DH10--Bayer MedRad Enterprise Platform
Page 11 of 11 This is a combined synopsis/solicitation for commercial products prepared in accordance with the format in Federal Acquisition Regulation (FAR) subpart 12.6, Streamlined Procedures for E... Page 11 of 11 This is a combined synopsis/solicitation for commercial products prepared in accordance with the format in Federal Acquisition Regulation (FAR) subpart 12.6, Streamlined Procedures for Evaluation and Solicitation for Commercial Products, as supplemented with additional information included in this notice. This announcement constitutes the only solicitation; quotes are being requested, and a written solicitation document will not be issued. This is a Brand Name or Equal To Request for Quote (RFQ), and the solicitation number is 36C26024Q0916. The Government anticipates awarding a firm-fixed price service order from this solicitation. This is a solicitation for Bayer© Contrast Dose Management Radimetrics Enterprise Platform. The solicitation document and incorporated provisions and clauses are those in effect through Federal Acquisition Circular (FAC) 2024-06 Effective August 29, 2024. This solicitation is 100% set-aside for SDVOSB. The associated North American Industrial Classification System (NAICS) code for this procurement is 541512, with a small business size standard of $34 Million and the PSC is DH10. All interested companies shall provide quotations that are Brand Name or Equal To for the following: Equipment Needed: BRAND NAME or EQUAL (Bayer ® Healthcare, LLC. All interested parties shall quote the following: Base-included in original award: period to begin September 23, 2024 Base year to include the following list of required items Option Year 1 Option Year 2 Option Year 3 Option Year 4 Item Description Qty ME-84219851 CDM App, Tier 2 7 ME-84220388 CDM-Outbound PACS Interface, Tier 2 6 ME-84219576 CDM-Outbound HL7 Interface, Tier 2 7 ME-84220299 CDM-Outbound SR Interface 7 ME-87008762 INFORMATICS STARTER PACKAGE SW FLEX 6 ME-84219843 CDM App, Tier 1 3 ME-84220396 CDM-Outbound PACS Interface Tier 1 4 ME-84220264 CDM-Outbound HL7 Interface Tier 1 4 ME-84220302 CDM-Outbound SR Interface Tier 1 4 ME-87008630 CDM-Informatics Starter Package SW MRX 4 ME-84856496 INSTALLATION - INFORMATICS 10 ME-59941260 SERVICES, CERTEGRA INTEGRATION 10 ME-84219584 Implementation Services 1 ME-81923167 EXP-Travel and Lodging 1 Salient Characteristics: Contrast Dose Management Bayer proprietary software that allows administrative access to evaluate contrast injection history PACS Outbound Interface Bayer proprietary interface that enables a Dicom secondary capture to be transferred to PACS systems (i.e. Carestream) HL7 Outbound Interface Bayer proprietary interface that enables contrast injection details to be transferred to RIS and HER systems (i.e. VISTA/CERNER) POC Informatics Starter Packages Bayer proprietary software that automates documentation details of patient demographics and exam details Speech Reporting Interface Bayer proprietary interface that auto-populates contrast injection details into speech reporting systems Note: Above solutions require Medrad Stellant and Medrad Stellant Flex CT injectors with Certegra Workstation or Medrad MRXperion MR injection system. Competitive injectors are not compatible with these configurations. CDM will be installed on the Radimetrics Enterprise Platform. VA Portland has already established a server which is currently used for Radiation Dose Management. Contrast Dose Management will also live on this same server. See full Statement of Work for additional system requirements and details Statement of Work VA Portland HCS Radiology Service Addition of Contrast Dose Management Software Purpose: The VA Portland HCS has many Bayer contrast injectors to support care in MRI (qty 4), CT (qty 4), and Angio (qty 2) imaging suites. This new request is for the installation of dose management software that was not included in the original sales order. The injectors have medical software that interfaces with the contrast management software. The CMS system ties injection information to patient demographics obtained through HL7 messaging that is sent from the PACS system. All information remains within the VAMC. WORK STATEMENT Scope: The Contractor will provide Contrast Dose Management System Software designed for continuity in patient dose management and data. Contractor shall: Deliver, install, and set up all data feeds from injector to the patient record. Provide technical support and guidance. Provide basic and advanced operator training. Location: The injectors are located at VA Portland HCS, 3710 SW US Veterans Hospital Rd, Portland, OR 97239, and VA Portland HCS-Vancouver Campus 1601 E Fourth Plain Blvd, Vancouver, WA 98661. Minimal onsite work is required. Performance Requirements: The following are required: Radimetrics Contrast Dose Management System - Bayer Part Number Description Qty 84219851 CDM App, Tier 2 7 84220388 CDM-Outbound PACS Interface, Tier 2 6 84219576 CDM-Outbound HL7 Interface, Tier 2 7 84220299 CDM Outbound SR Interface 7 87008762 Informatics Starter Package SW Flex 6 84219843 CDM App Tier 1 3 84220396 CDM Outbound PACS interface Tier 