renew for four (4) additional one (1) year option periods. The start date for services will begin on August 1, 2023. 4. Prices - All Inclusive: Any equipment, material, training, or other services required in the performance of this contract for which a price is not specifically identified by the Contractor will be considered to be included in the price of another item or provided at no cost to the Government, unless otherwise specified herein. 5. Line Count: Offerors must submit their proposal on a per line basis, not per page, page number, strokes or hour. All transcription shall be accomplished in Times New Roman, Font Size 12. For billing and payment purposes, Eastern Kansas Health Care System will utilize Microsoft (MS) Word s Word Count Software to accurately count the number of characters and lines received by Eastern Kansas Health Care System. This will be done per report, in accordance with the contract definition of a "line". Contractor billing will take place from this software. Eastern Kansas Health Care System will calculate transcribed lines as defined in Definitions (h) on pages 18. B. SPECIAL TERMS & CONDITIONS: 1. Dictation Subjects: Some of the medical reports to be transcribed include, but are not limited to, Discharge Summaries, Operative Reports, History and Physical Report, Consultation Report, Radiology Reports, Nuclear Medicine Reports, Special Procedures, Compensation and Pension (C&P) Exam Reports (specific history and physical), miscellaneous medical, anatomic pathology, and other administrative reports as required. The specialized vocabularies used will encompass a variety of subjects in the field of Medicine, Surgery, and Psychiatry to include Anesthesiology, Cardiology, Dermatology, Dentistry, Drug and Alcohol Treatment, Endocrinology, Gastroenterology, General Medicine, General Psychiatry, General Surgery, Hematology, Immunology, Neurology, Neurosurgery, Oncology, Pulmonary Disease, Radiology, Renal Disease, Rheumatology, and others. 2. Preparation and Format of Reports: A. General Format: The length of each report will vary according to the type of medical report required. The reports will be created and saved as ASCII text - only printable characters, single spaces, and . The text is single spaced with double space between paragraphs. No report shall include any text other than what was dictated; comments or questions must be sent as separate correspondence referencing the dictation system job number. Typed comments or questions are not counted as billable. B. Format of Documents: Contractor shall be able to format types of documents in accordance with the needs of VA Heartland Medical Center. Formatting for the transmission shall be in the manner specified by VA Heartland Medical Center technical staff. This will consist of data to identify the report document type and various patient demographic elements. C. Header and Footer Format: It is the contractor's responsibility to assure that all header and footer information complies with the sample header and footer provided in Attachment 1. VA Heartland Medical Center /Transcription will provide formats for new report types as needed. (1) Header information: Each document will include the specified header conforming to the standard provided by Eastern Kansas Health Care System. This header includes the document type, patient name, patient Social Security Number, date of encounter, date of surgery, date of admission, date of visit and location of visit, the document author, dictation date and the attending physician (attending physician is not required for Compensation & Pension exams). (2) Footer information: The first line of the footer will include the initials of the author and transcriptionist. The second line of the footer will include the Dictation date and time. The third line of the footer will include the Transcription date and time. The fourth line of the footer will include the job number. 3. Transmission of Documents to Eastern Kansas Health Care System: A. Destination of transcribed documents: Eastern Kansas Health Care System requires transcribed documents to be uploaded by a batch and transmitted to the VISN 15 VISTA. At each transmission of transcribed reports, an accompanying daily log sheet shall be provided. Transmissions will occur multiple times a day and are to be electronically submitted to the Eastern Kansas Health Care System / Transcription and Radiology Departments. B. Frequency of Transmission: Transcribed documents, except C&P Reports (see (c) (1) below), will be transmitted to Eastern Kansas Health Care System frequently enough to meet TAT times. C. Format & Protocol of Transmission: The contractor may use a direct XML data transfer or up to date NIST, FIPS, FISMA compliant transmission process for transmitting properly formatted documents to the Eastern Kansas Health Care System. Contractor is also responsible for provision