Inactive

The North Texas VA Health Care System (NTVAHCS) in Dallas, Texas is seeking Service Disabled Veteran Owned Small Business (SDVOSB), Veteran Owned Small Business (VOSB), or Small Business sources capab... The North Texas VA Health Care System (NTVAHCS) in Dallas, Texas is seeking Service Disabled Veteran Owned Small Business (SDVOSB), Veteran Owned Small Business (VOSB), or Small Business sources capable of meeting the requirement listed below. The acquisition will be accomplished using commercial item procedures in accordance with FAR Part 12. NOTE: TO QUALIFY SDVOSB AND VOSB VENDORS MUST BE CERTIFIED IN THE VA VENDOR INFORMATION PAGES (VIP) DATABASE. The North American Industry Classification System (NAICS) is 325413. Any SDVOSB, VOSB, or Small Business firms who wish to identify their interests and capability to provide this product must provide product specifications, performance and delivery information by notifying the Contract Specialist no later than 11 AM Central Time, August 24, 2023. Notification shall be e-mailed to Akisha Woods, at akisha.woods@va.gov. Any vendor who responds to this Notice must provide credentials to perform the requirement as outlined in the below scope. DISCLAIMER This Sources Sought Notice is issued solely for information and planning purposes only and does not constitute a solicitation. All information received in response to this Notice that is marked as proprietary will be handled accordingly. In accordance with the Federal Acquisition Regulation, responses to this notice are not offers and cannot be accepted by the Government to form a binding contract. Responders are solely responsible for all expenses associated with responding to this Notice. 5-6 The purpose of this contract is to provide quality laboratory services to Veteran patients. Contractor is to provide healthcare resources in accordance with Public Law 104.262 and 38 U.S.C. 8153. Contractor agrees to provide the following laboratory procedures/tests within the current published turnaround times in support of the VA North Texas Health Care System (VANTHCS) in Dallas, Texas. Pricing includes all labor, materials, equipment and supplies necessary to perform certain human laboratory procedures/tests. Total annual estimated test volume is less than 50. The following menu is required but not limited. VANTHCS is not limited only to these tests for utilization. Test requests are dependent on the ordering physicians at VANTHCS. Contractor shall perform and provide results for, the following tests: Item Number Test Name Test Codes Estimated Annual Test Volume 1 Adenosine Deaminase in Pericardial Fluid 3002984 3 2 Cytokine Panel 13, CSF 3003259 10 3 Meningitis Encephalitis Panel by PCR 2013305 10 4 Susceptibility, Individual MIC 0060201 5 5 Miscellaneous Test request, reserved for additional laboratory tests not yet developed or listed in contract or part of the price schedule. variable 1 WORK STATEMENT Contractor shall provide laboratory services to the Pathology & Laboratory Medicine Service of the VA North Texas Health Care System, Department of Veterans Affairs Medical Center, located at 4500 S. Lancaster Road, Dallas, Texas. Tests will be performed as prescribed by the VA attending physician. VA North Texas Health Care System (VANTHCS) makes no guarantee as to what volume of tests, if any, the contractor may receive. VANTHCS reserves the right to request additional tests other than those listed within. If additional tests are added, either by the contractor or VANTHCS, the contractor will provide appropriate CPT and LOINC codes, pricing, and sample reports for the new tests. Contractor shall provide to the methodology and ranges for results on any tests that are requested by representatives of VANTHCS. Only fully licensed/ CLIA-accredited laboratories actively engaged in providing the specific services and laboratory testing outlined in this solicitation shall be considered. Contractor shall provide laboratory services to include analysis, reporting of analytic results, and consultation regarding selection, collection, transportation, and result interpretation. These procedures/tests shall be performed to the satisfaction of VA North Texas Health Care System (VANTHCS) Pathology & Laboratory Medicine Service, Chief of Staff, and the Contracting Officer s Representative (COR). Contractor shall provide all labor, equipment, and materials required to perform procedures/tests as stated herein. Contractor shall supply transport tubes, specimen bags, test kits and collection containers as indicated. Supplies will be delivered at no charge at the request of P&LMS personnel and/or through vendor s inventory system. Specimens submitted are human blood, body fluids, and tissue for diagnostic testing. Results are to be accessible through the contractor s electronic database by P&LMS personnel. Contractor will consult with VANTHCS laboratory personnel on test results as needed. Contractor shall provide to VANTHCS the methodology, ranges, and expected turnaround time for results on any tests that are requested. All lab results shall be ordered and reported electronically through the contractor s secured on-line website. Contractor shall have the ability to interface with VANTHCS for order and result submission. Contractor shall maintain a searchable test database that contains