1 4 84220264 CDM Outbound HL7 Interface Tier 1 4 84220302 CDM Outbound SR Interface Tier 1 4 87008630 CDM Informatics Starter Package SW MRX 4 84856496 Installation-Informatics 10 59941260 Services, Certegra integration 10 84219584 Implementation services 1 81923167 EXP Travel and Lodging 1 System Requirement: Point of Care software PACS Outbound Interface RIS Outbound Interface Speech Reporting Outbound Interface Imaging System (CT and MRI) Interfacing Display Requirements: Able to be used on current workstation for injector and existing workstations in the scanning room. System Functions: Fine-Tuned Performance, a contrast dose management solution can speed things up by eliminating manual process through interfacing. Automated Documentation Accuracy, easy access to accurate study reporting and accelerate report turnaround times. Facilitates compliance aids in meeting requirements surrounding contrast use and documentation required by The Joint Commission (TJC). Quality management, contrast dose management automates technologist workflows for accurate CT contrast-injection documentation at the point of care and throughout the post-procedure workflow. Radiation dose management streamlines compliance through automated dose reporting. Safety The Contractor shall immediately notify VAPORHCS of any changes in supplies, procedure modification, recall notification, or any changes that will affect the performance of the equipment or procedure according to FDA regulations. Prioritized messages and alerts for end user Connectivity Requirements: All network connections shall match the Enterprise Risk Assessment completed by Bayer and the VA. Any changes to the topology shall be communicated to the VA and shall not proceed to be implemented until approval is granted. A copy of the Enterprise Risk Assessment can be provided upon request. Maintenance: N/A Technical Support: Support Personnel will be available during business hours each business day, and live representatives via the Contractor s message center will be available by telephone at all other times. Technical support shall be available via telephone during business days (and by message center after hours) to provide troubleshooting assistance or to answer testing inquiries. All remote support shall occur within 2 hours of initial notification of the issue On-site technical support shall be available for escalations within 48 hours. On-site Repairs: For issues that the Contractor determines to require on-site support, the Contractor shall dispatch one or more Support Personnel within 48 business hours after documentation. The Contractor shall submit a detailed work report to include all required materials. The Contractor shall provide all parts and materials at no additional cost to the government. The Contractor shall remove all parts, equipment or materials replaced, or upgraded by the Contractor due to and not limited to repairs, replacements, recall, and upgrades without any cost to the government. The contractor shall check in and out with Biomedical Engineer or designee upon arrival and departure if onsite work is required. Biomedical Engineering staff is located in B1D106-100-P. Training: The contractor shall provide the following: Initial training for end users One additional on-site or off-site Basic Operator class per year. Handouts and training materials in sufficient quantity for each participant. These are off-the-shelf courses. The contractor shall provide lesson plan, course materials and media (DVD s, CD s, videos, etc. if required), and editable procedures at no additional cost. Additional on-site training as requested by VAPORHCS at no additional charge. Period of Performance: Contractor shall provide the complete order to the facility within 90 days of purchase. Any delays in delivery shall be communicated to the Contracting Officer. FOB: Destination Option Years: shall be as follows for software support Base-included in original award: period to begin September 23, 2024 Option Year 1 Option Year 2 Option Year 3 Option Year 4 Deliverables and Supplies: This contract is for licensing and software support of interfaces to the RIS and PACS systems. The Contractor shall deliver all and not limited to operational, maintenance, troubleshooting, small repairs, specifications, and test manuals. The Contractor shall install the equipment and perform verification according to manufacturer specification and regulatory requirements. If requested supplies are on back-order, Contractor is to provide information as to the estimated time of availability. The Contractor shall deliver all invoices for review according to the established contract at the end of each billing cycle. All items not contracted shall be specifically detailed on the invoice including description, quantity acquired, and government cost. All modifications, upgrades, patches to the interfaces and software shall be communicated to VAPORHCS Biomedical Engineering staff prior to implementation. Any changes will require written concurrence from a member of the VA. Any changes in modifications shall be immediately disclosed by the Contractor electronically, and detailed guidance for implementation within twenty-four hours