of telecommunications application that is compatible with and will utilize the secure file transfer methods agreed upon by Eastern Kansas Health Care System Compensation & Pension (C&P) reports: The contractor shall upload reports into the patient record as they are transcribed. Contractor may be further instructed by some facilities to upload as Attachment 1, Progress Notes. Medical Reports (Non-C&P): For work that is to be batch transmitted to the Eastern Kansas Health Care System file server (PC), the contractor will transmit via the contractor's communication software. Separate batch files must be uploaded for each report type. Each batch will include a daily log listing the documents included in the batch. The reports transmitted in each batch must adhere to the file naming conventions provided by Eastern Kansas Health Care System in Attachment 1. An electronic submission is required for those documents which are not able to be uploaded. D. STAT reports are required under this contract; however, if an emergency arises, Eastern Kansas Health Care System will request a STAT report from the contractor telephonically and/or electronically, along with any instructions to the contractor regarding a timeliness of this special delivery. Any report designated as STAT by Eastern Kansas Health Care System /Transcription will be transcribed by the Contractor within two (2) hours. The contractor shall upload these reports into the patient record as they are transcribed. 4. Completed Work: Contractor shall provide the completed work in ASCII language. It shall be transmitted to the VA Medical Center VISTA computer systems transmission protocol, agreed upon by VA Medical Center and Contractor. 5. Completed Documents: Documents shall be in final form and in accordance with the quality standards called for under the contract. Completed documents shall be transmitted with appropriate document header to facilitate receipt of the documents by VISN 15 VISTA computer systems. 6. Control of Documents: The Contractor shall provide daily logs which identify the number of reports typed, with associated characters, lines per individual reports, patient names, patient Social Security Numbers, type of report, dictation identification number, time report was dictated, time report was transcribed, and time report was uploaded to accompany delivery of finished work. This daily log shall also provide the total line count for all reports typed. All work shall be safeguarded from any type of delivery until Eastern Kansas Health Care System takes custody. 7. Quality Assurance: A. Quality Standards: The Contractor shall maintain a quality standard of ninety-eight percent (98%) accuracy or better. Percentage is based on ratio of errors to lines. (Example: 1000 lines produced, 20 errors: 20/1000=0.02 or 2% errors. Accuracy is 98%.). This standard will be applied on a monthly basis by the individual Eastern Kansas Health Care System facilities. Unacceptable errors are considered to be: Incorrect or omitted medical terminology that is clearly dictated Typographical errors Punctuation or spelling which changes the meaning of the sentence Transposed words or numbers Entering material that is not dictated Unauthorized abbreviations (Note: only abbreviations listed in accordance with Eastern Kansas Health Care System site specific abbreviation policies will be used in the patient records. These will be provided to the contractor upon award of contract by VA Heartland Medical Center.) Misspelled words that would have been caught by a spell-check program Misspelled words that would have been caught by a medical terms spell-check program Information located under wrong heading within the document or under the wrong document type Any report, which does not meet the Quality Standards outlined above, shall be returned to the contractor for correction. The report shall be corrected within four (4) hours of receipt at no additional expense to Eastern Kansas Health Care System. If not completed within the four (4) hours of receipt there will be no charge to Eastern Kansas Health Care System. B. Eastern Kansas Health Care System Quality Monitors: Eastern Kansas Health Care System staff will select a random sampling of reports per month for quality review. This will be done by comparing the completed report with the dictation. Both the transcribed report and the headers and footers will be monitored for accuracy. The sampling may be either a sampling of all reports or a subset of reports. If the review shows that the accuracy rate has fallen below 98% on the sample for two (2) consecutive months, work performance will be deemed unacceptable and will be cause for termination of the contract. 