the minimum information: Test Name Test Description Test Code Specimen Requirements to include: Collection instructions Storage and Shipping instructions Rejection Criteria Turnaround time Set up day(s) The Contractor may add new tests to the base FSS contract over the course of the contract performance as test volumes increase or when new technology becomes available. Since not all tests may be listed on the contract, due to low volume testing or facility preferences, any test that appears on the Federal Supply Schedule (FSS) fee schedule shall be billed at the FSS fee schedule amount. The Contractor shall supply a list of all tests on the FSS with their associated costs. Tests ordered that do not appear on either schedule shall be offered by the Contractor and will be billed at the fair/open market rate. Contract shall cover a period from October 1, 2023, through September 30, 2028. Contract will be renewable for (4) option years. Pricing will be provided for the base year and each option year. Base October 1, 2023, through September 30, 2024 Option 1 October 1, 2024, through September 30, 2025 Option 2 October 1, 2025, through September 30, 2026 Option 3 October 1, 2026, through September 30, 2027 Option 4 October 1, 2027, through September 30, 2028 These procedures/tests shall be performed to the satisfaction of Quality Assurance Surveillance Plan (QASP) outlined in this document. Services rendered will be verified by a record keeping system maintained by Pathology & Laboratory Medicine Service and Fiscal Service at VANTHCS, which assures that the VA pays for only those services requested, and only for valid patients of VANTHCS. Services rendered will be verified by a record keeping system maintained by Pathology & Laboratory Medicine Service and Fiscal Service at VANTHCS, which assures that the VA pays for only those services requested, and only for valid patients of VANTHCS. The Contractor shall reimburse the facility for any costs/supplies related to tests sent to a referral laboratory when testing is not available through no fault of the facility due to reagent problems, other product issues, instrumentation failure, or other factors. The assessed damages shall be applied to the invoice in the form of a credit or deduction. The Contractor recognizes that the services under this contract are vital to the Government and must be continued without interruption and that, upon contract expiration, a successor, either the Government or another contractor, may continue them. The Contractor agrees to (1) furnish phase-in training and (2) exercise its best efforts and cooperation to affect an orderly and efficient transition to a successor. Security Requirements: VA Protected Health Information is provided to the vendor under this contract. This contract is to enable a HIPAA Covered Entity to provide clinical services on behalf of VA.  A patient s consent is not required (1605.1P24). The vendor is required to secure the PHI as required by HIPAA. See below. EVALUATION CRITERIA SECTION A: REQUIRED DOCUMENTS The Contractor shall provide the following documentation with their offer: Response to solicitation including pricing Proof of CLIA Accredited laboratory certification. Link to catalog that includes test menu and turnaround times. Testing must be performed on-site at the laboratory. Professional Staff Curricula Vitae. CAP and/or any other Proficiency Exam Participation and Exception Reports for the past two (2) years. Performance improvement monitor data for the previous 12 months that include and are not limited to demonstration of: Number of lost/damaged specimens Number of cancelled specimens Delays in turnaround times (including but not limited to lack of staffing, lack of availability of reagents, instrumentation issues, etc.), Resolution of complaints Number of corrected reports issued Errors in reporting patient results Courier route delays/cancellations Three (3) references of current or prior contracts, consisting of at least two (2) governmental, including one federal, who can attest to the duration of overall service and performance and of documentation of successful interfacing. References to include the facility address, telephone number, email address, and contact person s name who can validate experience within the last two (2) years. SECTION B: REQUIREMENTS/SPECIFICATIONS ORDERING AND REPORTING OF LAB REPORTS RESULTS: All lab results shall be ordered and reported electronically through the contractor s secured on-line website and pushed to VistA through Data Innovations or LEDI. If electronic retrieval of lab reports is unavailable for an extended period, results may be sent by secured fax and retransmitted electronically when the issue is resolved. Test reports that cannot be transmitted to VistA, such as those that contain graphs, symbols, or colors that are integral to the result shall be available via the vendor s website for download. LAB REPORTS: All lab reports shall contain at a minimum the following information: Patient's full name Patient s identification number Specimen Identification Number Patient s Date of Birth Physician's name (if supplied) Patient's location (clinic/ward) (if supplied) Test ordered Date/time of specimen collection Date/time test completed Test result Reference intervals Toxic and therapeutic ranges, if applicable