Active Navigation (Brand Name or Equal) Discovery Center TAC Number: VA-27-00000574

DEPARTMENT OF VETERANS AFFAIRS

Office of Information & Technology Financial Service Center

Active Navigation (Brand Name or Equal) Discovery Center

Date: July 15, 2026

VA-27-00000574

Product Description

Version Number: 1.0

Contents

1.0 PRODUCT REQUIREMENTS

The Department of Veterans Affairs (VA) Financial Service Center (FSC) requires Brand Name or Equal Active Navigation to provide an agentless Advanced Electronic File Analysis Solution to index, categorize, and tag documents within 10 terabyte (TB) TB of unstructured repositories. The Advanced Electronic File Analysis Solution (hereafter referred to as “the Solution”) shall discover redundant, obsolete, and trivial data and remediate information at risk of spillage. The Solution must also inventory electronic content holdings in VA File Shares to identify duplicated content and de-duplicate files as appropriate, remediate sensitive content such as personally-identifiable information (PII), protected health information (PHI), agency confidential documents, and other information that should be controlled to minimize risk. The number of repositories will be determined by the electronic file analysis Solution but should not be limited. The file types within the repositories are based on the data owners and include but not limited to common office file types such as xlsx, docx, pptx, pdf, etc.

The Period of Performance shall be a 12-month base period with three (3) 12-month Option Periods for maintenance and support. The Solution shall be server based and its location and control will be managed by the FSC.

Vendor access will be configured using existing cybersecurity methodologies in VA Directive & Handbook.( https://vaww.va.gov/vapubs/search_action.cfm?dType=2)

VA’s requirements are detailed in the table below.

Quantity

Quantity

Quantity

Quantity

ADVANCED ELECTRONIC FILE ANALYSIS SOLUTION SALIENT CHARACTERISTICS

The Solution’s salient characteristics are specified below:

1. Definitions:

a. Electronic File Analysis Solution – electronic file analysis Solution that extracts meaningful metadata universally from all supported file types. This Solution will enable VA to quickly identify and categorize documents by using policy metadata extraction rules.

b. Agentless – Software is not loaded on each workstation/area, rather centrally located.

2. Records Management Standards:

a. Develop rule-based records taxonomies and file plan structures that can be used to discover and auto-categorize files into retention schedules and manage this content in place or migrate it to restructured file shares or other systems.

b. Provide an automated method of monitoring ongoing compliance with information governance policies and periodically updating taxonomies and records metadata.

3. Security and Compliance:

a. Authentication: Users and services must authenticate with SMART Card aware with the ability authenticate with a username/password as a requirement for accountability.

b. Software: All software to be installed/used will be evaluated on and approved by the Department of Veterans Affairs One‐VA Technical Reference Model (One‐VA TRM) approved list and be locally installed behind the VA FSCfirewall to meet VA security requirements (www.va.gov/trm/searchpage.aspx). Contractor must submit names of all software to be used.

c. Accountability: Create an audit log entry that includes the minimum requirements:

1. Date/timestamps for activity

2. Username associated with activity/action

3. Status

4. Starting / stopping services. The VA FSC uses windows integrated authentication, and do not store this information anywhere.

5. Request Type: For tasks such as index processing and deletions, the VA FSC store an edited by and created by value, along with an updated date record

4. Software Support:

a. 24 x 7 x 365 software ticketing

b. Software Updates as released

c. Software Upgrades as released On-site support as needed (within 24 hours)1.1.1 ADVANCED ELECTRONIC FILE ANALYSIS SOLUTION GENERAL REQUIREMENTS The Solution shall:

1. Extract meaningful metadata universally from all supported file types. The Solution shall enable VA to quickly identify and categorize documents by using policy metadata extraction rules.

2. Be Agentless software is not loaded on each workstation/area, rather centrally

3. Adhere to Records Management Standards at a minimum,

a. Develop rule-based records taxonomies and file plan structures that can be used to discover and auto-categorize

b. Place files into retention schedules and manage this content in place or migrate it to restructured file shares or other systems.

c. Provide an automated method of monitoring ongoing compliance with information governance policies and periodically updating taxonomies and records metadata.