8. Proof reading: Contractor will proofread all reports for compliance with established format for each work type and make any necessary corrections. For any words or phrases that cannot be transcribed due to difficulties in hearing and/or understanding the dictators voice the transcriptionist shall type six (6) characters defined by Eastern Kansas Health Care System. These characters will be required for all transcribed reports (i.e. ___@@@ ). Eastern Kansas Health Care System Radiology departments may require five (5) characters to be typed. 9. Spell check: Contractor will use a medical spell checker on each document and perform corrections for spelling and grammar. 10. Turnaround Time (TAT): TAT Reports shall be typed in the priority indicated below: A. Stat Requests 2 hours B. Inpatient Progress Notes 2 hours C. History and Physical 2 hours D. Operative/Procedure Reports 4 hours E. Radiology/Nuclear Medicine Reports 4 hours F. Compensation and Pension (C&P) 12 hours G. Outpatient Progress Notes 24 hours H. Consults 24 hours I. Discharge/Interim Summaries 24 hours J. Recorded Consents 24 hours K. Cardiology 24 hours L. Other Reports 24 hours Transcription not completed within the required turnaround time shall be brought to the COR s attention. There shall be NO CHARGE to the Eastern Kansas Health Care System for transcription not delivered within the specified time frames, except in situations where Eastern Kansas Health Care System Facility is the cause for the delay. This deduction will be calculated by the individual Eastern Kansas Health Care System Facilities on a monthly basis. At least 95% of all reports shall meet TAT requirements during each monthly billing cycle. If the TAT falls below 95% for two (2) consecutive months, work performance will be deemed unacceptable and will be cause for termination of the contract. CLIN * REPORT TYPE TURN AROUND TIME (TAT) HOURS EST. REPORTS EST. LINES 1. STAT 2 100 5,500.00 2. Inpatient Progress Notes 2 100 5,500.00 3. History & Physicals 2 72 1,412.00 1,412.00 4. Operative/Procedure Reports 4 720 27,033.60 5. Radiology/Nuclear Medicine Reports 4 0 0.00 6. Compensation & Pension (C&P) 12 0 0.00 7. Outpatient Progress Notes 24 48 853.80 8. Consults 24 216 7,880.76 9. Discharge/Interim Summaries 24 0 0.00 10. Recorded Consents 24 0 0.00 11. Cardiology 24 0 0.00 ESTIMATED TOTA AL LINES 48,180.16 11. Duplicate Documents: Reports received (uploaded) by Contractor in duplicate will not be billed to Eastern Kansas Health Care System twice. Consistent loading of duplicate reports will be cause for VA Heartland Medical Center to terminate the contract. 12. Records Storage/Security: Contractor will have the plant security and ADP security necessary to safeguard Eastern Kansas Health Care System records. The contractor shall maintain and provide backup media of transcribed material, upon request, for a period of 12 months. Contractor shall purge on a monthly basis anything greater than 12 months old. Each permanent destruction/deletion of medical records shall be certified to the COR at Eastern Kansas Health Care System. 13. The Privacy Act and the Health Insurance Portability and Accountability Act (HIPAA): The contractor shall comply with the provisions of the Privacy Act of 1974, and the Health Insurance Portability and Accountability Act (HIPAA) of 1996, as well as all applicable VHA regulations. Contractor shall insure the confidentiality of all patient and employee information and shall be held liable in the event of a breech of confidentiality. Any person who knowingly or willingly discloses confidential information obtained from the VA may be subject to fines. The Contractor shall not maintain, in any form, any sensitive or patient identified information except as noted in Paragraph 12, Records Storage/Security above. The Contractor shall comply with the Privacy Act/HIPAA as it pertains to general patient information, HIV, Drug and Alcohol Abuse, and Sickle Cell Anemia. 14. Billing and Invoices: Invoice shall be submitted monthly in arrears to the Eastern Kansas Health Care System Invoices received from the Contractor shall provide sufficient detail to validate line counts. Each invoice (or delivery ticket) will list daily logs with the corresponding line counts for the identified month. The line counts for the daily logs on the invoice shall be totaled at the end of the invoice. The COR will review a proposed draft of the invoice prior to award of contract. Any changes to the billing/invoice procedures must be approved by the COR prior to implementation. Frequent and/or major discrepancies will prompt a full investigation of the billing procedures of the Contractor. In the event the Eastern Kansas Health Care System is unable to substantiate line counts, the contractor shall be required to provide their billing copies and their personnel to accomplish the recount and resolve discrepancies. Payment will be held in abeyance until such time as verification is provided and the discrepancies are resolved to the satisfaction of the COR. 15. Workload Fluctuation: Prior to contract award the contractor shall have a written plan to address periodic fluctuations in Eastern Kansas Health Care System workload. 