PWS CUI with comment 3_9_26.docx

Controlled Unclassified Information (CUI)

VA-26-00041445

PERFORMANCE WORK STATEMENT (PWS)

DEPARTMENT OF VETERANS AFFAIRS

Office of Information & Technology Enterprise Records Service (ERS) Controlled Unclassified Information (CUI)

Controlled Unclassified Information Date: 02/25/2026 VA-26-00041445PWS Version Number: 1.0

Contents

BACKGROUND

The Department of Veterans Affairs (VA), Office of Information & Technology (OIT), Compliance, Risk and Remediation (CRR) Enterprise Record Service (ERS) strives to provide high quality, effective, and efficient Information Technology (IT) services to those responsible for providing care to the Veterans at the point-of-care as well as throughout all the points of the Veterans’ health care in an effective, timely and compassionate manner. The VA depends on Information Management/Information Technology (IM/IT) systems to meet mission goals.

The Executive Order (E.O.) 13556, Controlled Unclassified Information establishes an open and uniform program for managing unclassified information requiring safeguarding or dissemination controls pursuant to and consistent with law, regulations, and Government-wide policies. In accordance with 32 CFR 2002, the VA must establish Controlled Unclassified Information (CUI) Self-Inspection and Incident Management programs.

In support of these programs, the VA requires the development of program implementation plans and support in executing these plans. The VA is actively involved in the project implementation phase of this effort. Several key deliverables have been developed since 2016, which require updates based on Office of Management and Budget (OMB) mandates and National Archives and Records Administration (NARA) policy. As VA moves beyond the implementation phase, it requires support to implement program sustainment activities, and the ability to measure program success and optimize program activities.

APPLICABLE DOCUMENTS

In the performance of the tasks associated with this Performance Work Statement, the Contractor shall comply with the following:

1. “Federal Information Security Modernization Act of 2014”

2. Federal Information Processing Standards (FIPS) Publication 140-3, “Security Requirements for Cryptographic Modules”, March 22, 2019

3. FIPS Pub 199. “Standards for Security Categorization of Federal Information and Information Systems,” February 2004

4. FIPS Pub 200, “Minimum Security Requirements for Federal Information and Information Systems,” March 2006

5. FIPS Pub 201-3, “Personal Identity Verification of Federal Employees and Contractors,” January 2022

6. 10 U.S.C. § 2224, "Defense Information Assurance Program", as amended

7. 5 U.S.C. § 552a, as amended, “The Privacy Act of 1974”

8. Public Law 109-461 (P.L. 109-461), Veterans Benefits, Health Care, and Information Technology Act of 2006, as amended, Title IX, Information Security Matters

9. 42 U.S.C. § 2000d “Title VI of the Civil Rights Act of 1964”, as amended

10. VA Directive 0710, “Personnel Security and Suitability Program,” June 4, 2010, https://www.va.gov/vapubs/index.cfm

11. VA Handbook 0710, “Personnel Security and Suitability Program,” May 2, 2016, https://www.va.gov/vapubs/index.cfm

12. VA Directive 6102, “Internet/Intranet Services,” August 5, 2019

13. 36 C.F.R. Part 1194 “Information and Communication Technology Standards and Guidelines,” as amended

14. Office of Management and Budget (OMB) Circular A-130, “Managing Federal Information as a Strategic Resource,” July 28, 2016

15. 32 C.F.R. Part 199, “Civilian Health and Medical Program of the Uniformed Services (CHAMPUS)”, as amended

16. NIST SP 800-66 Rev. 2, “Implementing the Health Insurance Portability and Accountability Act (HIPAA) Security Rule: A Cybersecurity Resource Guide,” February 2024

17. 45 C.F.R Parts 160 and 164, Subparts A and E, the Standards for Privacy of Individually Identifiable Health Information (“Privacy Rule”); and 45 C.F.R. Parts 160 and 164, Subparts A and C, the Security Standard (“Security Rule”); as amended

18. Sections 504 and 508 of the Rehabilitation Act (29 U.S.C. § 794d), as amended

19. Homeland Security Presidential Directive (12) (HSPD-12), August 27, 2004

20. VA Directive 6500, “VA Cybersecurity Program,” February 24, 2021 (see VA NOTICE 24-18, dated September 27, 2024, “Update to VA Directive 6500 Cybersecurity Program”, and VA Notice 25-07, dated 3/18/25, “Amending VA Directive 6500 to incorporate M-24-15”)

21. VA Handbook 6500, “Risk Management Framework for VA Information Systems VA Information Security Program,” February 24, 2021 (see VA Notice 25-01, dated October 15, 2024, “Update to VA Handbook 6500 Risk Management Framework for VA Information Systems VA Information Security Program”, and VA Notice 25-06, dated 3/18/25, “Amending VA Directive 6500 to incorporate M-24-15”)

22. VA Handbook 6500.2, “Management of Breaches Involving Sensitive Personal Information (SPI),” June 30, 2023

23. VA Handbook 6500.6, “Contract Security,” March 12, 2010 (see VA Notice 24-12, dated April 22, 2024, “Update to VA Handbook 6500.6, Contract Security, Appendix C VA Information and Information System Security/Privacy Language For Inclusion Into Contracts, As Appropriate”)