of its application. Additional charges incurred by the government to provide the continuity of contracted tests to patients and not limited to outsourcing, transportation, and or any other additional cost shall be covered by the Contractor at no additional charge to the government. Contractor Security Contract Requirements: This Contractor requires no access to VAPOR HCS or any VA information system. There will be no access to the LIS. There will be supervised access when the Contractor is present for technical support, service calls, and scheduled preventative maintenance. NO VA DATA OF ANY TYPE SHALL BE TRANSFERRED FROM THE VA. NARA Records Management Language for Contracts (May 2017) 1. Contractor shall comply with all applicable records management laws and regulations, as well as National Archives and Records Administration (NARA) records policies, including but not limited to the Federal Records Act (44 U.S.C. chs. 21, 29, 31, 33), NARA regulations at 36 CFR Chapter XII Subchapter B, and those policies associated with the safeguarding of records covered by the Privacy Act of 1974 (5 U.S.C. 552a). These policies include the preservation of all records, regardless of form or characteristics, mode of transmission, or state of completion. 2. In accordance with 36 CFR 1222.32, all data created for Government use and delivered to, or falling under the legal control of, the Government are Federal records subject to the provisions of 44 U.S.C. chapters 21, 29, 31, and 33, the Freedom of Information Act (FOIA) (5 U.S.C. 552), as amended, and the Privacy Act of 1974 (5 U.S.C. 552a), as amended and must be managed and scheduled for disposition only as permitted by statute or regulation. 3. In accordance with 36 CFR 1222.32, Contractor shall maintain all records created for Government use or created in the course of performing the contract and/or delivered to, or under the legal control of the Government and must be managed in accordance with Federal law. Electronic records and associated metadata must be accompanied by sufficient technical documentation to permit understanding and use of the records and data. 4. [FACILITY] and its contractors are responsible for preventing the alienation or unauthorized destruction of records, including all forms of mutilation. Records may not be removed from the legal custody of [FACILITY] or destroyed except for in accordance with the provisions of the agency records schedules and with the written concurrence of the Head of the Contracting Activity. Willful and unlawful destruction, damage or alienation of Federal records is subject to the fines and penalties imposed by 18 U.S.C. 2701. In the event of any unlawful or accidental removal, defacing, alteration, or destruction of records, Contractor must report to [FACILITY]. The agency must report promptly to NARA in accordance with 36 CFR 1230. 5. The Contractor shall immediately notify the appropriate Contracting Officer upon discovery of any inadvertent or unauthorized disclosures of information, data, documentary materials, records, or equipment. Disclosure of non-public information is limited to authorized personnel with a need-to-know as described in the [contract vehicle]. The Contractor shall ensure that the appropriate personnel, administrative, technical, and physical safeguards are established to ensure the security and confidentiality of this information, data, documentary material, records and/or equipment is properly protected. The Contractor shall not remove material from Government facilities or systems, or facilities or systems operated or maintained on the Government s behalf, without the express written permission of the Head of the Contracting Activity. When information, data, documentary material, records and/or equipment is no longer required, it shall be returned to [FACILITY] control or the Contractor must hold it until otherwise directed. Items returned to the Government shall be hand carried, mailed, emailed, or securely electronically transmitted to the Contracting Officer or address prescribed in the [contract vehicle]. Destruction of records is EXPRESSLY PROHIBITED unless in accordance with Paragraph (4). 6. The Contractor is required to obtain the Contracting Officer's approval prior to engaging in any contractual relationship (sub-contractor) in support of this contract requiring the disclosure of information, documentary material and/or records generated under, or relating to, contracts. The Contractor (and any sub-contractor) is required to abide by Government and [FACILITY] guidance for protecting sensitive, proprietary information, classified, and controlled unclassified information. 7. The Contractor shall only use Government IT equipment for purposes specifically tied to or authorized by the contract and in accordance with [FACILITY] policy. 8. The Contractor shall not create or maintain any records containing any non-public [FACILITY] information that are not specifically tied to or authorized by the contract. 