36C10B26Q0450.docx

Call Recording Exports and Retention

GENERAL INFORMATION

Technology Acquisition Center

23 Christopher Way Eatontown NJ 07724

POINT OF CONTACT*

Contract Specialist Belinda Espindola belinda.espindola@va.gov 848-377-5129

PLACE OF PERFORMANCE

POSTAL CODE

COUNTRY

ADDITIONAL INFORMATION

AGENCY’S URL

URL DESCRIPTION

EMAIL DESCRIPTION

DESCRIPTION

The U.S. Department of Veterans Affairs (VA) is undergoing a significant technology transformation, migrating all unified communications and contact center operations. As part of this transition, the VA must preserve, manage, and provide compliant access to hundreds of millions of legacy call recordings currently stored across three on-premise platforms: Calabrio One, Avaya, and Verint. These recordings must be retained in accordance with National Archives and Records Administration (NARA) mandates, with variable retention policies by call type — including crisis, benefits, and healthcare interactions.

The VA needs a solution that extracts, decrypts, and standardizes its legacy recordings into an open format, consolidates them into a single compliant archive, and allows the decommissioning of these platforms once the contact center migration is complete.

Item\Qty Brand name or equal Base Year

Optional CLINs

Option Year 1

Option Year 2

Option Year 3

Option Year 4

Please see attached Product Description

This notice does not in itself represent the issuance of a formal request for proposal/quote and is not intended to be taken as such. This is a request for Information (RFI) only and shall not be considered an Invitation for Bid, Request for Quotation, or a Request for Proposal. Do not submit a proposal or a quote. This market research is issued for information and planning purposes only and does not constitute a solicitation nor does it restrict the Government as to the ultimate acquisition approach. In accordance with FAR 15.201(e), responses to this notice are not offers and cannot be accepted by the Government to form a binding contract. Additionally, there is no obligation on the part of the Government to acquire any products or services described in this RFI. You will not be entitled to payment for direct or indirect costs that you incur in responding to this RFI. Any contract that might be awarded based on information received or derived from this market research will be the outcome of a competitive process. Interested parties are responsible for adequately marking proprietary, restricted or competition sensitive information contained in their response. The Government does not intend to pay for the information submitted in response to this RFI

Submittal Instructions:

If your company is capable of providing the aforementioned products/services, please submit a Vendor Capabilities Statement, limited to five pages for your company, to include a cover page which indicates your company’s full name, points of contact and your size standard for NAICS 561422.

All interested parties who can supply all the required products/services shall respond no later than 12:00 PM EST on June 10, 2026, via email to Belinda.espindola@va.gov.

Sources Sought Notice Sources Sought Notice See attached document: PD Call Recording Exports.

Sources Sought Notice

PRODUCT DESCRIPTION (PD)

DEPARTMENT OF VETERANS AFFAIRS

Office of Information and Technology (OIT), Development, Security, and Operations (DevSecOps) Connectivity & Collaboration Services (CCS) Unified Communications (UC)

Call Recording Exports and Retention

Date: 3/19/2026 PD Version Number: 1.0

Contents

PRODUCT REQUIREMENTS

The U.S. Department of Veterans Affairs (VA) is undergoing a significant technology transformation, migrating all unified communications and contact center operations. As part of this transition, the VA must preserve, manage, and provide compliant access to hundreds of millions of legacy call recordings currently stored across three on-premise platforms: Calabrio One, Avaya, and Verint. These recordings must be retained in accordance with National Archives and Records Administration (NARA) mandates, with variable retention policies by call type — including crisis, benefits, and healthcare interactions.

The VA needs a solution that extracts, decrypts, and standardizes its legacy recordings into an open format, consolidates them into a single compliant archive, and allows the decommissioning of these platforms once the contact center migration is complete.

1.1 ITEM 1 SALIENT CHARACTERISTICS

1.11 Source Systems

The VA's legacy recording environment consists of the following systems:

1. Calabrio One v11.5 (Main Production) — Single-tenant, Azure Cloud storage. Confirmed file count: approximately 227,381,000 files (January 2018 – present).

1. Calabrio One v11.5 (Legacy System) — Single-tenant, actively purging. Confirmed file count: approximately 1,860,000 files. Count will decrease over time.