24. VA Handbook 6500.8, “Information System Contingency Planning,” March 25, 2025

25. VA Handbook 6500.10, “Mobile Device Security Policy,” February 15, 2018

26. VA Handbook 6500.11, “VA Firewall Configuration,” August 22, 2017

27. OIT Process Asset Library (PAL), OIT Process Asset Library.

28. One-VA Technical Reference Model (TRM) (reference at https://www.va.gov/trm/TRMHomePage.aspx)

29. VA Directive 6508, “Implementation of Privacy Threshold Analysis and Privacy Impact Assessment,” October 15, 2014

30. VA Directive 6510, “VA Identity, Credential and Access Management,” September 3, 2024

31. VA Handbook 6510, “VA Identity, Credential and Access Management,” September 27, 2024

32. VA Directive and Handbook 6513, “Secure External Connections,” October 12, 2017

33. VA Directive 6300, “Records and Information Management,” September 21, 2018

34. VA Handbook, 6300.1, “Records Management Procedures,“ March 24, 2010

35. NIST SP 800-37 Rev 2, “Risk Management Framework for Information Systems and Organizations: A System Life Cycle Approach for Security and Privacy,” December 2018

36. NIST SP 800-53 Rev. 5, “Security and Privacy Controls for Federal Information Systems and Organizations,” September 23, 2020 (includes updates as of 12/10/2020)

37. VA Directive 0735, “Homeland Security Presidential Directive 12 (HSPD-12) Program,” October 26, 2015

38. VA Handbook 0735, “Homeland Security Presidential Directive 12 (HSPD-12) Program,” March 24, 2014

39. OMB Memorandum 05-24, “Implementation of Homeland Security Presidential Directive (HSPD) 12 – Policy for a Common Identification Standard for Federal Employees and Contractors,” August 5, 2005

40. OMB Memorandum M-19-17, “Enabling Mission Delivery Through Improved Identity, Credential, and Access Management,” May 21, 2019

41. OMB Memorandum, “Guidance for Homeland Security Presidential Directive (HSPD) 12 Implementation,” May 23, 2008

42. Federal Identity, Credential, and Access Management (FICAM) Architecture, June 30, 2023 (FICAM Architecture (idmanagement.gov))

43. NIST SP 800-116 Rev 1, “Guidelines for the Use of Personal Identity Verification (PIV) Credentials in Facility Access,“ June 2018

44. NIST SP 800-63-3, 800-63A, 800-63B, 800-63C, “Digital Identity Guidelines,” updated March 02, 2020

45. NIST SP 800-157, “Guidelines for Derived PIV Credentials,” December 2014

46. VA Memorandum, VAIQ #7100147, “Continued Implementation of Homeland Security Presidential Directive 12 (HSPD-12),” April 29, 2011 (reference https://www.voa.va.gov/documentlistpublic.aspx?NodeID=514)

47. IAM Identity Management Business Requirements Guidance document, May 2013, (reference Enterprise Architecture Section, PIV/IAM (reference https://www.voa.va.gov/documentlistpublic.aspx?NodeID=514)

48. VA Memorandum “Personal Identity Verification (PIV) Logical Access Policy Clarification,” July 17, 2019, https://www.voa.va.gov/DocumentView.aspx?DocumentID=4896

49. Trusted Internet Connections (TIC) 3.0 Core Guidance Documents, https://www.cisa.gov/publication/tic-30-core-guidance-documents

50. OMB Memorandum M-19-26, “Update to the Trusted Internet Connections (TIC) Initiative,” September 12, 2019

51. OMB Memorandum M-08-23, “Securing the Federal Government’s Domain Name System Infrastructure,” August 22, 2008

52. Sections 524 and 525 of the Energy Independence and Security Act of 2007, (P.L. 110–140), December 19, 2007

53. Section 104 of the Energy Policy Act of 2005, (P.L. 109–58), August 8, 2005

54. Executive Order 13221, “Energy-Efficient Standby Power Devices,” August 2, 2001

55. VA Directive 0057, “VA Environmental Management Program,” October 25, 2022

56. Office of Information Security (OIS) VAIQ #7424808 Memorandum, “Remote Access,” January 15, 2014, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28

57. Clinger-Cohen Act of 1996, 40 U.S.C. §11101 and §11103

58. “Veteran Focused Integration Process (VIP) Guide 4.0,” March 2021, https://www.voa.va.gov/DocumentView.aspx?DocumentID=4371

59. VA Memorandum “Proper Use of Email and Other Messaging Services,” January 2, 2018, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28

60. “Product Line Management Transformation Playbook” version 3.1, August 2023, https://www.voa.va.gov/DocumentView.aspx?DocumentID=4946

61. NIST SP 500-267B Revision 1, “USGv6 Profile,” November 2020

62. OMB Memorandum M-21-07, “Completing the Transition to Internet Protocol Version 6 (IPv6),” November 19, 2020

63. Social Security Number (SSN) Fraud Prevention Act of 2017

64. Section 240 of the Consolidated Appropriations Act (CAA) 2018, March 23, 2018

65. C.F.R Title 15 Part 7, “Securing the Information and Communications Technology and Services (ICTS) Supply Chain”, as amended

66. Executive Order 14028, “Executive Order on Improving the Nation's Cybersecurity,” May 12, 2021, https://bidenwhitehouse.archives.gov/briefing-room/presidential-actions/2025/01/16/executive-order-on-strengthening-and-promoting-innovation-in-the-nations-cybersecurity/

67. OMB Memorandum M-22-09, “Moving the U.S. Government Toward Zero Trust Cybersecurity Principles”, January 26, 2022, https://www.whitehouse.gov/wp-content/uploads/2022/01/M-22-09.pdf.