9. The Contractor shall not retain, use, sell, or disseminate copies of any deliverable that contains information covered by the Privacy Act of 1974 or that which is generally protected from public disclosure by an exemption to the Freedom of Information Act. 10. The [FACILITY] owns the rights to all data and records produced as part of this contract. All deliverables under the contract are the property of the U.S. Government for which [FACILITY] shall have unlimited rights to use, dispose of, or disclose such data contained therein as it determines to be in the public interest. Any Contractor rights in the data or deliverables must be identified as required by FAR 52.227-11 through FAR 52.227-20. 11. Training.  All Contractor employees assigned to this contract who create, work with, or otherwise handle records are required to take VHA-provided records management training, Talent Management System (TMS) Item #3873736, Records Management for Records Officers, and Liaisons. The Contractor is responsible for confirming training has been completed according to agency policies, including initial training and any annual or refresher training. VA Sensitive Information 1. GENERAL Contractors, contractor personnel, subcontractors, and subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security. 2. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS a. A contractor/subcontractor shall request logical (technical) or physical access to VA information and VA information systems for their employees, subcontractors, and affiliates only to the extent necessary to perform the services specified in the contract, agreement, or task order. b. All contractors, subcontractors, and third-party servicers and associates working with VA information is subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations, Security, and Preparedness is responsible for these policies and procedures. c. Contract personnel who require access to national security programs must have a valid security clearance. National Industrial Security Program (NISP) was established by Executive Order 12829 to ensure that cleared U.S. defense industry contract personnel safeguard the classified information in their possession while performing work on contracts, programs, bids, or research and development efforts. The Department of Veterans Affairs does not have a Memorandum of Agreement with Defense Security Service (DSS). Verification of a Security Clearance must be processed through the Special Security Officer located in the Planning and National Security Service within the Office of Operations, Security, and Preparedness. d. Custom software development and outsourced operations must be located in the U.S. to the maximum extent practical. If such services are proposed to be performed abroad and are not disallowed by other VA policy or mandates, the contractor / subcontractor must state where all non-U.S. services are provided and detail a security plan, deemed to be acceptable by VA, specifically to address mitigation of the resulting problems of communication, control, data protection, and so forth. Location within the U.S. may be an evaluation factor. e. The contractor or subcontractor must notify the Contracting Officer immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the contractor or subcontractor s employ. The Contracting Officer must also be notified immediately by the contractor or subcontractor prior to an unfriendly termination. 3. VA INFORMATION CUSTODIAL LANGUAGE a. Information made available to the contractor or subcontractor by VA for the performance or administration of this contract or information developed by the contractor/subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of the VA. This clause expressly limits the contractor/subcontractor's rights to use data as described in Rights in Data - General, FAR 52.227-14(d) (1). b. VA information should not be co-mingled, if possible, with any other data on the contractors/subcontractor s information systems or media storage systems in order to ensure VA requirements related to data protection and media sanitization can be met. If co-mingling must be allowed to meet the requirements of the business need, the contractor must ensure that VA s information is returned to the VA or destroyed in accordance with VA s sanitization requirements. VA reserves the right to conduct on-site inspections of contractor and subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures are in compliance with VA directive requirements. c. Prior to termination or completion of this contract, contractor/subcontractor must not destroy information received from VA, or gathered/created by the contractor in the course of performing this contract without prior written approval by the VA. Any data destruction done on behalf of VA by a contractor/subcontractor must be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management and its Handbook 6300.1 Records Management Procedures, applicable VA Records Control Schedules, and VA Handbook 6500.1, Electronic Media Sanitization. Self-certification by the contractor that the data destruction requirements above have been met must be sent to the VA Contracting Officer within 30 days of termination of the contract. d. The contractor/subcontractor must receive, gather, store, back up, maintain, use, disclose and dispose of VA information only in compliance with the terms of the contract and