4. Be scalable to millions of files per day.

5. Identify documents that are due for disposition based on internal or external policies, tag metadata, and mark-up documents for review, deletion, migration etc.

6. Discretely categorize documents regardless of format

7. Be an agentless Solution that has 3% or less of total index size of total content under management.

1.1.2 ADVANCED ELECTRONIC FILE ANALYSIS SOLUTION TECHNICAL REQUIREMENTS

Theolution has multiple phase requirements: Classification, Metadata creation and Extraction, and auto-classification. Specifically:

a. Classification Requirements:

i. Solution shall classify documents by textual analysis, keywords or layout, and then extract data from unstructured files.

ii. Rules sets may be written to help identify the location of the text to be used for classification and extraction.

iii. Shall pull key information directly from electronic documents fast and accurately.

iv. Shall be able to identify and make sense of a wide variety of documents, regardless of their size, use of symbols, and language.

v. Shall recognize, sort and extract data from unstructured documents.

b. Metadata Extraction Requirements:

i. Metadata extraction rulesets shall be able to be modeled against the extracted metadata to refine logic sets and utilize regular expressions (RegEx) for pattern match and recognition.

ii. All Metadata extraction structures shall be fully customizable in order to refine the categorization/classification rules for document identification.

iii. Work packages shall be exportable to ensure integration with business processes.

iv. Once index values have been identified, the software shall be able to extract data for review later in the validation process.

v. Software shall be able to compare recognized data to data that exists in unstructured environments.

c. Delivery Requirements:

After document repositories have gone through the previous stages, the documents along with its metadata, index information shall be able to be released to any of the following: database, Content Management System, file system, Line of Business Application, archive location, XML file, API with third party applications, or other specified destinations.

1.1.3 ADVANCED ELECTRONIC FILE ANALYSIS SOLUTION SYSTEM REQUIREMENTS

1. Provide Security and Compliance including:

a. Authentication: Users and services shall authenticate with a unique id as a requirement for accountability.

b. Software: All software to be installed/used will be evaluated on and shall pass the Department of Veterans Affairs One‐VA Technical Reference Model (One‐VA TRM) approved list and be locally installed behind the VA FSC firewall to meet VA security requirements (www.va.gov/trm/searchpage.aspx). Contractor shall submit names of all software to be used.

c. Accountability: Create an audit log entry that includes the minimum requirements including:

i. Date/timestamps for activity

ii. Username associated with activity/action

iii. Status

iv. Starting / stopping services. The FSCuses windows integrated authentication, and do not store this information anywhere.

v. Request Type: For tasks such as index processing and deletions, the VA FSC store an edited by and created by value, along with an updated date record

2. Support at a minimum, the following Operating Systems:

a. Windows Platforms

b. Windows Server 2008 64 bit

c. Windows Server 2008 R2

d. Windows Server 2012

e. Windows Server 2012 R2

f. Windows Server 2016

g. Windows Server 2019 (once AGM approved)

h. Windows 10

3. Support at a minimum, the following Databases:

a. Microsoft SQL Server 2012 (X64) - All Versions

b. Microsoft SQL Server 2014

c. Microsoft SQL Server 2016

4. Support at a minimum, the following Browsers:

a. Internet Explorer current version

b. Chrome current version

c. Microsoft Edge current version

SOLUTION MAINTENANCE, LICENSING AND SUPPORT

The Contractor shall provide twelve-months of software maintenance updates and software licensing for the software included in this PD.

The maintenance services shall adhere to the following requirements:

1. Support services shall be available by phone 24 hours per day, 7 days a week, 365 days per year.

2. The contractor shall provide current versions of all software included in this PD throughout the maintenance period.

3. The Contractor shall provide Premium software maintenance and technical support services covering software in this effort to include the following:

a. Direct access (phone and email) to Technical Support team on a 24-hours a day, 7 days a week basis (24/7).

b. Online support, providing access to: Software upgrades and updates to include major releases, point releases, service releases and security releases of applicable software.

c. The ability of the Facility Records Officer to extract reports from the system by department at the user access level.

d. Update the system with the current record control schedules.

e. Provide a user interface dashboard for ease of access by the Facility Records Officer.

f. The dashboard must define deficiencies based upon the current record control schedule. The granularity must be at the directorate and department level.

g. Data Mining support

h. Record Management support

SUPPLEMENTAL REQUIREMENTS

The contractor shall provide the following additional services.