68. NIST SP 800-52 Revision 2, “Guidelines for the Selection, Configuration, and Use of Transport Layer Security (TLS) Implementations

69. OMB M-22-18, “Enhancing the Security of the Software Supply Chain through Secure Software Development Practices,” September 14, 2022

70. OMB M-23-16, “Update to Memorandum M-22-18,” June 9, 2023

71. OMB M-21-31, “Improving the Federal Government’s Investigative and Remediation Capabilities Related to Cybersecurity Incidents,” August 27, 2021

72. NIST SP 800-88 Revision 1 “Guidelines for Media Sanitization,” December 2014

73. CISA Binding Operational Directive (BOD) 19-02: “Vulnerability Remediation Requirements of Internet-Accessible Systems,” April 29, 2019, BOD 19-02: Vulnerability Remediation Requirements for Internet-Accessible Systems | CISA

74. CISA BOD 22-01: “Reducing the Significant Risk of Known Exploited Vulnerabilities,” November 3, 2021, BOD 22-01: Reducing the Significant Risk of Known Exploited Vulnerabilities | CISA

75. CISA BOD 23-01: Improving Asset Visibility and Vulnerability Detection on Federal Networks.” Cybersecurity & Infrastructure Security Agency (CISA), BOD 23-01: Improving Asset Visibility and Vulnerability Detection on Federal Networks | CISA

76. VA Directive 6550, Pre-Procurement Assessment and Implementation of Medical Devices/Systems, June 03, 2019

77. VA Memorandum, “VA Security Controls,” January 17, 2025, https://www.voa.va.gov/DocumentView.aspx?DocumentID=5010

78. E.O. 13960, “Promoting the Use of Trustworthy Artificial Intelligence in the Federal Government,” December 3, 2020

79. E.O. 14319, “Preventing Woke AI in the Federal Government,” July 23, 2025

80. OMB Memorandum M-25-21, “Accelerating Federal Use of AI through Innovation, Governance, and Public Trust,” April 3, 2025

81. OMB Memorandum M-25-22, “Driving Efficient Acquisition of Artificial Intelligence in Government,” April 3, 2025

82. OMB Memorandum M-26-04, “Increasing Public Trust in Artificial Intelligence (AI) Through Unbiased AI Principles,” December 11, 2025

SCOPE OF WORK

The Contractor shall provide the resources necessary to accomplish implementation of the CUI program for the Department of VA, Office of Privacy and Records Management (OPRM) as described in this Performance Work Statement (PWS). Specifically, the Contractor shall tailor VA specific CUI policy based on the NARA policy, stand-up executive steering committee, sustain CUI working group, develop CUI training, review IT systems, conduct self-inspections and prepare monthly status reports.

PERFORMANCE DETAILS

PERFORMANCE PERIOD

The Period of Performance (PoP) shall be one 12-month base period with four (4) 12-month option periods and two optional tasks. The PoP for the optional tasks shall not exceed the POP for the base or option period for which it was exercised. All base tasks shall be performed in the base and option periods, if exercised. In addition, the requirement includes two optional tasks, one for Web-based CUI Training and the other for 60 days of Transition support. The overall Task Order (TO) PoP shall not exceed 60 months.

Any work at the Government site shall not take place on Federal holidays or weekends unless directed by the Contracting Officer (CO).

There are 11 Federal holidays set by law (USC Title 5 Section 6103) that VA follows:

Under current definitions, five are set by date:

If any of the above falls on a Saturday, then Friday shall be observed as a holiday. Similarly, if one falls on a Sunday, then Monday shall be observed as a holiday.

The other six are set by a day of the week and month:

PLACE OF PERFORMANCE

Efforts under this PWS shall be considered onsite at the Government facility but the work shall be performed virtually or at the Government facility, 811 Vermont Avenue, NW, Washington, DC 20420.

TRAVEL

The Government does not anticipate travel under this effort to perform the tasks associated with the effort. Local travel to the duty location will not be reimbursed.

SPECIFIC TASKS AND DELIVERABLES

The Contractor shall perform the following:

PROJECT MANAGEMENT

CONTRACTOR PROJECT MANAGEMENT PLAN

The Contractor shall deliver a Contractor Project Management Plan (CPMP) that lays out the Contractor’s approach, timeline, and tools to be used in execution of the contract. The CPMP should take the form of both a narrative and graphic format that displays the schedule, milestones, risks, and resource support. The CPMP shall also include how the Contractor shall coordinate and execute planned, routine, and ad hoc data collection reporting requests as identified within the PWS. The initial baseline CPMP shall be concurred upon and updated in accordance with Section B of the contract. The Contractor shall update and maintain the VA PM approved CPMP throughout the PoP.

Deliverable:

A. Contractor Project Management Plan

REPORTING REQUIREMENTS

The Contractor shall submit a Weekly Status Report and Monthly Activities Report. The Contractor shall submit Weekly Status Reports to support the Weekly Status Meetings.

The Monthly Activities Report will support the activities performed for the month and will report activities, accomplishments and risk mitigation actions as well as planned activities for the next reporting period. This is accomplished by reviewing the progress and issues with respect to CUI implementation. In these Weekly Status Meetings, the CUI PM will review the progress made on the CUI implementation. In preparation of these weekly meetings, the Contractor shall submit status via Weekly Status Reports and the progress and issues will be discussed during the meeting.

The Contractor shall submit status of VA CUI and Information Security Awareness and Rules of Behavior training for all individuals engaged in the task. Status reporting shall identify a single Contractor Security Point of Contact (POC), the names of all personnel engaged on the task, the initial training date for VA CUI and Information Security Awareness and Rules of Behavior training for each person engaged in the task, and the next required training date training for each person engaged on the task.