1. Avaya / Verint 15.2 — Thales KMS (2 KMS instances). Azure Blob storage. File count: approximately 42,618,159 files.

Total confirmed 458,811,000 files.

Base Year

Optional CLINs

Option Year 1

Option Year 2

Option Year 3

Option Year 4

1.12 Deliverables

1. Extraction of all call recordings and associated metadata from Calabrio (main and legacy) and Avaya/Verint environments.

1. Decryption of all encrypted files, leveraging the VA's existing Thales KMS credentials.

1. Conversion to open-standard WAV format with associated metadata, stored in a VA-designated location (on-premise, Azure Blob, or AWS S3).

1. Deployment and configuration of Continuity Replay within the VA's approved hosting environment (on-premise or FedRAMP-certified AWS).

1. Configuration of NARA-compliant retention policies by call type (crisis, benefits, healthcare, etc.).

1. Professional services including project management, installation, and training.

1.13 Continuity Replay

The chosen solution shall provide Continuity Replay. Continuity Replay shall be configured at deployment to enforce NARA retention requirements across the VA's diverse call types. The system shall apply retention periods based on metadata attributes — such as call type, department, or location — ensuring that crisis calls, benefits interactions, and healthcare recordings are each held for the appropriate duration and automatically purged upon expiry. Legal hold capabilities will allow the VA to pause purge on specific files flagged for audit, compliance review, or litigation support.

Core Capabilities

1. Dashboard: Real-time visibility into interactions under legal hold, files scheduled for purge in the next 30 days, and total archive metrics by year.

1. Advanced Search & Replay: Intuitive filter interface by date range, user, interaction ID, group, department, call type, and custom tags. Playback of any archived audio directly in-browser.

1. On-Demand Transcription: Any archived call can be transcribed within the platform, regardless of whether it was transcribed by the original recording system. Useful for the VA's ad hoc transcription workflows.

1. NARA Retention Engine: Configurable retention policies by metadata attribute. Automatic purge scheduling with pre-purge notification. Legal hold to override purge for specific interactions.

1. Role-Based Access Control (RBAC): Granular permissions by user, group, or department. Full audit trail of all access, downloads, legal holds, and replay events.

1. Bulk Export: Export interactions and metadata in bulk for audit response, litigation support, or downstream processing.

1. Multi-Interaction Support: Supports audio calls, email, chat, screen recordings, and more — future-proofed for all interaction types the VA may need to archive.

1.14 Salient Technical Specifications

NOTICE OF THE FEDERAL ACCESSIBILITY LAW AFFECTING ALL INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) PROCUREMENTS (SECTION 508)

On January 18, 2017, the Access Board issued a final rule that updated accessibility requirements covered by Section 508 and refreshed guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The final rule went into effect on January 18, 2018. The revisions and updates to the Section 508-based standards and Section 255-based guidelines are intended to ensure that information and communication technology (ICT) covered by the respective statutes is accessible to and usable by individuals with disabilities.

1.2 SECTION 508 – INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) STANDARDS

The Section 508 standards established by the Access Board are incorporated into, and made part of all VA orders, solicitations and purchase orders developed to procure ICT. These standards are found in their entirety at: Revised 508 Standards and 255 Guidelines (access-board.gov). A single PDF file version of the Revised Section 508 Standards and 255 Guidelines will be supplied upon request, or can be obtained from the Access Board website. Federal agencies must comply with the Rehabilitation Act of 1973, as amended.

The Contractor shall comply with “508 Chapter 2: Scoping Requirements” for all electronic ICT and content delivered under this contract. Specifically, as appropriate for the technology and its functionality, the Contractor shall comply with the technical standards marked here:

1.3 COMPATABILITY WITH ASSISTIVE TECHNOLOGY

The standards do not require installation of specific accessibility-related software or attachment of an assistive technology device. Section 508 requires that ICT be compatible with such software and devices so that ICT can be accessible to and usable by individuals using assistive technology, including but not limited to screen readers, screen magnifiers, and speech recognition software.