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 Product Description. 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 Peroid of Performance (PoP).

The Project Manager shall serve as the single primary and direct Point of Contact (POC) throughout the PoP. The Project Manager shall conduct calls a minimum of every other week with the VA PA, COR, and PM beginning one week after award and continuing throughout the duration of the effort.

R Deliverable:

A. Contractor Project Management Plan

REPORTING REQUIREMENTS

The Contractor shall provide the COR with Monthly Progress Reports in electronic form in Microsoft Word and Project formats. The report shall include detailed instructions/explanations for each required data element, to ensure that data is accurate and consistent. These reports shall reflect data as of the last day of the preceding Month.

The Monthly Progress Reports shall cover all work completed during the reporting period and work planned for the subsequent reporting period. The report shall also identify any problems that arose and a description of how the problems were resolved. If problems have not been completely resolved, the Contractor shall provide an explanation including their plan and timeframe for resolving the issue. It is expected that the Contractor will keep in communication with VA accordingly so that issues that arise are transparent to both parties to prevent escalation of outstanding issues.

Deliverable:

A. Monthly Progress Report

ADDITIONAL SERVICES

The Contractor shall provide Subject Matter Expertise services in support of this effort in the areas of Data Mining and Records Management. Any contractor discussion, analyses, recommendations, and conclusions shall be documented in the VA Monthly Activity Report.

DATA MINING SERVICES

The contractor shall provide Data Mining Subject Matter expertise for ongoing support of the data analysis and management of the VA digital file environment. The subject matter expert be expert in the proposed Solution and setup, configure and customize the Solution to meet VA requirements. At a minimum the Data Mining Subject Matter expert shall:

a. Be fully trained on all aspects of the Advanced Electronic File Analysis Systems.

b. Provides support related to the installation, capabilities, and use of the Advanced Electronic File Analysis specific to the VA FSC.

c. Provide comprehensive Advanced Electronic File Analysis System orientation to VA FSC focused on system configuration, application installation, application capabilities, and Advanced Electronic File Analysis System use cases.

d. Provide Advanced Electronic File Analysis System administration and user documentation where required in either a digital or paper form that provides information on system configuration, application installation, application capabilities, and application products.

e. Guide and assist in the configuration of the computer system in preparation for the application installation.

f. Install the Advanced Electronic File Analysis System application.

g. Train selected VA on the operation and maintenance of the Advanced Electronic File Analysis System

h. Train selected VA FSC staff on the use and workflow of Advanced Electronic File Analysis System

i. Guide and assist VA FSC staff in selecting candidate sets for use in Advanced Electronic File Analysis System

j. Guide and assist VA FSC staff in producing Advanced Electronic File Analysis System products in either digital or paper form.

Please Note: The Data Mining Subject Matter Expert Will Not directly interact with the data; will not have network access, VPN access will not be authorized; Actual interaction will be performed by agency personnel NOTICE OF THE FEDERAL ACCESSIBILITY LAW AFFECTING ALL INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) PROCUREMENTS (SECTION 508) On January 18, 2017, the Architectural and Transportation Barriers Compliance Board (Access Board) revised and updated, in a single rulemaking, standards for electronic and information technology developed, procured, maintained, or used by Federal agencies covered by Section 508 of the Rehabilitation Act of 1973, as well as our guidelines for telecommunications equipment and customer premises equipment covered by Section 255 of the Communications Act of 1934. 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.

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: https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines. A printed copy of the standards will be supplied upon request.

Federal agencies must comply with the updated Section 508 Standards beginning on January 18, 2018. The Final Rule as published in the Federal Register is available from the Access Board: https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule.

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:

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.

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 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 ENERGY-EFFICIENT 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 13834, “Efficient Federal Operations”, dated May 17, 2018; Executive Order 13221, “Energy-Efficient Standby Power Devices,” dated August 2, 2001; and the Federal Acquisition Regulation (FAR) to provide ENERGY STAR®, Federal Energy Management Program (FEMP) designated, low standby power, and Electronic Product Environmental Assessment Tool (EPEAT) registered products in providing information technology products and/or services.