To perform the tasks identified in the TO, each Contractor staff personnel must read, accept, and submit a copy of the VA CUI and Information Security Awareness and Rules of Behavior Certificate to the COR.

Deliverables:

A. Weekly Status Report B. Monthly Activities Report (IT Systems, Policies) C. VA CUI and Information Security and Rules of Behavior Training Certificates

5.1.3 TECHNICAL KICKOFF MEETING

A technical kickoff meeting shall be held within 10 days after TO award. The Contractor shall coordinate the date, time, and location (can be virtual) with the Contracting Officer (CO), the VA PM, the Contract Specialist (CS), and the COR. The Contractor shall provide a draft agenda to the CO and VA PM at least five (5) calendar days prior to the meeting. Upon Government approval of a final agenda, the Contractor shall distribute to all meeting attendees. During the kickoff-meeting, the Contractor shall present, for review and approval by the Government, the details of the intended approach, work plan, and project schedule for each effort via a Microsoft Office PowerPoint presentation. The Contractor shall submit the final updated presentation within three (3) calendar days after the meeting. The Contractor shall also distribute the meeting minutes of the kickoff meeting to the CO, COR and all attendees within three (3) calendar days after the meeting.

Deliverables:

A. Kick Off Meeting Agenda B. Kick Off Meeting Presentation Slide Deck C. Kick Off Meeting Minutes

5.2 TAILOR THE CUI POLICY DEVELOPED BY THE EXECUTIVE AGENT

FOR VA CUI DIRECTIVE AND HANDBOOK (BASE AND ALL OPTIONS)

The CUI policy is currently being developed for all Federal agencies by the Executive Agent, the National Archives and Records Administration (NARA). The Contractor shall review the policy guidance issued to Executive Branch departments and in coordination and consultation with Government personnel, tailor the guidance for the development of the VA CUI Directive and VA CUI Handbook concerning markings, safeguarding, dissemination and decontrol of CUI that, to the extent practicable and permitted by law, regulation, and Government-wide policies, shall remain consistent across categories and subcategories of CUI throughout the Executive Branch. VA does not currently have an electronic marking tool. The requirement is to review VA IT systems & toolsets to identify systems impacted by CUI and the contractor is to develop a plan will utilize an existing COTS solution. Additionally, the Contractor shall develop and finalize a CUI process guide (standard operating procedure).

The Contractor shall review the NARA (Executive Agent for CUI) policies quarterly, and apply updates and tailoring to the VA policy, communications plans, training, CUI Directive and CUI Handbook as required. Moreover, the Contractor shall maintain the current VA CUI Decision Matrix in order to ensure senior VA leaders provide the critical decisions according to a CUI milestone or event.

Deliverables:

A. Updated VA CUI Directive B.VA CUI Handbook C. CUI process guide

5.3 REVIEW OF VA INFORMATION TECHNOLOGY SYSTEMS TO IDENTIFY

SYSTEMS IMPACTED BY CUI

The VA requires critical support to ensure that the VA enterprise information system portfolio (currently over 700 information systems) continues to meet CUI compliance requirements. Under this task, the VA requires development of compliance strategies and system change requirements, and coordination with the VA OIT to conduct system impact assessments.

The Contractor shall review IT systems and toolsets, Personally Identifiable Information (PII) inventory, and artifacts created by Risk Vision and VA Systems Inventory (VASI) to identify systems impacted by CUI. The Contractor shall document the information describing all IT systems impacted by CUI in a written report, titled: Information Technology Systems Impacted by CUI Report. The Contractor shall prepare a report based on the plan for electronic marking solutions, titled “Plan for Electronic Marking Solutions Report” as required by the CUI registry and develop target dates for phased implementation in a Phased Implementation Target Dates Report.

The Contractor shall review VA Information Technology Systems Inventories, and tools for new or unidentified IT systems that must be added to the Information Technology Systems Impacted by CUI Report, and Plan for Electronic Markings Solutions Report.

The Contractor shall update the Information Technology Systems Inventories Impacted by CUI Report, Plan for Electronic Markings Report and shall provide Phased Implementation Target dates for any new or unidentified IT systems as required.

Furthermore, the Contractor shall implement the Electronic Marking Solutions across

VA.

In support of this requirement, the Contractor shall utilize a three-phased IT Systems Assessment Process approach that includes an update to the Baseline Assessment (Phase 1), an update to the Compliance Analysis (Phase 2), and an update to the Corrective Action Plan (Phase 3). These phases shall be completed in accordance with the following target dates:

Phase 1 - 12 months, Phase 2a 12 months Phase 2b 12 months, Phase 3 - 12 months.

The contractor shall develop and maintain the IT Systems Marking Strategic Plan. The Contractor shall coordinate with OIT, system owners, and other program offices to identify and assess IT systems for CUI compliance. The Contractor shall provide OIT and system owners with system-specific marking recommendations, as needed. The Contractor shall define CUI Impact Assessment criteria for any new systems or tools which may contain CUI and support completion CUI Impact Assessments, as needed.

The Contractor shall review and update the Baseline Assessment of initial inventory of all existing VA systems that likely contain CUI; the Compliance Analysis of the Baseline Assessment to determine if system security controls comply with CUI program and its categories; and thirdly, the Corrective Action Plan to include identification of gaps and a strategy to achieve compliance.