applicable Federal and VA information confidentiality and security laws, regulations, and policies. If Federal or VA information confidentiality and security laws, regulations and policies become applicable to the VA information or information systems after execution of the contract, or if NIST issues or updates applicable FIPS or Special Publications (SP) after execution of this contract, the parties agree to negotiate in good faith to implement the information confidentiality and security laws, regulations, and policies in this contract. e. The contractor/subcontractor shall not make copies of VA information except as authorized and necessary to perform the terms of the agreement or to preserve electronic information stored on contractor/subcontractor electronic storage media for restoration in case any electronic equipment or data used by the contractor / subcontractor needs to be restored to an operating state. If copies are made for restoration purposes, after the restoration is complete, the copies must be appropriately destroyed. f. If VA determines that the contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be sufficient grounds for VA to withhold payment to the contractor or third party or terminate the contract for default or terminate for cause under Federal Acquisition Regulation (FAR) part 12. g. If a VHA contract is terminated for cause, the associated BAA must also be terminated and appropriate actions taken in accordance with VHA Handbook 1600.01, Business Associate Agreements. Absent an agreement to use or disclose protected health information, there is no business associate relationship. h. The contractor/subcontractor must store, transport, or transmit VA sensitive information in an encrypted form, using VA-approved encryption tools that are, at a minimum, FIPS 140-2 validated. i. The contractor/subcontractor s firewall and Web services security controls, if applicable, shall meet or exceed VA s minimum requirements. VA Configuration Guidelines are available upon request. j. Except for uses and disclosures of VA information authorized by this contract for performance of the contract, the contractor/subcontractor may use and disclose VA information only in two other situations: (i) in response to a qualifying order of a court of competent jurisdiction, or (ii) with VA s prior written approval. The contractor / subcontractor must refer all requests for, demands for production of, or inquiries about, VA information and information systems to the VA contracting officer for response. k. Notwithstanding the provision above, the contractor/subcontractor shall not release VA records protected by Title 38 U.S.C. 5705, confidentiality of medical quality assurance records and/or Title 38 U.S.C. 7332, confidentiality of certain health records pertaining to drug addiction, sickle cell anemia, alcoholism or alcohol abuse, or infection with human immunodeficiency virus. If the contractor/subcontractor is in receipt of a court order or other requests for the above-mentioned information, that contractor/subcontractor shall immediately refer such court orders or other requests to the VA contracting officer for response. l. For service that involves the storage, generating, transmitting, or exchanging of VA sensitive information but does not require C&A or an MOU-ISA for system interconnection, the contractor/subcontractor must complete a Contractor Security Control Assessment (CSCA) on a yearly basis and provide it to the COR. 4. INFORMATION SYSTEM DESIGN AND DEVELOPMENT a. Information systems that are designed or developed for or on behalf of VA at non-VA facilities shall comply with all VA directives developed in accordance with FISMA, HIPAA, NIST, and related VA security and privacy control requirements for Federal information systems. This includes standards for the protection of electronic PHI, outlined in 45 C.F.R. Part 164, Subpart C, information and system security categorization level designations in accordance with FIPS 199 and FIPS 200 with implementation of all baseline security controls commensurate with the FIPS 199 system security categorization (reference Appendix D of VA Impact Assessment (PIA) must be completed, provided to the COR, and approved by the VA Privacy Service in accordance with Directive 6507, VA Privacy Impact Assessment. b. The contractor/subcontractor shall certify to the COR that applications are fully functional and operate correctly as intended on systems using the VA Federal Desktop Core Configuration (FDCC), and the common security configuration guidelines provided by NIST or the VA. This includes Internet Explorer 7 configured to operate on Windows XP and Vista (in Protected Mode on Vista) and future versions, as required. c. The standard installation, operation, maintenance, updating, and patching of software shall not alter the configuration settings from the VA approved and FDCC configuration. Information technology staff must also use the Windows Installer Service for installation to the default program files directory and silently install and uninstall. d. Applications designed for normal end users shall run in the standard user context without elevated system administration privileges. e. The