16. Information Technology: All information technology used in performance of this contract shall be compatible with Eastern Kansas Health Care System systems and shall be virus-free. If software updates are required, i.e. for the dictation system, these costs will be incurred by the contractor. Contractor must follow Guidelines for use of VA Heartland Medical Center computing resources. 17. Contractor Owned Equipment Failure: Contractor will notify Eastern Kansas Health Care System of all problems that are anticipated to keep equipment out of use for a period of time greater than one (1) hour, or when transmission times are delayed more than 30 minutes. Any planned down-time for maintenance of contractor-owned equipment will need to be communicated to Eastern Kansas Health Care System Center no less than three (3) days in advance. In case of contractor down-time that exceeds two (2) hours, contractor will provide alternate services consistent with the terms of this contract. If a cassette dictation system is the alternate service in the event of dictation equipment failure or down-time, the cassette dictation system and cassettes will be provided by the contractor. This system will need to be able to be accessed by a toll-free number. The contractor shall not be penalized for transcription delays due to equipment failure that is caused by Eastern Kansas Health Care System Facilities (i.e., VISTA down-time). 18. Contractor owned dictation system: If, and when necessary, the contractor will provide a Contractor owned/leased dictation system service for Eastern Kansas Health Care System Facility for unanticipated or anticipated dictations system downtimes. The hospital at any time may encounter a downtime, which would require the usage of the Contractor owned dictation system service which will be at no cost to Eastern Kansas Health Care System. The Contractor-owned system shall be accessed by a toll-free (to the Government) telephone number, with sufficient lines that access will not be an issue. This telephone number shall be made available at the award of the contract. Usage of this system shall be at the discretion of each facility. 19. Contractor Training of Eastern Kansas Health Care System Staff: The Contractor shall provide training for authorized Government staff at VA Heartland Medical Center to assure appropriate use of the contractor-owned dictation system at the beginning of the contract period and annually thereafter. Annual training shall take place one (1) year from the date of the beginning of the contract period and shall be coordinated with the COR. Training shall be of sufficient length to cover all aspects of the dictation system (e.g., how to dictate, access the recorded voice, check turn-around time, calculate and validate the number of lines received, access transcribed documents from the contractor s database, and reach the Help Desk, as well as who to call and where to get help in the event of hardware failure, etc.) Contractor will also provide handouts (i.e., step-by-step instructions, etc.) explaining each process in detail. Location of training will be coordinated with the VA Heartland Medical Center /Transcription at each facility under this contract. The Contractor shall provide training for authorized Government staff at each Eastern Kansas Health Care System Facility when Contractor procedure protocols change due to technological improvements and/or software enhancements. Training shall occur prior to implementation of any change by the Contractor at no cost incurred to the Eastern Kansas Health Care System. C. SPECIAL GOVERNMENT RESPONSIBILITIES: 1. To provide electronic access to the Eastern Kansas Health Care System computer and dictation systems. 2. To provide training to contractor staff, to include upload staff if applicable, during a 60-day phase-in period between contract award and the commencement of live production. A reasonable amount of consultation with designated Government Computer Staff will be available as needed. 3. Eastern Kansas Health Care System will provide a list of staff and residents, as well as rotation schedules when applicable. 4. Eastern Kansas Health Care System will provide templates for reports and header and footer formats. 5. Eastern Kansas Health Care System will provide advance notification whenever possible, regarding workflow fluctuations, or other changes that impact contractor performance. 