Deliverables:

A. A. Information Technology Systems Impacted by CUI Report B. IT Systems Marking Strategic Plan C. Electronic Marking Solutions Report D. Bimonthly System Completion Report E. Phased Implementation Target Dates Report F. Updated Baseline Assessment G. Updated Compliance Analysis H. Updated Corrective Action Plan

5.4 SELF-INSPECTION

The Contractor shall support the implementation of the Self-Inspection program by identifying offices, coordinating communications, responding to questions, and developing and executing actions and next steps. The Contractor shall document VA agency-level plans and target dates for the creation of a Self-Inspection Program Plan including reviews and assessments, to evaluate program effectiveness, measure the level of compliance with the Order and Notice, and monitor the progress of CUI implementation. The review and assessments in the Self-Inspection Program Plan shall be integrated with VA department policies and guidance.

The Contractor shall describe and document plans to integrate lessons learned from reviews, and assessments to improve operational policies, procedures, and training.

The Contractor shall provide Lessons Learned Reports. The Contractor shall establish a system for corrective action to prevent and respond to non-compliance with the Order and Notice. The Contractor shall provide documentation in the form of a Corrective Action Plan that reflects the analysis, and conclusions of the self-inspection program to the Executive Agent (EA) on an annual basis and as requested by the EA.

The contractor shall provide a review of the self-inspection program every 60 days and shall provide updates to the Self-Inspections Program Plan, Lessons Learned Reports, and Corrective Actions Plan as required as referenced in para 5.3. The Contractor shall apply lessons learned from the previous self-inspection efforts to the Self-Inspection Program Plan and the Corrective Action Plan.

The contractor shall develop VA CUI Incident Management procedures, responsibilities, and escalation criteria. The Contractor shall support the review of and response to CUI incidents and challenges and support the development of requirements for a CUI Incident Management tool. The Contractor shall develop Self-Inspection and Incident Management metrics and reporting mechanisms to report on and track open and completed items. The Contractor shall develop and implement a CUI Compliance Dashboard that measures implementation of all requirements defined in 32 CFR 2002.

The Contractor shall support other program implementation and sustainment activities as needed as defined by NARA (National Archives Registry Administration).

Deliverables:

A. Self-Inspection Program Plan Update B. Lessons Learned Reports C. VA Incident Management Program Plan D. Updates to the CUI Compliance Dashboard

5.5 WEB BASED CUI TRAINING

Upon approval of the CUI Enterprise Directive, the Contractor shall review agency-level development plans to ensure that VA personnel or Contractors and other information sharing partners who create or handle CUI have a satisfactory knowledge and understanding of relevant CUI categories and associated markings, applicable safeguarding, dissemination including CUI handling agreements, and decontrol policies and procedures. The Contractor shall coordinate and consult with Government personnel to describe plans and tailor the CUI Training Plan for the Talent Management System (TMS) to meet the specific needs of the agency and the activities that VA personnel or Contractors and other information-sharing partners are expected to perform as determined by the agency. CUI training has been developed by the Executive Agent. The Contractor shall tailor the already developed training to meet specific VA requirements for training VA personnel and contractors who handle CUI.

Upon completion of the tailored training, this training shall be turned over to the OIT, Information Technology Workforce Development (ITWD), for deployment and sustainment in the TMS.

The Contractor shall review the training materials on a quarterly basis for changes to the NARA policy and provide any required updates to the training management plan and training for delivery to ITWD.

Deliverables:

A. CUI Training Plan B. CUI Training Materials for the TMS

5.6 TRANSITION PLAN (OPTIONAL TASK 1)

The VA may exercise this optional task once, at any time during the base or option periods. If exercised, the PoP will be two months and will not exceed the overall TO POP of five years. The Contractor shall transition activities and services to the Federal Government or to a follow-on Contractor at the end of this TO period of performance for a period of two months. The Contractor shall perform the following activities:

1. Create a Transition Plan that describes the Contractor’s transition approach and activities.

2. Provide all pertinent information needed to continue the services being performed by the Contractor.

3. Provide current inventory of all Government-owned information or assets used by the Contractor along with full support in the reconciliation of this inventory.

4. Provide “shadowing” and other knowledge transfer meetings and opportunities to facilitate the transfer of information, processes, and data needed to continue the services being performed by the Contractor.

5. Provide up-to-date program management documents, reports, process flows, dashboard, templates, training master materials, and any other artifact as requested.

Deliverable:

A. Transition Plan

5.7 OPTION PERIOD ONE

If Option Period One is exercised, the Contractor shall perform the requirements described in PWS Paragraphs 5.1 through 5.5.

5.8 OPTION PERIOD TWO

If Option Period Two is exercised, the Contractor shall perform the requirements described in PWS Paragraphs 5.1 through 5.5.

5.9 OPTION PERIOD THREE

If Option Period Two is exercised, the Contractor shall perform the requirements described in PWS Paragraphs 5.1 through 5.5.

5.10 OPTION PERIOD FOUR

If Option Period Two is exercised, the Contractor shall perform the requirements described in PWS Paragraphs 5.1 through 5.5.

GENERAL REQUIREMENTS

ENTERPRISE AND IT FRAMEWORK

VA TECHNICAL REFERENCE MODEL

The Contractor shall comply with the VA OIT Technical Reference Model (VA TRM). Compliance with the VA TRM is achieved by using only technologies and standards that are listed as approved for use in the VA TRM. The Contractor shall provide all necessary information requested by VA to ensure TRM approval is obtained prior to use on VA’s network.