1.4 ACCEPTANCE AND ACCEPTANCE TESTING

Deliverables resulting from this solicitation will be accepted based in part on satisfaction of the Section 508 Chapter 2: Scoping Requirements standards identified above.

The Government reserves the right to test for Section 508 Compliance before delivery. The Contractor shall be able to demonstrate Section 508 Compliance upon delivery.

INFORMATION TECHNOLOGY USING SUSTAINABLE PRODUCTS

The Contractor shall comply with Sections 524 and Sections 525 of the Energy Independence and Security Act of 2007; Section 104 of the Energy Policy Act of 2005; Executive Order 14148, “Initial Rescissions of Harmful Executive Orders and Actions,” dated January 20, 2025; Executive Order 13221, “Energy-Efficient Standby Power Devices,” dated August 2, 2001; and the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) to provide ENERGY STAR® certified and Federal Energy Management Program (FEMP) Designated Low Standby Power information technology products, see https://www.energy.gov/femp/search-energy-efficient-products. See http://www.energystar.gov for complete product specifications and updated lists of Energy Star certified products. FEMP low standby power product listing can be found at https://www.energy.gov/femp/low-standby-power-product-list.

The Contractor shall provide products that meet the definition of sustainable products if the products are delivered to the Government; furnished by the Contractor for use by the Government, incorporated into the construction of a public building or public work, or acquired by the Contractor for use in performing services under a Government contract where the cost of the products is a direct cost to a Government contract (versus costs which are normally applied to a contractor's general and administrative expenses or indirect costs).

Specifically, the Contractor shall provide sustainable products under this contract in accordance with RFO 52.223-23 (NOV 2025). The applicable products with their associated certification and/or designation required (e.g. Energy Star, FEMP Low Standby Power) are identified within the product requirements specifications in this PD. The Contractor shall self-certify that its proposed products meet the certification(s) and/or designation(s) specified.

SHIPMENT OF HARDWARE OR EQUIPMENT

(State the acceptance criteria and provide Shipping Address / Mark For requirements. For National Acquisitions, see below.)

Inspection: Destination Acceptance: Destination Free on Board (FOB): Destination

Ship To and Mark For:

Primary

Alternate

Name:

Name:

Address:

Address:

Voice:

Voice:

Email:

Email:

1.5 SPECIAL SHIPPING INSTRUCTIONS

Prior to shipping, Contractor shall notify Site POCs, by phone followed by email, of all incoming deliveries including line-by-line details for review of requirements. The Contractor shall not make any changes to the delivery schedule at the request of Site POC.

Contractors shall coordinate deliveries with Site POCs before shipment of <hardware> hardware to ensure sites have adequate storage space.

All shipments, either single or multiple container deliveries, shall bear the VA IFCAP Purchase Order number (if applicable) on external shipping labels and associated manifests or packing lists. In the case of multiple container deliveries, a statement readable near the VA Integrated Funds Distribution, Control Point Activity, Accounting and Procurement (IFCAP) Purchase Order (PO) or Contract number shall indicate total number of containers for the complete shipment (e.g. “Package 1 of 2”), clearly readable on manifests and external shipping labels.

Packing Slips/Labels and Lists shall also include the following:

IFCAP PO # or Contract No.: ____________ (e.g., 166-E11234 (the IFCAP PO number is located in block #20 of the Standard Form, SF 1449)) Project Description: (e.g. Tier I Lifecycle Refresh)

Total number of Containers: Package ___ of ___. (e.g., Package 1 of 3)

1.6 NATIONAL ACQUISITIONS

Shipment/Delivery Kick-off Meeting

The Contractor shall conduct a Shipment/Delivery Kick-off Meeting with the VA Program Manager (PM), COR, Delivery Date Coordinator, Implementation Manager, and Facility CIOs (or designee) to discuss delivery schedule requirements and facilitate delivery of equipment. This meeting may be held in conjunction with the post award conference or identified technical kickoff meeting, if applicable. The Contractor shall also present the Shipment/Delivery Weekly Progress Report format for review and approval by the Government. This meeting, if held independently, shall be conducted telephonically within ten days after award and shall incorporate any delivery schedule changes to the draft Delivery Schedule identified by the Government.