Flagged abnormal test results Reference laboratory specimen number Name and address of testing laboratory Any other information the laboratory has that may indicate questionable validity of test results Unsatisfactory specimen shall be reported with documentation supporting its unsuitability for testing Notification of a test result that has been identified in the commercial reference Contractor laboratory as a critical or alert value shall be communicated by telephone to VANTHCS. A hard copy result must follow any telephonic reporting either by fax or computer-generated report. Contractor shall provide daily, a report listing all delayed results and an updated completion estimate. The Contractor shall state their policy and any associated fees for repeat testing if requested by the provider. TURNAROUND TIMES: The Contractor shall provide timely (defined by the minimum and maximum turnaround times detailed in the description of requirements) and appropriate testing of patient specimens as requested by VANTHCS. Test results shall be received within 24 hours following specimen pick-up either by hard copy or electronic report transmission. It is recognized that certain test procedures will require a longer turn-around time than the 24 hours. The Contractor shall provide a list of the estimated turn-around time for any tests that require longer than 24 hours to complete. The status and the results of testing are available within published timeframes and easily retrievable using varying options. Examples of these options are through a patient search, a sort by timeframe, a sort by test, a sort of incomplete tests, etc. Incomplete tests shall have an indication of the pending time until completion. Alert messages are generated when testing is delayed beyond published timeframes, when specimens require additional testing (reflex), or when specimens are cancelled due to unacceptability. Reports of test results shall be immediately available upon verification of the test result. The computer must be able to print test results upon request and reprint retrospective test results according to a defined timeframe. SPECIMEN IDENTIFICATION: VANTHCS will provide laboratory specimens properly collected identified with both the Patient s Identification (as utilized by each facility) and requested tests. For those specimens that require special handling, the Contractor shall provide at no additional charge an adequate supply of specimen collection materials for such testing that is destined to the commercial reference laboratory for analysis (i.e., stabilizing tablets, ice packets, 24-hour collection container with preservatives, special collection tubes, etc.). TRANSPORTATION SERVICES: A. The Contractor shall provide specimen pick-up/delivery services regardless of the number of specimens picked up. Contractor shall transport specimens in such a manner as to ensure the integrity and quality of the specimen. B. Contractor will arrange for daily pickup Monday through Friday excluding National holidays from the Laboratory at Dallas VA Medical Center, 4500 S. Lancaster Rd., Dallas, TX 75216. Change in frequency of routine pickups will be negotiated between contractor and VANTHCS. VANTHCS may exercise the right to adjust the transportation schedule with respect to the timetable and the number of daily pick-ups. The Contractor shall be responsible for ensuring that all transport personnel are trained and follow the storage requirements for all laboratory specimens and that their competency is regularly assessed in appropriate safety and packaging procedures suitable to specimen type and distances transported. This shall include issues such as adherence to regulations for transport of biohazards, use of rigid containers where appropriate, temperature control, notification procedures in case of accident or spills, etc. During the term of this contract, this program may need to be updated and/or revised to comply with regulatory requirements. This documentation shall be made available to the VISN 17 facilities upon their request. CUSTOMER SUPPORT: Contractor shall be responsible for providing services in between the hours of 8:00am and 4:30pm Monday through Friday excluding Federal Holidays. Federal Holidays are as follows: New Years Day, Martin Luther King s Birthday, President s Day, Memorial Day, Juneteenth, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, Christmas Day and any other day specifically designated as a national holiday by the President of the United States. Telephone inquiries are divided into four major categories with additional subcategories defining the type of inquiry and the VA minimum time expectation for meeting this service: Specimen Collection Routine inquiries where the reference laboratory performs the actual testing - if further clarification on the collection requirements is needed, shall be addressed at the time of the inquiry. Esoteric inquiries, where the information on the availability and/or requirements of the questioned test requires further research, shall be addressed within 1 day of the initial inquiry. Testing Status of Ordered Testing - inquiries regarding the status of pending orders shall be addressed at the time of the inquiry. Esoteric inquiries where information is requested regarding methodology, correlation, interferences, reflex