ZERO TRUST – VA CRITICAL SECURITY CONTROLS

VA has established minimum mandatory security requirements and requires that any network connected software system or service must meet the VA Critical Security Controls as outlined in the VA Memorandum, “VA Security Controls”, https://www.voa.va.gov/DocumentView.aspx?DocumentID=5010. VA Critical Security Controls identify the minimum mandatory requirements that must be implemented across all VA enterprise infrastructure, cloud computing environments, information systems, networks, and specialized devices (medical devices/systems, special-purpose systems, and research scientific computing devices) that process, store, and/or transmit VA data. Effective July 1, 2025, the Contractor shall implement these VA Critical Security Controls, within any network connected software system or service prior to being authorized for use in the VA. This functional requirement is not negotiable, and Plan of Action & Milestones (POAM) will not be accepted in the event these controls cannot be implemented for new systems. Critical Security Controls are intended to increase VA’s security posture and provide security and privacy risk visibility into the VA network and is not a new requirement. The Contractor’s failure to maintain these VA Critical Controls after implementation will result in VA discontinuing the use of the system.

FEDERAL IDENTITY, CREDENTIAL, AND ACCESS MANAGEMENT (FICAM)

The Contractor shall ensure Commercial Off-The-Shelf (COTS) product(s), software configuration and customization, and/or new software are Personal Identity Verification (PIV) card-enabled by accepting HSPD-12 PIV credentials using VA Enterprise Architecture (EA), and VA Identity and Access Management (IAM) approved Enterprise Technology Guidelines (ETG). The Contractor shall ensure all Contractor delivered applications and systems comply with the VA Identity, Credential, and Access Management policies and guidelines set forth in Executive Order 14028, VA Handbook 6510 VA Identity and Access Management, VA Handbook 0735 Homeland Security Presidential Directive 12 (HSPD-12) Program, CISA Binding Operational Directive 23-01, and align with the Federal Identity, Credential, and Access Management Roadmap and Implementation Guidance v2.0.

The Contractor shall ensure all Contractor delivered applications and systems provide user authentication services compliant with the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-63-3, VA Handbook 6500, and VA IAM enterprise requirements for direct, assertion-based authentication, and/or trust based authentication, as determined by the ETGs. Direct authentication at a minimum must include Public Key Infrastructure (PKI) based authentication supportive of PIV card and/or Common Access Card (CAC), as determined by the business need.

The Contractor shall ensure all Contractor delivered applications and systems conform to the specific Identity and Access Management PIV requirements set forth in the Office of Management and Budget (OMB) Memoranda M-05-24, M-19-17, M-22-09, and NIST Federal Information Processing Standard (FIPS) 201-3. Contractor delivered applications and systems shall be on the FIPS 201 Approved Product List (APL). If the Contractor delivered application and system is not on the APL, the Contractor shall be responsible for taking the application and system through the FIPS 201 Evaluation Program.

The Contractor shall ensure all Contractor delivered applications and systems support:

1. Automated provisioning and are able to use enterprise provisioning service.

2. Interfacing with VA’s Master Person Index (MPI) to provision identity attributes, if the solution relies on VA user identities. MPI is the authoritative source for VA user identity data.

3. The VA defined unique identity (Secure Identifier [SEC ID] / Integrated Control Number [ICN]).

4. Multiple authenticators for a given identity and authenticators at every Authenticator Assurance Level (AAL) appropriate for the solution.

5. Identity proofing for each Identity Assurance Level (IAL) appropriate for the solution.

6. Federation for each Federation Assurance Level (FAL) appropriate for the solution, if applicable.

7. Two-factor authentication (2FA) through an applicable Technology Guideline as outlined in VA ETG.

8. A Security Assertion Markup Language (SAML) implementation if the solution relies on assertion-based authentication. Additional assertion implementations, besides the required SAML assertion, may be provided as long as they are compliant with NIST SP 800-63-3 guidelines.

9. Authentication/account binding based on trusted Hypertext Transfer Protocol (HTTP) headers if the solution relies on Trust based authentication.

10. Role Based Access Control.

11. Auditing and reporting capabilities.

12. Compliance with VIEWS 00155984, PIV Logical Access Policy Clarification https://www.voa.va.gov/DocumentView.aspx?DocumentID=4896.

The required Assurance Levels for this specific effort are Identity Assurance Level 3, Authenticator Assurance Level 3, and Federation Assurance Level 3.

INTERNET PROTOCOL VERSION 6 (IPv6)

The Contractor solution shall support IPv6-Only based upon the memo issued by the Office of Management and Budget (OMB) on November 19, 2020 (https://www.whitehouse.gov/wp-content/uploads/2020/11/M-21-07.pdf). Which defines IPv6-only as the state of an operational system or service when IPv4 protocol functions (addressing, packet forwarding) are not in use. The NIST USGv6 profile defines technical requirements for a product to be capable of operating in IPv6-Only environments. IPv6-Only technology, in accordance with the USGv6 Program (https://www.nist.gov/programs-projects/usgv6-program/usgv6-revision-1), NIST Special Publication (SP) 500-267B Revision 1 “USGv6 Profile” (https://doi.org/10.6028/NIST.SP.500-267Br1), and NIST SP 800-119 “Guidelines for the Secure Deployment of IPv6” (https://doi.org/10.6028/NIST.SP.800-119), compliance shall be included in all IT infrastructures, application designs, application development, operational systems and sub-systems, and their integration. In addition to the above requirements, all devices, applications, and systems shall support all applicable functionality on native IPv6-Only as well as dual stack (IPv6 / IPv4) connectivity without additional memory or other resources being provided by the Government, so that they can function in a mixed environment. All public/external facing servers and services (e.g., web, email, DNS, ISP services, etc.) shall support native IPv6-Only and dual stack (IPv6 / IPv4) users and all internal infrastructure and applications shall support using native IPv6-Only and dual stack (IPv6 / IPv4) for all functionality and operations.