Shipment/Delivery Weekly Progress Report

The Contractor shall provide a Shipment/Delivery Weekly Progress Report which shall identify the items shipped, the serial number associated with each piece of equipment; the date of each shipment; the status of each shipment, tracking information, and information relative to Government-receipt of the equipment items at each delivery site. In addition, the Shipment/Delivery Weekly Progress Report shall identify any problems and provide a description of how the problems were resolved/addressed. If problems have not been completely resolved, the Contractor shall provide an explanation and status of resolution. Shipment/Delivery Weekly Progress Reports shall be submitted in Microsoft Excel Format and shall clearly identify each serial number of the equipment being delivered with one (1) serial number per cell.

Inspection: Destination Acceptance: Destination Free on Board (FOB): Destination

Packing Slips/Labels and Lists shall also include the following:

IFCAP PO #: ____________ (e.g., 166-E11234 (the IFCAP PO number is located in block #20 of the SF 1449)) Project Description: (e.g. Tier 1 Lifecycle Refresh)

Total number of Containers: Package ___ of ___. (e.g., Package 1 of 3)

Deliverables:

A. Master Delivery Schedule B. Shipment/Delivery Weekly Progress Report

GENERAL REQUIREMENTS

1.7 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.

1.8 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.

1.9 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 Integrated Control Number (ICN) in all VA information systems for all individuals. The Contractor shall ensure that all Contractor delivered applications and systems integrate with the VA Master Person Index (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.

1.10 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.

1.11 SOFTWARE AND LICENSING REQUIREMENTS

The Contractor shall be responsible for the provision of all software licenses and any associated licensing maintenance required for any development, delivery, integration, operation, and/or maintenance associated with its proposed application(s), software products, software solution, and/or system including, but not limited to, any and all application(s), software and/or software products that comprise, are a part of, or integrate with the Contractor’s proposed application(s), software products, software solution, and/or system for the life of any resulting contract.

1.12 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.)

1.13 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 withholding of payment, termination for cause/default, or other appropriate contractual remedies, as determined by the Contracting Officer.

All AI for delivery and/or use in performance of the contract shall adhere to the VA Trustworthy AI Framework, available at https://department.va.gov/ai/trustworthy/. Once the Contractor has obtained CO authorization to use specific AI in contract performance, the Contractor shall provide the COR a signed Statement of Attestation prior to AI implementation as identified in the Artificial Intelligence in VA Contracts clause, to include its associated list of AI being used in contract performance.

Deliverable:

1. Statement of Attestation

1.13.1 AI SYSTEM/LLM DEVELOPMENT AND OPERATION DOCUMENTATION REQUIREMENTS

To enable Government continued assessment of compliance with Trustworthy AI requirements and both Unbiased AI Principles, Truth-seeking and Ideological Neutrality, in accordance with OMB M-26-04, the Contractor shall provide AI System/LLM Development and Operation Documentation Package to include, at a minimum:

1. Acceptable Use Policy The Contractor shall provide an Acceptable Use Policy document governing its AI operation that characterizes and differentiates appropriate and inappropriate use of their product offering

1. Model Cards, System Cards and/or Data Cards The Contractor shall provide documentation describing essential information about the model, system, and or data as it relates to the AI/LLM product offering. The documentation shall address summaries of training process, identified risks and mitigations, and model evaluation scores on LLM benchmarks at a minimum, where appropriate

1. End User Resources The Contractor shall provide documentation to include product tutorials, developer guides, and/or other tools to assist VA in ensuring proper use of the AI/LLM to maximize utility

1. Mechanism for End User Feedback The Contractor shall provide documentation describing the mechanism employed to provide feedback to the Offeror on outputs identified that violate the Unbiased AI Principles. This may be satisfied by a general inbox, specific Point of Contact, or similar feedback mechanism.

1. Pre-Training and Post-Training Activities of the AI System/LLM The Contractor shall provide documentation of Pre-Training and Post Training Activity that provides details on:

4. Actions taken that impact the factuality and grounding of AI System/LLM outputs

4. System-level prompts that provide natural language instructions to the model specifying guidelines on responding to user-generated queries, to include how a model responds when reliable information is incomplete, contradictory, or subject to individual interpretation

4. The type of outputs restricted via content moderation and safety filters

4. The use of red teaming as a means of continuously assessing the model to protect against incidents of bias in generated output.