The Contractor shall ensure that information technology products are procured and/or services are performed with products that meet and/or exceed ENERGY STAR, FEMP designated, low standby power, and EPEAT guidelines. The Contractor shall provide/use products that earn the ENERGY STAR label and meet the ENERGY STAR specifications for energy efficiency. Specifically, the Contractor shall:

1. Provide/use ENERGY STAR products, as specified at www.energystar.gov/products (contains complete product specifications and updated lists of qualifying products).

2. Provide/use the purchasing specifications listed for FEMP designated products at https://www4.eere.energy.gov/femp/requirements/laws_and_requirements/energy_star_and_femp_designated_products_procurement_requirements . The Contractor shall use the low standby power products specified at http://energy.gov/eere/femp/low-standby-power-products.

3. Provide/use EPEAT registered products as specified at www.epeat.net. At a minimum, the Contractor shall acquire EPEAT® Bronze registered products. EPEAT registered products are required to meet the technical specifications of ENERGY STAR, but are not automatically on the ENERGY STAR qualified product lists. The Contractor shall ensure that applicable products are on both the EPEAT Registry and ENERGY STAR Qualified Product Lists. The acquisition of Silver or Gold EPEAT registered products is encouraged over Bronze EPEAT registered products

4. The Contractor shall use these products to the maximum extent possible without jeopardizing the intended end use or detracting from the overall quality delivered to the end user.

The following is a list of information technology products for which ENERGY STAR, FEMP designated, low standby power, and EPEAT registered products are available:

1. Computer Desktops, Laptops, Notebooks, Displays, Monitors, Integrated Desktop Computers, Workstation Desktops, Thin Clients, Disk Drives

2. Imaging Equipment (Printers, Copiers, Multi-Function Devices, Scanners, Fax Machines, Digital Duplicators, Mailing Machines)

3. Televisions, Multimedia Projectors

This list is continually evolving, and as a result is not all-inclusive.

SHIPMENT OF HARDWARE OR EQUIPMENT

Inspection: Destination Acceptance: Destination Free on Board (FOB): Destination Ship To and Mark For:

Primary:

Alternate:

Name:

Name:

Address:

Address:

Voice:

Voice:

Email:

Email:

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 to ensure sites have adequate storage space.

All shipments, either single or multiple container deliveries, shall bear the VA IFCAP Purchase Order number on external shipping labels and associated manifests or packing lists. In the case of multiple container deliveries, a statement readable near the VA IFCAP PO 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 #: ____TBD________ (e.g., 166-E11234 (the IFCAP PO number is located in block #20 of the SF 1449)) Project Description: (e.g. Tier I Lifecycle Refresh)

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

GENERAL REQUIREMENTS

VA TECHNICAL REFERENCE MODEL

The Contractor shall support the VA enterprise management framework. In association with the framework, the Contractor shall comply with OI&T Technical Reference Model (VA TRM). The VA TRM is one component within the overall Enterprise Architecture (EA) that establishes a common vocabulary and structure for describing the information technology used to develop, operate, and maintain enterprise applications. Moreover, the VA TRM, which includes the Standards Profile and Product List, serves as a technology roadmap and tool for supporting OI&T. Architecture & Engineering Services (AES) has overall responsibility for the VA TRM.

It is the responsibility of the contractor that their product is VA Technical Reference Model (TRM) approved.

POSITION/TASK RISK DESIGNATION LEVEL(S)

In accordance with VA Handbook 0710, Personnel Security and Suitability Program, the position sensitivity and the level of background investigation commensurate with the required level of access for the following tasks within the Product Description (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.

POINTS OF CONTACT

VA Program Manager:

Name:

Address:

Voice:

Email:

Invoice Representative:

Name:

Address:

Voice:

Email:

Contracting Specialist:

Name:

Voice:

Email:

Contract Officer:

Name:

Voice:

Email:

Facility Area Manager Name:

Voice:

Email:

INFORMATION SECURITY CONSIDERATIONS:

The Assessment and Authorization (A&A) requirements do not apply and a Security Accreditation Package is not required

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

GENERAL

Contractors, Contractor personnel, Subcontractors, and Subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security.

ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS

a. A Contractor/Subcontractor shall request logical (technical) or physical access to VA information and VA information systems for their employees, Subcontractors, and affiliates only to the extent necessary to perform the services specified in the contract, agreement, or task order.

b. All Contractors, Subcontractors, and third-party servicers and associates working with VA information are subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for Contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations, Security, and Preparedness is responsible for these policies and procedures.

c. Contract personnel who require access to national security programs must have a valid security clearance. National Industrial Security Program (NISP) was established by Executive Order 12829 to ensure that cleared U.S. defense industry contract personnel safeguard the classified information in their possession while performing work on contracts, programs, bids, or research and development efforts. The Department of Veterans Affairs does not have a Memorandum of Agreement with Defense Security Service (DSS). Verification of a Security Clearance must be processed through the Special Security Officer located in the Planning and National Security Service within the Office of Operations, Security, and Preparedness.

d. Custom software development and outsourced operations must be located in the U.S. to the maximum extent practical. If such services are proposed to be performed abroad and are not disallowed by other VA policy or mandates (e.g. Business Associate Agreement, Section 3G), the Contractor/Subcontractor must state where all non-U.S. services are provided and detail a security plan, deemed to be acceptable by VA, specifically to address mitigation of the resulting problems of communication, control, data protection, and so forth. Location within the U.S. may be an evaluation factor.

e. The Contractor or Subcontractor must notify the CO immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the Contractor or Subcontractor’s employ. The CO must also be notified immediately by the Contractor or Subcontractor prior to an unfriendly termination.

VA INFORMATION CUSTODIAL LANGUAGE

1. Information made available to the Contractor or Subcontractor by VA for the performance or administration of this contract or information developed by the Contractor/Subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of VA. This clause expressly limits the Contractor/Subcontractor's rights to use data as described in Rights in Data - General, FAR 52.227-14(d) (1).

2. VA information should not be co-mingled, if possible, with any other data on the Contractors/Subcontractor’s information systems or media storage systems in order to ensure VA requirements related to data protection and media sanitization can be met. If co-mingling must be allowed to meet the requirements of the business need, the Contractor must ensure that VA information is returned to VA or destroyed in accordance with VA’s sanitization requirements. VA reserves the right to conduct on site inspections of Contractor and Subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures are in compliance with VA directive requirements.

3. Prior to termination or completion of this contract, Contractor/Subcontractor must not destroy information received from VA, or gathered/created by the Contractor in the course of performing this contract without prior written approval by VA. Any data destruction done on behalf of VA by a Contractor/Subcontractor must be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management and its Handbook 6300.1 Records Management Procedures, applicable VA Records Control Schedules, and VA Handbook 6500.1, Electronic Media Sanitization. Self-certification by the Contractor that the data destruction requirements above have been met must be sent to the VA CO within 30 days of termination of the contract.

4. The Contractor/Subcontractor must receive, gather, store, back up, maintain, use, disclose and dispose of VA information only in compliance with the terms of the contract and applicable Federal and VA information confidentiality and security laws, regulations and policies. If Federal or VA information confidentiality and security laws, regulations and policies become applicable to VA information or information systems after execution of the contract, or if NIST issues or updates applicable FIPS or Special Publications (SP) after execution of this contract, the parties agree to negotiate in good faith to implement the information confidentiality and security laws, regulations and policies in this contract.

5. The Contractor/Subcontractor shall not make copies of VA information except as authorized and necessary to perform the terms of the agreement or to preserve electronic information stored on Contractor/Subcontractor electronic storage media for restoration in case any electronic equipment or data used by the Contractor/Subcontractor needs to be restored to an operating state. If copies are made for restoration purposes, after the restoration is complete, the copies must be appropriately destroyed.

6. If VA determines that the Contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be sufficient grounds for VA to withhold payment to the Contractor or third party or terminate the contract for default or terminate for cause under Federal Acquisition Regulation (FAR) part 12.