TRUSTED INTERNET CONNECTION (TIC)

The Contractor solution shall meet the requirements outlined in Office of Management and Budget Memorandum M-19-26, “Update to the Trusted Internet Connections (TIC) Initiative“ (https://www.whitehouse.gov/wp-content/uploads/2019/09/M-19-26.pdf), VA Directive 6513 “Secure External Connections”, and shall comply with the TIC 3.0 Core Guidance Documents, including all Volumes and TIC Use Cases, found at the Cybersecurity & Infrastructure Security Agency (CISA) (https://www.cisa.gov/publication/tic-30-core-guidance-documents).

STANDARD COMPUTER CONFIGURATION

The Contractor IT end user solution that is developed for use on standard VA computers shall be compatible with and be supported on the standard VA operating system, Windows 10 (64bit) and Windows 11, Edge (Chromium based), and 365 Apps for enterprise. Applications delivered to VA and intended to be deployed to Windows 10 and or Windows 11 workstations shall be delivered as a signed .msi package with switches for silent and unattended installation and updates shall be delivered in signed .msp file formats for easy deployment using Microsoft Endpoint Configuration Manager (CM) VA’s current desktop application deployment tool. Signing of the software code shall be through a vendor provided certificate that is trusted by VA using a code signing authority such as Verizon/Cybertrust or Symantec/VeriSign. The Contractor shall also ensure and certify that their solution functions as expected when used from a standard VA computer, with non-admin, standard user rights that have been configured using the Defense Information Systems Agency (DISA) Secure Technical Implementation Guide (STIG) specific to the particular client operating system being used.

VETERAN FOCUSED INTEGRATION PROCESS (VIP) AND PRODUCT LINE MANAGEMENT (PLM)

The Contractor shall support VA efforts IAW the Veteran-Focused Integration Process (VIP) Guide and Product Line Management (PLM) Playbook. The major focus of VIP is on Enterprise Oversight, Governance, reporting, and establishing practices that focus on outcomes and continuously delivering sustainable IT capabilities to benefit the Veteran. PLM is a framework that focuses on delivering functional products that provide the highest priority work to customers while delivering simplified, reliable, and practical solutions to the business, medical staff, and our Veterans. The VIP Guide is a companion guide to the PLM Transformation Playbook and can be found at: https://www.voa.va.gov/DocumentView.aspx?DocumentID=4371 and the PLM Transformation Playbook can be found at https://www.voa.va.gov/DocumentView.aspx?DocumentID=4946. VIP and PLM are the authoritative processes that IT projects must follow to ensure development and delivery of IT products.

The VIP Guide provides guidance for transitioning from project-centric to product-centric delivery. The VIP guide applies to all OIT Office of Management and Budget (OMB) reportable products that are required to collect and report costs, schedules, risks, and other valuable information in VA PARS (whether products are procured or developed by VA) and any VA Information Technology project effort in Software Product Management (SPM) and Infrastructure Operations (IO), or their successors, that touch the VA network regardless of IT organizational alignment (whether it spends government funding from VA's Congressional IT Appropriation or any other appropriation).

The PLM Transformation Playbook details how OIT leadership expects Product Lines (PLs) to implement PLM, DevOps, and Lean-Agile principles, methods, practices, and techniques through levels of maturity. The PLM Transformation Playbook applies to all Information Technology (IT) products aligned to PLs in the Software Product Management, Infrastructure Operations and Product Engineering organizations within the OIT organization.

Others outside the referenced groups or organizations may use the VIP Guide and PLM Transformation Playbook for situational awareness as needed.

PROCESS ASSET LIBRARY (PAL)

The Contractor shall perform their duties consistent with the processes defined in the OIT Process Asset Library (PAL). The PAL includes a spectrum of OIT functions and activities, such as project management, operations, service delivery, communications, acquisition, and resource management. PAL serves as an authoritative and informative repository of searchable processes, activities or tasks, roles, artifacts, tools and applicable standards and guides to assist the OIT workforce, Government and Contractor personnel. OIT utilizes PAL processes to ensure compliance with policies and regulations and to meet VA quality standards. The PAL includes the contractor onboarding process consistent with Section 6.2.2 and can be found at process_CONB_ext.docx (live.com). The main PAL can be accessed at www.va.gov/process.

AUTHORITATIVE DATA SOURCES

The VA Enterprise Architecture Repository (VEAR) is one component within the overall EA that establishes the common framework for data taxonomy for describing the data architecture used to develop, operate, and maintain enterprise applications. The Contractor shall comply with the department’s Authoritative Data Source (ADS) requirement that VA systems, services, and processes throughout the enterprise shall access VA data solely through official VA ADSs where applicable, see below. The Information Classes which compose each ADS are located in the VEAR, in the Data & Information domain. The Contractor shall ensure that all delivered applications and system solutions support:

1. Interfacing with VA’s Master Person Index (MPI) (formerly the Master Veteran Index (MVI)) to provision identity attributes, if the solution relies on VA user identities. MPI is the authoritative source for VA user identity data.

2. Interfacing with Capital Asset Inventory (CAI) to conduct real property record management actions, if the solution relies on real property records data. CAI is the authoritative source for VA real property record management data.