security controls must be designed, developed, approved by VA, and implemented in accordance with the provisions of VA security system development life cycle as outlined in NIST Special Publication 800-37, Guide for Applying the Risk Management Framework to Federal Information Systems, VA Handbook 6500, Information Security Program and VA Handbook 6500.5, Incorporating Security and Privacy in System Development Lifecycle. f. The contractor/subcontractor is required to design, develop, or operate a System of Records Notice (SOR) on individuals to accomplish an agency function subject to the Privacy Act of 1974, (as amended), Public Law 93-579, December 31, 1974 (5 U.S.C. 552a) and applicable agency regulations. Violation of the Privacy Act may involve the imposition of criminal and civil penalties. g. The contractor/subcontractor agrees to: (1) Comply with the Privacy Act of 1974 (the Act) and the agency rules and regulations issued under the Act in the design, development, or operation of any system of records on individuals to accomplish an agency function when the contract specifically identifies: (a) The Systems of Records (SOR); and (b) The design, development, or operation work that the contractor/subcontractor is to perform; (2) Include the Privacy Act notification contained in this contract in every solicitation and resulting subcontract and in every subcontract awarded without a solicitation, when the work statement in the proposed subcontract requires the redesign, development, or operation of a SOR on individuals that is subject to the Privacy Act; and (3) Include this Privacy Act clause, including this subparagraph (3), in all subcontracts awarded under this contract which requires the design, development, or operation of such a SOR. h. In the event of violations of the Act, a civil action may be brought against the agency involved when the violation concerns the design, development, or operation of a SOR on individuals to accomplish an agency function, and criminal penalties may be imposed upon the officers or employees of the agency when the violation concerns the operation of a SOR on individuals to accomplish an agency function. For purposes of the Act, when the contract is for the operation of a SOR on individuals to accomplish an agency function, the contractor/subcontractor is considered to be an employee of the agency. (1) Operation of a System of Records means performance of any of the activities associated with maintaining the SOR, including the collection, use, maintenance, and dissemination of records. (2) Record means any item, collection, or grouping of information about an individual that is maintained by an agency, including, but not limited to, education, financial transactions, medical history, and criminal or employment history and contains the person s name, or identifying number, symbol, or any other identifying particular assigned to the individual, such as a fingerprint or voiceprint, or a photograph. (3) System of Records means a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some identifying number, symbol, or other identifying particular assigned to the individual. i. The vendor shall ensure the security of all procured or developed systems and technologies, including their subcomponents (hereinafter referred to as Systems ), throughout the life of this contract and any extension, warranty, or maintenance periods. This includes, but is not limited to workarounds, patches, hotfixes, upgrades, and any physical components (hereafter referred to as Security Fixes) which may be necessary to fix all security vulnerabilities published or known to the vendor anywhere in the Systems, including Operating Systems and firmware. The vendor shall ensure that Security Fixes shall not negatively impact the Systems. j. The vendor shall notify VA within 24 hours of the discovery or disclosure of successful exploits of the vulnerability which can compromise the security of the Systems including the confidentiality or integrity of its data and operations, or the availability of the system). Such issues shall be remediated as quickly as is practical, but in no event longer than _30_ days. k. When the Security Fixes involve installing third party patches (such as Microsoft OS patches or Adobe Acrobat), the vendor will provide written notice to the VA that the patch has been validated as not affecting the Systems within 10 working days. When the vendor is responsible for operations or maintenance of the Systems, they shall apply the Security Fixes within _10_ days. l. All other vulnerabilities shall be remediated as specified in this paragraph in a timely manner based on risk, but within _60_ days of discovery or disclosure. Exceptions to this paragraph (e.g., for the convenience of VA) shall only be granted with approval of the contracting officer and the VA Assistant Secretary for Office of Information and Technology. 5. INFORMATION SYSTEM HOSTING, OPERATION, MAINTENANCE, OR USE a. For information systems that are hosted, operated, maintained, or used on behalf of VA at non-VA facilities, contractors/subcontractors are fully responsible and accountab...
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