7. If a VHA contract is terminated for cause, the associated Business Associate Agreement (BAA) must also be terminated and appropriate actions taken in accordance with VHA Handbook 1600.05, Business Associate Agreements. Absent an agreement to use or disclose protected health information, there is no business associate relationship.

8. The Contractor/Subcontractor must store, transport, or transmit VA sensitive information in an encrypted form, using VA-approved encryption tools that are, at a minimum, FIPS 140-2 validated.

9. The Contractor/Subcontractor’s firewall and Web services security controls, if applicable, shall meet or exceed VA minimum requirements. VA Configuration Guidelines are available upon request.

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

11. Notwithstanding the provision above, the Contractor/Subcontractor shall not release VA records protected by Title 38 U.S.C. 5705, confidentiality of medical quality assurance records and/or Title 38 U.S.C. 7332, confidentiality of certain health records pertaining to drug addiction, sickle cell anemia, alcoholism or alcohol abuse, or infection with human immunodeficiency virus. If the Contractor/Subcontractor is in receipt of a court order or other requests for the above mentioned information, that Contractor/Subcontractor shall immediately refer such court orders or other requests to the VA CO for response.

12. For service that involves the storage, generating, transmitting, or exchanging of VA sensitive information but does not require Assessment and Authorization (A&A) or a Memorandum of Understanding-Interconnection Security Agreement (MOU-ISA) for system interconnection, the Contractor/Subcontractor must complete a Contractor Security Control Assessment (CSCA) on a yearly basis and provide it to the COR.

INFORMATION SYSTEM DESIGN AND DEVELOPMENT

1. Information systems that are designed or developed for or on behalf of VA at non-VA facilities shall comply with all VA directives developed in accordance with FISMA, HIPAA, NIST, and related VA security and privacy control requirements for Federal information systems. This includes standards for the protection of electronic PHI, outlined in 45 C.F.R. Part 164, Subpart C, information and system security categorization level designations in accordance with FIPS 199 and FIPS 200 with implementation of all baseline security controls commensurate with the FIPS 199 system security categorization (reference VA Handbook 6500, Risk Management Framework for VA Information Systems – Tier 3: VA Information Security Program, and the TIC Reference Architecture). During the development cycle a Privacy Impact Assessment (PIA) must be completed, provided to the COR, and approved by the VA Privacy Service in accordance with Directive 6508, Implementation of Privacy Threshold Analysis and Privacy Impact Assessment.

2. The Contractor/Subcontractor shall certify to the COR that applications are fully functional and operate correctly as intended on systems using the VA Federal Desktop Core Configuration (FDCC), and the common security configuration guidelines provided by NIST or VA. This includes Internet Explorer 11 configured to operate on Windows 7 and future versions, as required.

3. The standard installation, operation, maintenance, updating, and patching of software shall not alter the configuration settings from the VA approved and FDCC configuration. Information technology staff must also use the Windows Installer Service for installation to the default “program files” directory and silently install and uninstall.

4. Applications designed for normal end users shall run in the standard user context without elevated system administration privileges.

5. The security controls must be designed, developed, approved by VA, and implemented in accordance with the provisions of VA security system development life cycle as outlined in NIST Special Publication 800-37, Guide for Applying the Risk Management Framework to Federal Information Systems, VA Handbook 6500, Risk Management Framework for VA Information Systems – Tier 3: VA Information Security Program and VA Handbook 6500.5, Incorporating Security and Privacy in System Development Lifecycle.

6. The Contractor/Subcontractor is required to design, develop, or operate a System of Records Notice (SOR) on individuals to accomplish an agency function subject to the Privacy Act of 1974, (as amended), Public Law 93-579, December 31, 1974 (5 U.S.C. 552a) and applicable agency regulations. Violation of the Privacy Act may involve the imposition of criminal and civil penalties.

7. The Contractor/Subcontractor agrees to:

a. Comply with the Privacy Act of 1974 (the Act) and the agency rules and regulations issued under the Act in the design, development, or operation of any system of records on individuals to accomplish an agency function when the contract specifically identifies:

i. The Systems of Records (SOR); and

ii. The design, development, or operation work that the Contractor/Subcontractor is to perform;

b. Include the Privacy Act notification contained in this contract in every solicitation and resulting subcontract and in every subcontract awarded without a solicitation, when the work statement in the proposed subcontract requires the redesign, development, or operation of a SOR on individuals that is subject to the Privacy Act; and

c. Include this Privacy Act clause, including this subparagraph (c), in all subcontracts awarded under this contract which requires the design, development, or operation of such a SOR.