4. Training or development, if any, that occurred outside the United States, to include the type of activity and the country in which it occurred.

4. Any modifications or configurations undertaken to comply with any regulation from a government other than the U.S. Federal Government.

1. Model Evaluation Results and Methodologies The Contractor shall provide documentation describing the Evaluation Results of bias evaluations conducted by the Vendor to include the methodology for performing such tests (e.g., testing prompt pairs for politically oriented topics).

The documentation shall also include Benchmark scoring results measuring the model’s bias, helpfulness, honesty, or accuracy when provided with ambiguous versus straightforward questions. (Including any benchmarks comparing performance across multiple languages, where applicable).

1. Description of Enterprise-Level Controls The Contractor shall provide documentation describing the Enterprise Governance tools and controls, such as:

6. Customizable system instructions that are additive to a base model’s system prompts or content generation filters.

6. Product features that require a model to cite sources of its outputs or otherwise provide visibility into the provenance of the model’s outputs.

6. AI System/LLM model evaluation tools that enable comparisons either between a model’s outputs, or across various models.

1. Third Party Modification Disclosure The Contractor shall disclose of any additional controls to modify an AI Model’s/LLM’s output applied by the Contractor if the Contractor is not a direct developer of the LLM (e.g., classifiers, system prompts, fine-tuning, content moderation and filters, etc.)

Deliverable:

A. AI System/LLM Development and Operation Documentation Package

1.13.2 MONITORING, REPORTING, AND CORRECTIVE ACTION

The Contractor shall develop and implement a Compliance Monitoring and Reporting Plan supporting ongoing monitoring processes to evaluate AI outputs for compliance with Trustworthy AI and Unbiased AI principles. This plan shall include the mechanism for authorized users to provide end user feedback to report suspected violations of Truth-Seeking or Ideological Neutrality requirements.

The Contractor shall notify the COR within 10 business days of identifying any material deviation from these principles and shall submit a written Corrective Action Plan describing mitigation steps, responsible parties, and timelines. Any material deviation, corrective action taken, and results shall be detailed in the <Weekly or Monthly> Progress Reports.

Deliverable:

1. Compliance Monitoring and Reporting Plan

1. Corrective Action Plan

1.13.3 AI MODEL UPDATES AND CHANGE DISCLOSURES

The Contractor, in an AI Model/LLM Change Disclosure, shall notify the Government throughout the PoP in advance of any material changes to AI models, including new AI enhancements, features and/or components, controls, retraining, classifiers, system prompts, fine-tuning, content moderation, filters, version replacement, or architectural changes, that could reasonably affect compliance with Trustworthy AI or Unbiased AI principles. Updated documentation shall be provided to VA for VA approval prior to implementation of such changes.

Deliverable:

1. AI Model/LLM Change Disclosure

SOURCE CODE HARMONIZATION AND REUSE IN INFORMATION TECHNOLOGY (SHARE IT Act)

N/A

SECURITY AND PRIVACY REQUIREMENTS

1.14 POSITION/TASK RISK DESIGNATION LEVEL(S)

In accordance with VA Handbook 0710, Personnel Vetting Program, the position sensitivity and the level of background investigation commensurate with the required level of access for the following tasks within the PD are:

Position Sensitivity and Background Investigation Requirements by Service Task/Item Number Service Task / Item Number

The Tasks identified above and the resulting Position Sensitivity and Background Investigation requirements identify, in effect, the Background Investigation requirements for Contractor individuals, based upon the tasks the particular Contractor individual will be working. The submitted Contractor Staff Roster must indicate the required Background Investigation Level for each Contractor individual based upon the tasks the Contractor individual will be working, in accordance with their submitted proposal.

1.15

CONTRACTOR PERSONNEL SECURITY REQUIREMENTS

Contractor Responsibilities:

1. The Contractor shall prescreen all personnel requiring access to the computer systems to ensure they maintain the appropriate Background Investigation, and are able to read, write, speak, and understand the English language.