6. Eastern Kansas Health Care System will hold meetings annually, monthly or at other increments, as mutually agreed upon between the VA Heartland Medical Center and the contractor. D. SPECIAL CONTRACTOR RESPONSIBILITES: 1. Appoint a primary and alternate Point of Contact (POC), by name, telephone and fax number, who will function as a liaison with the COR on the day-to-day operations, and who will be available during normal business hours (8:00 a.m. 4:30 p.m.), five (5) days a week. This person should oversee contractor personnel and ensure compliance with the provisions of this contract. They should have full authority to act on behalf of the contractor to handle day-to-day problems as they arise. 2. Appoint a company officer who is authorized to resolve ongoing problems at the operations level. Provide the name, telephone and fax number of this individual. 3. Dictaphone recommends that transcriptionists have specific equipment when transcribing reports from VA Heartland Medical Center Facility Dictaphone Enterprise Express VOICE and TEXT systems. It will be the contractor s responsibility to ensure that these are available. 4. Contractors are required to submit a signed Business Associate Agreement (BAA) to Eastern Kansas Health Care System Facilities unless the contractor has signed a BAA with the VHA. A signed BAA shall be included in the contractor response to this solicitation. Any questions regarding this matter shall be directed to the Contracting Officer. E. CONTRACTOR QUALIFICATIONS: 1. Offers will be considered only from offerors who are regularly established in the transcription business. In addition, the contractor must be, in the judgment of the Contracting Officer, financially responsible and able to show evidence of resources, experience and qualifications necessary to render services in accordance with the contract requirements. 2. The contractor must have the ability to work with the various dictation systems within the Eastern Kansas Health Care System F. CONTRACT ADMINISTRATION: 1. Day to day communications will occur between both the contractor s primary or alternate POC and the Eastern Kansas Health Care System COR (or designated staff). Any problems that are unresolved at this level will be referred to the VISN 15 Contracting Officer and the contractor's designated operations level officer. 2. Utilizing the MS line count software defined under DEFINITION (h), the contractor will submit invoices monthly in arrears. Any appropriate TAT deductions will be suspended from the payment by Eastern Kansas Health Care System. The Eastern Kansas Health Care System TAT report will be sent to the contractor attached to bill payment for those reports not meeting TAT requirements. G. KEY PERSONNEL AND TEMPORARY EMERGENCY SUBSTITUTIONS: The Contractor shall assign to this contract a primary and alternate POC as well as a company officer who is authorized to resolve ongoing problems at the operations level. These individuals will be designated as Key Personnel. During the first ninety (90) days of performance, the contractor shall make NO substitutions of the key personnel unless the substitution is necessitated by illness, death, or termination of employment. The contractor shall notify the Contracting Officer, in writing, within 5 calendar days after the occurrence of any of these events. H. CONFIDENTIALITY OF PATIENT RECORDS: 1. The Contractor is a VISN 15 contractor and will assist in the provision of health care to patients seeking such care from or through VA. As such, the Contractor is considered as being part of the Department health care activity. Contractor is considered to be a VA contractor for purposes of the Privacy Act, Title 5 U.S.C. 552a. Further, for the purpose of VA records access and patient confidentiality, Contractor is considered to be a VA contractor for the following provisions: Title 38 U.S.C. 5701, 5705, and 7362. Therefore, Contractor may have access, as would other appropriate components of VA, to patient medical records including patient treatment records pertaining to drug and alcohol abuse, HIV, and sickle cell anemia, to the extent necessary to perform its contractual responsibilities. However, like other components of the Department, and not withstanding any other provisions of the contract, the Contractor is restricted from making disclosures of VA records, or information contained in such records, to which it may have access, except to the extent that explicit disclosure authority from VA has been received. The Contractor is subject to the same penalties and liabilities for unauthorized disclosures of such records as VA. 2. The records referred to above shall be and remain the property of VA and shall not be removed or transferred from VA except in accordance with U.S.C.551a (Privacy Act), 38 U.S.C. 5701 (Confidentiality of claimants records), 5 U.S.C. 552 (FOIA), 38 U.S.C. 5705 (Confidentiality of Medical Quality Assurance Records) 38 U.S.C. 7332 (Confidentiality of certain medical records) and federal laws, rules and regulations. Subject to applicable federal confidentiality or privacy laws, the Contractor, or their designated representatives, and designated representatives of federal regulatory agencies having jurisdiction