8. In the event of violations of the Act, a civil action may be brought against the agency involved when the violation concerns the design, development, or operation of a SOR on individuals to accomplish an agency function, and criminal penalties may be imposed upon the officers or employees of the agency when the violation concerns the operation of a SOR on individuals to accomplish an agency function. For purposes of the Act, when the contract is for the operation of a SOR on individuals to accomplish an agency function, the Contractor/Subcontractor is considered to be an employee of the agency.

a. “Operation of a System of Records” means performance of any of the activities associated with maintaining the SOR, including the collection, use, maintenance, and dissemination of records.

b. “Record” means any item, collection, or grouping of information about an individual that is maintained by an agency, including, but not limited to, education, financial transactions, medical history, and criminal or employment history and contains the person’s name, or identifying number, symbol, or any other identifying particular assigned to the individual, such as a fingerprint or voiceprint, or a photograph.

c. “System of Records” means a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some identifying number, symbol, or other identifying particular assigned to the individual.

9. The vendor shall ensure the security of all procured or developed systems and technologies, including their subcomponents (hereinafter referred to as “Systems”), throughout the life of this contract and any extension, warranty, or maintenance periods. This includes, but is not limited to workarounds, patches, hot fixes, upgrades, and any physical components (hereafter referred to as Security Fixes) which may be necessary to fix all security vulnerabilities published or known to the vendor anywhere in the Systems, including Operating Systems and firmware. The vendor shall ensure that Security Fixes shall not negatively impact the Systems.

10. The vendor shall notify VA within 24 hours of the discovery or disclosure of successful exploits of the vulnerability which can compromise the security of the Systems (including the confidentiality or integrity of its data and operations, or the availability of the system). Such issues shall be remediated as quickly as is practical, based upon the severity of the incident.

11. When the Security Fixes involve installing third party patches (such as Microsoft OS patches or Adobe Acrobat), the vendor will provide written notice to VA that the patch has been validated as not affecting the Systems within 10 working days. When the vendor is responsible for operations or maintenance of the Systems, they shall apply the Security Fixes based upon the requirements identified within the contract.

12. All other vulnerabilities shall be remediated as specified in this paragraph in a timely manner based on risk, but within 60 days of discovery or disclosure. Exceptions to this paragraph (e.g. for the convenience of VA) shall only be granted with approval of the CO and the VA Assistant Secretary for Office of Information and Technology.

INFORMATION SYSTEM HOSTING, OPERATION, MAINTENANCE, OR USE

a. For information systems that are hosted, operated, maintained, or used on behalf of VA at non-VA facilities, Contractors/Subcontractors are fully responsible and accountable for ensuring compliance with all HIPAA, Privacy Act, FISMA, NIST, FIPS, and VA security and privacy directives and handbooks. This includes conducting compliant risk assessments, routine vulnerability scanning, system patching and change management procedures, and the completion of an acceptable contingency plan for each system. The Contractor’s security control procedures must be equivalent, to those procedures used to secure VA systems. A Privacy Impact Assessment (PIA) must also be provided to the COR and approved by VA Privacy Service prior to operational approval. All external Internet connections to VA network involving VA information must be in accordance with the TIC Reference Architecture and reviewed and approved by VA prior to implementation. For Cloud Services hosting, the Contractor shall also ensure compliance with the Federal Risk and Authorization Management Program (FedRAMP).

b. Adequate security controls for collecting, processing, transmitting, and storing of Personally Identifiable Information (PII), as determined by the VA Privacy Service, must be in place, tested, and approved by VA prior to hosting, operation, maintenance, or use of the information system, or systems by or on behalf of VA. These security controls are to be assessed and stated within the PIA and if these controls are determined not to be in place, or inadequate, a Plan of Action and Milestones (POA&M) must be submitted and approved prior to the collection of PII.