Within 3 business days after award, the Contractor shall provide a roster of Contractor and Subcontractor employees to the COR to begin their background investigations in accordance with the PAL template artifact. The Contractor Staff Roster shall contain the Contractor’s Full Name, Date of Birth, Place of Birth, individual background investigation level requirement (based upon Section 6.2.1 Tasks), etc. The Contractor shall submit full Social Security Numbers either within the Contractor Staff Roster or under separate cover to the COR. The Contractor Staff Roster shall be updated and provided to VA within 1 day of any changes in employee status, training certification completion status, Background Investigation level status, additions/removal of employees, etc. throughout the Period of Performance. The Contractor Staff Roster shall remain a historical document indicating all past information and the Contractor shall indicate in the Comment field, employees no longer supporting this contract. The preferred method to send the Contractor Staff Roster or Social Security Number is by encrypted e-mail. If unable to send encrypted e-mail, other methods which comply with FIPS 140-2 (or its successor) are to encrypt the file, use a secure fax, or use a traceable mail service. (Note that by September 22, 2026, all FIPS 140-2 certificate validations will be placed on the Historical List. See FIPS Transition Effort Timeline for more details: https://csrc.nist.gov/projects/fips-140-3-transition-effort#schedule)

1. The Contractor should coordinate with the location of the nearest VA fingerprinting office through the COR. Only electronic fingerprints are authorized. The Contractor shall bring their completed Personnel Security Adjudication Center (PSAC) Fingerprint request form with them (see paragraph d.4. below) when getting fingerprints taken.

b. The Contractor shall ensure the following required forms are submitted to the COR within 5 days after contract award:

1) Optional Form 306

2) Self-Certification of Continuous Service

3) VA Form 0710

4) Completed PSAC Fingerprint Request Form The Contractor personnel shall submit all required information related to their background investigations (completion of the investigation documents (SF85, SF85P, or SF 86) utilizing the Defense Counterintelligence and Security Agency (DCSA) National Background Investigation Services (NBIS) Electronic Application (eAPP) (formerly e-QIP) after receiving an email notification from the PSAC.

The Contractor employee shall certify and release the eAPP document, print, and sign the signature pages, and send them encrypted to the COR for electronic submission to the PSAC. These documents shall be submitted to the COR within 3 business days of receipt of the eAPP) notification email. (Note: DCSA is moving towards a “click to sign” process. If click to sign is used, the Contractor employee should notify the COR within 3 business days that documents were signed via eAPP).

1. The Contractor shall be responsible for the actions of all personnel provided to work for VA under this contract. In the event that damages arise from work performed by Contractor provided personnel, under the auspices of this contract, the Contractor shall be responsible for all resources necessary to remedy the incident.

1. A Contractor may be granted unescorted access to VA facilities and/or access to VA Information Technology resources (network and/or protected data) with a favorably adjudicated Special Agreement Check (SAC), completed training delineated in VA Handbook 6500.6 (Appendix C, Section 4), signed “Contractor Rules of Behavior”, and with a valid, operational Personal Identity Verification (PIV) credential for PIV-only logical access to VA’s network. A PIV card credential can be issued once your SAC has been favorably adjudicated and your background investigation has been scheduled by DCSA. However, the Contractor will be responsible for the actions of the Contractor personnel they provide to perform work for VA. The investigative history for Contractor personnel working under this contract must be maintained in the database of DCSA.

1. The Contractor, when notified of an unfavorably adjudicated background investigation on a Contractor employee as determined by the Government, shall withdraw the employee from consideration in working under the contract.

Failure to comply with the Contractor personnel security investigative requirements may result in loss of physical and/or logical access to VA facilities and systems by Contractor and Subcontractor employees and/or termination of the contract for default.

PIV Credential Holders must follow all HSPD-12 policies and procedures as well as use and protect their assigned identity credentials in accordance with VA policies and procedures, displaying their badges at all times, and returning the identity credentials upon termination of their relationship with VA.

Deliverable:

A. Contractor Staff Roster

ADDENDUM B – VA INFORMATION AND INFORMATION SYSTEM SECURITY/ PRIVACY LANGUAGE

NOTE: In the event of a conflict, VA Acquisition Regulation (VAAR) Security Clauses take precedence over the language in this Addendum B.