tests, etc. shall be addressed within 1 day of the initial inquiry. Technical Expertise Test utilization inquiries where information is required as to the most appropriate test to be ordered shall be addressed within 1 day of initial inquiry. Result interpretation inquiries shall be addressed within an appropriate timeframe. Consultative services where information is required regarding the clinical significance of test or inquiries by the provider into what is the best test to order for more effective patient care shall be addressed within an appropriate timeframe. Account Follow-up Account follow-up that requires information general in nature yet specific to the account, e.g. test pricing, courier service problems, specimen results discrepancy issues, equipment repair, supply ordering, etc. shall be addressed within four (4) hours of the initial inquiry. TEST CONTRACTOR POINT OF CONTACT: Contractor shall assign a specific account representative to VANTHCS. LICENSING AND ACCREDITATION: Contractor shall be licensed, accredited, and inspected by the Laboratory Accreditation Program (LAP) of an accrediting agency [i.e., College of American Pathologists (CAP)] with deemed status from the Center for Medicare and Medicaid Services (CMS), the Nuclear Regulatory Commission, Center for Disease Control, Medicare and/or other state regulatory agencies as mandated by federal and state statutes. In addition, the reference laboratory shall be certified as meeting the requirements of the Clinical Laboratory Improvement Act of 1988 and comply with the National Standards to Protect the Privacy of Personal Health Information (HIPPA). Personnel assigned by the contractor to perform these services covered under this contract shall be licensed in a State, Territory or Commonwealth of the United States or the District of Columbia. Laboratory Director shall be a licensed pathologist, physician, or biologist. Copies of all relevant permits, licenses and certification of the Contractor and any subcontractor of the primary Contractor if tests and/or services are sent to another facility for testing, shall be supplied in response to this solicitation. In addition, as these documents for the Contractor and subcontracted facilities are reissued for accreditation, reworded, or renewed the awarded Contractor shall supply a copy to VANTHCS annually. QUALITY CONTROLS: By the end of each month following the end of the quarter, the contractor shall provide to the Laboratory Manager and COR a cumulative (year-to-date) summary report by test. The report shall include at minimum the following Number of tests performed Number of test rejections with reason for rejection TAT for each test order during that quarter The top 20 tests performed for VANTHCS by month each quarter. Monthly summary sheet by dollar volume for each test in descending order of dollar volume with volume of tests ordered, unit charge for each test, total charges for each month and year to date. Contractor shall immediately advise the Laboratory Manager and COR of any changes in methodology, procedure, reference ranges and any new test introduced, including CPT code. Contractor shall provide the following information annually during the life of the contract: Indication of average monthly volume of specified tests listed in this contract. Provide address of processing sites under contract. Proficiency testing data shall include a list of tests outside of the -+2SD range for the past two (2) years. Contractor agrees to maintain the satisfactory service, reporting systems and quality control as specified herein. Acceptable performance will be determined annually by the criteria listed below. Scoring Average score value per category: Exceptional 4 Very Good 3 Satisfactory 2 Marginal 1 Unsatisfactory <1 Standard Task Indicator Acceptable Quality Level Method of Surveillance Incentive Minimal unsuccessful performance due to instrument or reagent issues. Quality Assurance Successful peer group comparison 90% satisfactory performance to peer group. Exceptional: 100% Very Good: 95-99% Satisfactory: 90-94% Marginal: 85-89% Unsatisfactory: <85% Proficiency testing survey reports Exercise of Option Period Result delays are minimal. Turnaround time 90% within established turnaround time annually. Exceptional: 100% Very Good: 95-99% Satisfactory: 90-94% Marginal: 85-89% Unsatisfactory: <85% Problem records Sendout records TAT reports Telephone Support is responsive. Telephone inquiries 100% Issues resolved Exceptional: 100% Very Good: 98-99% Satisfactory: 95-97% Marginal: 85-89% Unsatisfactory: <85% Problem records Exercise of Option Period Invoices are submitted monthly. Cost Control Invoice Accountability 100% Invoices received through OLCS via Austin, Texas Invoice records Exercise of Option Period Invoices are itemized by service or product received. Invoice Verification 80% Invoices contain all necessary information for proper processing. Excellent: 95-100% Very Good: 90-94% Satisfactory: 85-89% Marginal: 80-84% Unsatisfactory: <80% Invoice records Exercise of Option Period Contractor will provide proactive notification of changes. Notification of significant changes in reagent and equipment modifications 100% Proactive notifications. Quality Bulletins Customer Letters Customer Contact Exercise of Option Period Timely recall notification of reagent