c. Outsourcing (Contractor facility, Contractor equipment or Contractor staff) of systems or network operations, telecommunications services, or other managed services requires A&A of the Contractor’s systems in accordance with VA Handbook 6500.3, Assessment, Authorization and Continuous Monitoring of VA Information Systems and/or the VA OCS Certification Program Office. Government-owned (Government facility or Government equipment) Contractor-operated systems, third party or business partner networks require memorandums of understanding and interconnection security agreements (MOU-ISA) which detail what data types are shared, who has access, and the appropriate level of security controls for all systems connected to VA networks.

d. The Contractor/Subcontractor’s system must adhere to all FISMA, FIPS, and NIST standards related to the annual FISMA security controls assessment and review and update the PIA. Any deficiencies noted during this assessment must be provided to the VA CO and the ISO for entry into the VA POA&M management process. The Contractor/Subcontractor must use the VA POA&M process to document planned remedial actions to address any deficiencies in information security policies, procedures, and practices, and the completion of those activities. Security deficiencies must be corrected within the timeframes approved by the Government. Contractor/Subcontractor procedures are subject to periodic, unannounced assessments by VA officials, including the VA Office of Inspector General. The physical security aspects associated with Contractor/Subcontractor activities must also be subject to such assessments. If major changes to the system occur that may affect the privacy or security of the data or the system, the A&A of the system may need to be reviewed, retested and re-authorized per VA Handbook 6500.3. This may require reviewing and updating all of the documentation (PIA, System Security Plan, and Contingency Plan). The Certification Program Office can provide guidance on whether a new A&A would be necessary.

e. The Contractor/Subcontractor must conduct an annual self assessment on all systems and outsourced services as required. Both hard copy and electronic copies of the assessment must be provided to the COR. The Government reserves the right to conduct such an assessment using Government personnel or another Contractor/Subcontractor. The Contractor/Subcontractor must take appropriate and timely action (this can be specified in the contract) to correct or mitigate any weaknesses discovered during such testing, generally at no additional cost.

f. VA prohibits the installation and use of personally-owned or Contractor/Subcontractor owned equipment or software on the VA network. If non-VA owned equipment must be used to fulfill the requirements of a contract, it must be stated in the service agreement, SOW or contract. All of the security controls required for Government furnished equipment (GFE) must be utilized in approved other equipment (OE) and must be funded by the owner of the equipment. All remote systems must be equipped with, and use, a VA-approved antivirus (AV) software and a personal (host-based or enclave based) firewall that is configured with a VA approved configuration. Software must be kept current, including all critical updates and patches. Owners of approved OE are responsible for providing and maintaining the anti-viral software and the firewall on the non-VA owned OE.

g. All electronic storage media used on non-VA leased or non-VA owned IT equipment that is used to store, process, or access VA information must be handled in adherence with VA Handbook 6500.1, Electronic Media Sanitization upon: (i) completion or termination of the contract or (ii) disposal or return of the IT equipment by the Contractor/Subcontractor or any person acting on behalf of the Contractor/Subcontractor, whichever is earlier. Media (hard drives, optical disks, CDs, back-up tapes, etc.) used by the Contractors/Subcontractors that contain VA information must be returned to VA for sanitization or destruction or the Contractor/Subcontractor must self-certify that the media has been disposed of per 6500.1 requirements. This must be completed within 30 days of termination of the contract.

h. Bio-Medical devices and other equipment or systems containing media (hard drives, optical disks, etc.) with VA sensitive information must not be returned to the vendor at the end of lease, for trade-in, or other purposes. The options are:

1) Vendor must accept the system without the drive;

2) VA’s initial medical device purchase includes a spare drive which must be installed in place of the original drive at time of turn-in; or

3) VA must reimburse the company for media at a reasonable open market replacement cost at time of purchase.

4) Due to the highly specialized and sometimes proprietary hardware and software associated with medical equipment/systems, if it is not possible for VA to retain the hard drive, then;

a) The equipment vendor must have an existing BAA if the device being traded in has sensitive information stored on it and hard drive(s) from the system are being returned physically intact; and

b) Any fixed hard drive on the device must be non-destructively sanitized to the greatest extent possible without negatively impacting system operation.