3. Interfacing with electronic Contract Management System (eCMS) for access to contract, contract line item, purchase requisition, offering vendor, and solicitation information above the micro-purchase threshold, if the solution relies on procurement data. ECMS is the authoritative source for VA procurement actions data.

4. Interfacing with HRSmart Human Resources Information System to conduct personnel action processing, on-boarding, benefits management, and compensation management, if the solution relies on personnel data. HRSmart is the authoritative source for VA personnel information data.

5. Interfacing with VA Profile to access personal contact information, if the solution relies on VA Veteran personal contact information data. VA Profile is the authoritative source for VA Veteran Personal Contact Data.

6. Interfacing with VA/Department of Defense (DoD) Identity Repository (VADIR) for determining eligibility for VA benefits under Title 38, if the solution relies on qualifying active-duty military service data. VADIR is the authoritative source for qualifying active-duty military service in VA.

7. Interfacing with VA Systems Inventory (VASI) to access VA systems information, if the solution relies on VA system information. VASI is the authoritative source for VA Information Technology systems.

8. Interfacing with Enterprise Mission Assurance Support Service (eMASS) to access the Authority to Operate (ATO) status of all VA Information Systems. eMASS contains the official Authority to Operate (ATO) status of all VA Information Systems.

SOCIAL SECURITY NUMBER (SSN) REDUCTION

The Contractor solution shall support the Social Security Number (SSN) Fraud Prevention Act (FPA) of 2017 which prohibits the inclusion of SSNs on any document sent by mail. The Contractor support shall also be performed in accordance with Section 240 of the Consolidated Appropriations Act (CAA) 2018, enacted March 23, 2018, which mandates VA to discontinue using SSNs to identify individuals in all VA information systems as the Primary Identifier. The Contractor shall ensure that any new IT solution discontinues the use of SSN as the Primary Identifier to replace the SSN with the ICN in all VA information systems for all individuals. The Contractor shall ensure that all Contractor delivered applications and systems integrate with the VA MPI for identity traits to include the use of the ICN as the Primary Identifier. The Contractor solution may only use a Social Security Number to identify an individual in an information system if and only if the use of such number is required to obtain information VA requires from an information system that is not under the jurisdiction of VA.

GENERATIVE ARTIFICIAL INTELLIGENCE REQUIREMENTS

If Artificial Intelligence (AI) is part of the Contractor system/solution, the Contractor shall be in compliance with E.O. 13960 and 14319, OMB Memorandums M-25-21, M-25-22, and M-26-04, and VA Directive and Handbook 6500 to support VA in trustworthy, secure, responsible, accountable, Truth Seeking, and Ideologically Neutral AI innovation.

No web-based, publicly available generative AI service has been approved for use with VA-sensitive data including, but not limited to OpenAI’s ChatGPT, Microsoft’s Copilot, Google’s Gemini, and Anthropic’s Claude. No PII, protected health information (PHI), or VA-sensitive data should be entered into these unapproved services. The entire definition of VA Sensitive Data can be found at 38 U.S.C. § 5727 (23). The Contractor shall protect VA Sensitive data from unauthorized disclosure or use, and from being used to train or improve the functionality of the vendor's commercial offerings without express permission from VA.

The Contractor shall deliver the services, technical data, configurations, models, weights, documentation or other information, including source code, developed during contract performance. The Contractor, in collaboration with VA, must evaluate the output of any AI tool for accuracy prior to using the output in VA efforts. All data, including models, weights, algorithms, and outputs generated using either Government-furnished data or data first developed under this contract shall be the property of the Government with unlimited rights as defined by FAR 52.227-14. The Contractor shall also deliver any custom-developed code developed with AI methodologies in accordance with the SHARE IT Act, if applicable. VA shall also retain unlimited rights to any improvements to that data, including the continued design, development, testing, and operation of AI systems and/or systems utilizing AI.

The Contractor shall ensure that all AI Systems, including Large Language Models (LLM), whether standalone LLMs or integrated into broader software platforms, procured under this effort and/or used in performance of this contract complies with the Unbiased AI Principles as defined in Executive Order 14319 and OMB Memorandum M-26-04, e.g. Truth Seeking and Ideologically Neutral, as applicable to the intended use of the system.

The Contractor shall ensure that AI System/LLM generated outputs are truthful in responding to user prompts seeking factual information or analysis, prioritize historical accuracy, scientific inquiry, and objectivity, as well as acknowledge uncertainty where reliable information is incomplete or contradictory and do not fabricate, hallucinate, or present unverifiable information as fact.

The Contractor shall ensure that LLMs and AI outputs are neutral, nonpartisan tools that do not manipulate responses in favor of ideological dogmas such as Diversity, Equity, and Inclusion (DEI). The Contractor shall ensure that the LLMs, including the AI System, are not intentionally encoded with partisan or ideological judgments within an AI System’s/LLM’s outputs unless those judgments are prompted by or otherwise readily accessible to the end user.

Compliance with the AI requirements of this contract, including adherence to the Unbiased AI Principles, Truth-Seeking and Ideological Neutrality requirements, disclosure obligations, monitoring and reporting requirements, and corrective action responsibilities, is a material condition of eligibility for payment and continued performance. In accordance with OMB Memorandum M-26-04, failure to comply with these requirements, or refusal to take timely and appropriate corrective action to remedy identified noncompliance, may constitute a material breach of contract and may result in remedies consistent with the terms of the contract and applicable law including but not limited to…