and supplies. Recall Notification 100% Recall notifications within 1 month of issuance. Quality Bulletins Customer Letters Customer Contact Exercise of Option Period Works with customer to resolve complaints. Customer Satisfaction Substantiated complaints No unresolved substantiated customer complaints per year Order records Invoice records Customer communications Problem records Troubleshooting records Exercise of Option Period Timely follow-up on complaints. Complaint Handling 90% Complaint follow-up within 24 hours of initial complaint or within agreed upon timeframe. Exceptional: 100% Very Good: 95-99% Satisfactory: 90-94% Marginal: 85-89% Unsatisfactory: <85% Order records Invoice records Customer communications Problem records Troubleshooting records Exercise of Option Period The Government may evaluate the quality of the professional and administrative services provided but retains no control over the medical professional aspects of services rendered (e.g. professional judgments, diagnosis for specific medical treatment). INVOICING: Invoices must contain at a minimum the following information. Contractor shall provide this information on one original invoice: Invoice number Contract number Proper CPT and LOINC Code Unit Cost Total Cost Date of Service CANCELLATION: The government may terminate this contract at any time upon at least 30 days written notice by the contracting officer to the contractor. The contractor, with written consent of the contracting officer, may terminate this contract upon at least 30 days written notice to the contracting officer. GOVERNING LAW: This contract shall be governed, construed and enforced in accordance with Federal Law. MARKETING: Contractor shall not advertise or use any marketing material, logos, trade names, service marks, or other material belonging to the VANTHCS without the VANTHCS consent. ORDER OF PRECEDENCE: The terms, conditions, and attachments referenced herein, including any formal written modifications thereto, constitute the complete agreement between the parties and take precedence over any other language, oral or written. RECORDS MANAGEMENT: All records (administrative and program specific) created during the period of the contract belong to VA North Texas Health Care System (VANTHCS) and must be returned to VANTHCS at the end of the contract. See below. E-RESULTS Post-award Contractor may provide a proposed plan to implement VistA interface including timeline and deliverables as listed below to meet the needs of VANTHCS. The Contractor shall furnish a schedule to show a customizable implementation plan of the required services (telecommunications, interface connectivity and validation, client service support, ordering, supplies, specimen processing services, reporting, quality assurance, billing, etc.). If the Contractor s test menu differs from that of the current VANTHCS VistA test menu, the contractor shall provide the information required for the initial build of tests into the VistA test database for tests performed at the reference lab. A VistA test file includes specimen collection and processing information, reference lab test code, CPT and LOINC codes, price, result template and other pertinent information specific to the test (ex. standard comments, ASR comments, etc.). Test files contain one test per file. VistA does not allow batch entries for test builds. Interfacing requirements to be provided by the vendor: Brief Summary of VistA Functionality - VistA is a public domain system to the VA whose functionality includes: Management of patient information through a database, Acceptance of test ordering information, Transmittal of patient laboratory test results. Storage and retrieval of patient laboratory test results. (Note: VistA is very limited in its functionality.)          Computer interface questions where information is required to update, maintain, and support the services of the host-to-host linkage between the VA and the Contractor shall be addressed within 1 day of the initial inquiry. The Contractor shall meet all Enterprise Cyber Security Infrastructure Project (ECSIP) requirements to establish an interconnection with the VA for transfer of laboratory test results directly into a VA computer system via the appropriate Laboratory Electronic Data Interchange protocol. There are three basic types of authorized connections. The ECSIP team will have the ultimate decision on which connection type is appropriate. The connection types are described below. More information can be obtained from the VA Information Security Officer at any facility or directly from the ECSIP team. See attachment: CHECKLIST FOR INFORMATION SECURITY IN THE INITIATION PHASE OF ACQUISITION from the VA HANDBOOK 6500.6 APPENDIX A which must be completed with the contractor s quote. External users shall be classified in one of three distinct categories: 1) client-to-site VPN, 2) site to-site VPN, or 3) Business Partner Gateways. Table 1 can be utilized in assisting users to determine which category a connection may best be identified. Client-to-Site VPNs satisfy remote connectivity for small groups of external users (IE <50) that require access to VA internal resources. Non- VA users are restricted to specific internal IP addresses identified by the Contracting Officer Representative (COR). External business partners