APPLICABLE SECTIONS TAILORED FROM: VA NOTICE 24-12, 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

GENERAL

This entire section applies to all acquisitions requiring any Information Security and Privacy language. Contractors, contractor personnel, Subcontractors and subcontractor personnel will be subject to the same federal laws, regulations, standards, VA directives and handbooks, as VA personnel regarding information and information system security and privacy.

VA INFORMATION CUSTODIAL LANGUAGE

a. The Government shall receive unlimited rights to data/intellectual property first produced and delivered in the performance of this contract or order (hereinafter “contract”) unless expressly stated otherwise in this contract. This includes all rights to source code and all documentation created in support thereof. The primary clause used to define Government and Contractor data rights is FAR 52.227-14 Rights in Data – General.

b. Information made available to the Contractor by VA for the performance or administration of this contract will be used only for the purposes specified in the service agreement, SOW, PWS, PD, and/or contract. The Contractor shall not use VA information in any other manner without prior written approval from a VA Contracting Officer (CO). The primary clause used to define Government and Contractor data rights is FAR 52.227-14 Rights in Data – General.

c. VA information will not be co-mingled with any other data on the Contractor’s information systems or media storage systems. The Contractor shall ensure compliance with Federal and VA requirements related to data protection, data encryption, physical data segregation, logical data segregation, classification requirements and media sanitization.

d. VA reserves the right to conduct scheduled or unscheduled audits, assessments, or investigations of Contractor Information Technology (IT) resources to ensure information security is compliant with Federal and VA requirements. The Contractor shall provide all necessary access to records (including electronic and documentary materials related to the contracts and subcontracts) and support (including access to Contractor and Subcontractor staff associated with the contract) to VA, VA's Office Inspector General (OIG), and/or Government Accountability Office (GAO) staff during periodic control assessments, audits, or investigations.

e. The Contractor may only use VA information within the terms of the contract and applicable Federal law, regulations, and VA policies. If new Federal information security laws, regulations or VA policies become applicable after execution of the contract, the parties agree to negotiate contract modification and adjustment necessary to implement the new laws, regulations, and/or policies.

f. The Contractor shall not make copies of VA information except as specifically authorized and necessary to perform the terms of the contract. If copies are made for restoration purposes, after the restoration is complete, the copies shall be destroyed in accordance with VA Directive 6500, VA Cybersecurity Program and VA Information Security Knowledge Service.

g. If a Veterans Health Administration (VHA) contract is terminated for default or cause with a business associate, the related local Business Associate Agreement (BAA) shall also be terminated and actions taken in accordance with VHA Directive 1605.05, Business Associate Agreements. If there is an executed national BAA associated with the contract, VA will determine what actions are appropriate and notify the contractor.

h. The Contractor shall store and transmit VA sensitive information in an encrypted form, using VA-approved encryption tools which are, at a minimum, Federal Information Processing Standards (FIPS) 140-2, Security Requirements for Cryptographic Modules (or its successor) validated and in conformance with VA Information Security Knowledge Service requirements. The Contractor shall transmit VA sensitive information using VA approved Transport Layer Security (TLS) configured with FIPS based cipher suites in conformance with National Institute of Standards and Technology (NIST) 800-52, Guidelines for the Selection, Configuration and Use of Transport Layer Security (TLS) Implementations.

i. The Contractor’s firewall and web services security controls, as applicable, shall meet or exceed VA’s minimum requirements.

j. Except for uses and disclosures of VA information authorized by this contract for performance of the contract, the Contractor may use and disclose VA information only in two situations: (i) in response to a qualifying order of a court of competent jurisdiction after notification to VA CO (ii) with written approval from the VA CO. The Contractor shall refer all requests for, demands for production of or inquiries about, VA information and information systems to the VA CO for response.

k. Notwithstanding the provision above, the Contractor 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 medical records pertaining to drug addiction, sickle cell anemia, alcoholism or alcohol abuse or infection with Human Immunodeficiency Virus (HIV). If the Contractor is in receipt of a court order or other requests for the above-mentioned information, the Contractor shall immediately refer such court order or other requests to the VA CO for response.

l. Information made available to the Contractor by VA…