over Contractor, may have access to VA s records, at VA s place of business on request during normal business hours, to inspect and review and make copies of such records. I. COMPUTER SECURITY REQUIREMENTS: 1. Contract Personnel: A. The contractor must provide immediate notification to the VA assigned ISO when an employee that has been given access to VA sensitive systems or data transfers to a different job and no longer requires access or when an individual is no longer employed. B. All contract employees and subcontractors under this contract who will be accessing the VA computer network or VA sensitive data are required to complete the VA s Information (Cyber) Security Awareness Training course annually. C. All contractors and business associates must receive privacy training. This requirement is met by receiving VHA National Privacy training or contractor furnished training that meets the requirements for the HHS Standards for Privacy of Individually-identifiable Health Information as determined by VHA. Proof of training is required. D. Contractor users who have access to VA sensitive information or systems will sign the VISN 15 VAMC Rules of Behavior (Computer Access Agreement) annually. (NOTE: Other Rules of Behavior such as VPN rules of behavior may also require signatures based on which systems the non-VA user accesses.) E. Contractor users who have access to VA sensitive information, systems or areas will complete background investigations as described in Security Appendix. F. Contractor staff will not access VA systems or data beyond that which is absolutely necessary to complete the terms of the contract. G. Documentation: (1) A copy of each users signed VA Rules of Behavior will be submitted to the VA assigned ISO prior to the user accessing VA sensitive data or VA networks and annually afterwards by the 12 month anniversary of this initial signing. (2) Documentation that the users have completed the VA Information (Cyber) Security Awareness Training course. (3) Documentation that the users have completed the VA Privacy Awareness Training course. (4) A Remote User Data Form will be filled out for each user to be given access to VA systems or a remote data connection to the VA network. (5) Documentation that users have completed background investigations. (See Security Appendix) 2. Sensitive Data: A. The contractor shall agree that all deliverables, associated working papers, and other material deemed relevant by the contractor in the performance of this task order are the property of the United States Government. The Contractor will treat all individually identifiable health information with the strictest confidentiality. Access to records shall be limited to essential personnel only. Records shall be secured when not in use. At the conclusion of the contract, all copies of individually identifiable health records shall be destroyed or returned to the VA. Any individually identifiable health records shall be deleted from computers not belonging to the VA. The contractor shall comply with the Privacy Act, 38 U.S.C. 5701, 38 U.S.C. 7332, and 5 U.S.C. 552(a) et. Seq. B. Upon termination of the contract, computer equipment or other devices that have stored or processed sensitive data used in performance of contractual obligations will be sanitized according to VA standards and guidelines. Hard drives owned or used by the contractor that store VA patient sensitive data will be either sanitized by a method approved by the VA or turned over to the VA for sanitization at the end of the contract. Items turned over to the VA for sanitization will not be returned to the contractor. There are multiple approved processes for sanitizing information, in general, multi-pass wipe and write methods are required. The contractor will submit their proposed method for sanitization to the VA for approval. C. If contractor equipment or devices that have stored VA sensitive data are taken out of use, disposed of or sold as salvage the contractor will certify that any confidential or private information is rendered totally unrecoverable before releasing or disposing of the equipment or components such as RAM, Flash memory, printed reports, or other items that store information. D. Paper, plastic or other similar based media containing VA sensitive data that is not sent to the VA will be properly disposed of by the contractor by methods such as shredders with no larger than 1/8 inch width cuts and then cross cut. Such media will be destroyed such that information may not be retrieved. Media with small print, such as microfilm will be completely destroyed such as to render the information unrecoverable. E. The contractor will be diligent to make sure that VA sensitive data is protected from being viewed by those unapproved to see such data. F. The contractor will take due diligence to make ...
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