should have access to the minimum resources required to meet contractual obligations. Site-to-Site VPNs are connections to external business partners, which terminate in an ECSIP gateway. These connections will then be routed across the VA WAN to the requisite VA facility resources as defined by firewall policy. Business Partner Gateways (BPGs) are connections to external business partners, which terminate at the requisite VA facility and do not traverse the VA WAN. These connections will be limited in number based on CIO requirement definitions. Table 1: VistA Connectivity Requirement VistA Connectivity Requirement Client-to-Site VPN Site-to-Site VPN Business Partner Gateway Small Number of Users- If the number of users accounts the ISO must administer is manageable. A client-to-site connection will usually suffice. X Numerous Users - Having a significant number of client-to-site user accounts to manage may justify a site-to-site VPN. X Persistent Connection Required - The need to maintain continuous connectivity can usually be supported with a site- to-site VPN. X X High Bandwidth- A large volume of traffic may be a valid need to establish or maintain a Business Partner Gateway (BPG) connection (0 prevent certain traffic from traversing the VA WAN. As an example, a medical teaching University supported by a VA Hospital that sends large radiological images on a regular basis. This could have a detrimental impact on the VA WAN if that traffic traverses the WAN through a VPN connection. X Service Level Agreements- SLAs that guarantee specific levels of support to contracted agencies that could not be provided using a One-VA VPN may also justify a BPG connection. X High Availability- Availability of critical business processes, such as financial and medical applications, may justify maintaining a BPG to minimize the risk of financial and personal health data loss. X Sensitive Information- Every effort should be made to protect sensitive information. Although protection mechanisms are in place, there are still risks associated with transmitting sensitive data across any network, to include the VA WAN. Although the One-VA VPN satisfies this requirement, the sensitivity of the data may be such that additional precautions are warranted. X X Server-to-Server Connections - In most cases, a site-to-site VPN can be used to support external server connections. X X Any equipment provided by the Contractor to VA which contains a storage device such that when the device is powered down, VA sensitive data remains on it, shall be sanitized prior to removal from the VA premises, shall become the property of the Federal Government, and remain on Federal property or shall be destroyed in accordance with Department of Veterans Affairs regulations at the time of removal (device decommissioning). Data required by the Health Insurance Portability and Accountability Account of 1996 (HIPAA) to remain on equipment located on Contractor's property shall be safeguarded in accordance with HIPAA and this information shall be destroyed in accordance with VA requirements when no longer required by HIPAA to be held by the contractor. Equipment shall be able to store and retransmit records (24 hours of maximal instrument throughput) in case of interface downtime. The reference laboratory shall meet VA information security and HIPPA requirements and shall be able to interface with the current or any new interface partner of the Laboratory Information System. The Contractor shall have all users with VA access complete the VHA Privacy and HIPAA Training and the VA Privacy and Information Security Awareness and Rules prior to starting services. The Contractor shall notify the facility Privacy Officer immediately with the list of patient names if any breach of computer security or privacy incident is accessed. The Contractor shall provide the following interfacing requirements: LIS physical connection and translation (drivers) Any required (additional) interface connection license(s) Web-based electronic ordering and resulting Interface shall transmit test results to the host computer via automatic upload. Automatic printing of laboratory results to a dedicated reference lab printer, supplied by the reference lab. PRIVACY Contractors and any subcontractors must adhere to the provisions of Public Law 104-191, Health Insurance Portability and Accountability Act (HIPAA) of 1996. This includes both the Privacy and Security Rules published by the Department of Health and Human Services (HHS). As required by HIPAA, HHS has promulgated rules governing the use and disclosure of protected health information by covered entities, Veterans Health Administration (VHA). In accordance with HIPAA, the contractor may be required to enter into a Business Associate Agreement (BAA) with VHA. Business associates must follow VHA privacy policies and practices when applicable. All contractors and business associates must receive privacy training annually. For contractors and business associates who do not have access to VHA computer systems, this requirement is met by completing VHA National Privacy Policy training, other VHA approved privacy training or contractor furnished training that meets the requirements of the HHS Standards for Privacy of Individually Identifiable Health Information as determined by VHA. For c...