36C10X20Q0001-001.docx

Title of Project: The Department of Veterans Affairs’ (VA), Office of Resolution Management (ORM) Requirement for Reader Assistant Support Services.

1) Background: The Department of Veterans Affairs (VA) ORM employs one (1) individual that is visually impaired and special accommodations services are required. Under Section 501 of the Rehabilitation Act of 1973, an employer is required to make a reasonable accommodation to the disability of a qualified applicant or employee if it would not impose an "undue hardship" on the operation of the employer's business. Undue hardship is defined as an action requiring significant difficulty or expense when considered in light of factors such as an employer's size, financial resources, and the nature and structure of the operation. The ORM Equal Employment Opportunity employee requested reasonable accommodations in the form of a Reader Assistant on a routine basis to perform clerical duties, which includes reviewing, reading or describing various documents, charts and graphs, organizing files, faxing and scanning documents for one (1) visually impaired employee. In addition, the Reader Assistant will accompany the ORM employee to meetings, trainings, conferences, and other job-related functions. Additionally, the Reader Assistant will be required to assist the ORM employee while on travel in guiding the VA employee to and from Government activities.

2) Scope of Work: ORM seeks to procure contractor Reader Assistant Support services to serve as a reader for one (1) visually impaired employee and perform associated clerical duties. The Reader assistant will perform a variety of administrative functions related activities, including, but not limited to deciphering handwritten/printed materials, e-mails, graphs, charts, excel spreadsheets, TIF and JPG files, and memos for the visually impaired employee who currently utilizes JAWS software that has limited capabilities. Additional duties shall also include scheduling appointments, maintaining electronic files, providing information to callers, operating office equipment, making copies, answering calls, coding files, and preparing reports. The support contractor personnel shall be able to explain and describe for the visually impaired employee various visual aids, such as complex graphs, charts, pictures, and illustrations. Assistance for the visually impaired employee shall also include sighted mobility assistance to locate unfamiliar people and places/locations when on training or conference travel. The support contractor personnel shall also be required to provide the visually impaired employee with instruction and assistance in navigating and editing electronic documents and applications. The contractor support personnel shall use discretion in dealing with sensitive information in accordance with Non-Disclosure Agreements, particularly when preparing reports, summaries, replies, and reviewing regulations in response to Government contracts.

3) Performance Period: The requirement described in this SOW is written by VA for a base period with four (4) one (1) Year options, subject to the availability of appropriated funds.

· Base Period: November 1, 2019, through September 30, 2020

· Option Year 1: October 1, 2020, through September 30, 2021

· Option Year 2: October 1, 2021 through September 30, 2022

· Option Year 3: October 1, 2022 through September 30, 2023

· Option Year 4: October 1, 2023 through September 30, 2024

4) Place of Performance: The place of performance will be at the Department of Veterans Affairs’, Office of Resolution Management, located at 1575 I Street, NW., 10th Floor, Washington, DC 20005, and other locations within the Washington, DC, commuting area if needed during the course of business operations to accompany the visually impaired employee to other official Government travel locations as authorized for business to attend seminars, conferences, workshops, training classes and other Government-related functions.

B. Type of Contract: This will be a Firm Fixed Price contract.

C. General Requirements:

The Reader Assistant tasks includes, but is not limited to, reading documents, assisting with computer navigation, copying/faxing/mailing documents, describing visual aids, and providing mobility assistance. The Reader Assistant shall perform administrative, clerical, and analytical duties, as outlined in this Statement of Work. The candidate is expected to have demonstrated experience in office management practices and administrative support processes; and the ability to use computer software programs such as MS Word, PowerPoint, and Excel. A skilled individual with computer navigation, interpretation, and analytical capabilities, as well as previous experience in working with the visually or hearing impaired, and/or a person with disabilities.

D. Specific Mandatory Tasks and Associate Deliverables:

Provides reading services.

On a daily basis Approximately 20% of total time.

Provides administrative support.

On a daily basis Approximately 25% of total time.

Explains visual aids.

On a daily basis Approximately 20% of total time.

Provides instruction and assistance.

On a daily basis Approximately 25% of total time.

Provides mobility assistance.

On a daily basis Approximately 10% of total time.

During prescribed days and hours of work, the Reader Assistant will be responsible for escorting and remaining with the visually impaired employee in the event of a fire, emergency drills, earthquake, and other disastrous acts or when the office building must be evacuated and accompany the ORM employee to the proper safety evacuation area.

E. Key Personnel Qualifications, Experience and Other Requirements: Qualifications for this contract include:

Education/Experience –

At a minimum, an associate college degree and two (2) years of work experience in a similar field, or high school diploma (or equivalent) and four (4) years of experience in a similar field.

Work experience is defined in overseeing, performing, and providing administrative and clerical functions, or similar field is required. Contractor’s key personnel must demonstrate experience in office management practices and administrative support processes. In addition, contractor’s key personnel must be skilled in computer navigation, interpretation, analysis, and previous experience in working with visually or hearing-impaired individuals, or persons with disabilities. The Reader Assistant will be provided Equal Employment Opportunity training via Veterans Affairs Talent Management System at no cost to the contractor.

F. Substitution of Personnel and Compliance with Agency Policy:

The personnel identified in the contractor’s quotation shall be considered key personnel essential for successful completion of the work performed under this contract. The contractor agrees that such personnel shall not be removed, diverted, or replaced from the work without prior written approval from the Contracting Officer (CO).

During the first ninety (90) days of performance under this contract, the contractor shall make no substitutions of key personnel unless the substitution is necessitated by illness, death, or termination of employment. The contractor shall notify the CO, in writing, within three (3) business days after the occurrence of any of these events and provide the information required by the paragraph below. When it becomes necessary at any time to replace key personnel due to illness, death, termination of employment, or for performance problems, the contractor shall provide an acceptable substitution to begin work within three (3) business days.

All requests for substitutions in personnel must be submitted to the CO three (3) business days prior to making any changes in key personnel. The request shall be in writing, providing a detailed explanation of the circumstances necessitating the proposed substitution, complete resumes for the proposed substitute(s), and any additional information requested by the CO. Proposed substitutions shall have abilities and qualifications equal to or greater than the key personnel replaced.

Contractor employees are subject to immediate removal from performance on this contract if the contractor support personnel are involved in a violation of the law, VA security, confidentially requirements, and/or other disciplinary reasons. The contractor must inform ORM when personnel are removed from this contract for any reason.

Contractor personnel shall comply with the agency and office dress code. Contractor shall always be easily recognized as a contractor employee by wearing a Security Identification Badge while on any Government premises. When contractor personnel attend meetings, answer phones, and work in other situations where their status is not obvious to third parties they must identify themselves as such to avoid creating the impression that they are a VA Government employee.

G. Schedule for Deliverables:

The contractor shall provide a Reader Assistant for the duration of the contract from approximately 9:30 AM to 4:00 PM Eastern Daylight Time (EDT) on Monday through Friday. Work shall not take place on Federal holidays or weekends unless directed by the CO. The contractor will be notified within ten (10) business days prior to any changes in work hours of the visually impaired employee’s scheduled days and times of work as listed.

The Government will provide the contractor personnel with advance notice; no less than two (2) hours prior to the start of the contractor personnel’s tour if the contractor is not needed to report for work and/or services. When the ORM employee is at work, the contractor is responsible for providing a Reader Assistant on the days and times noted above without interruption. Due to alternate work schedule, every other Friday of the month, the ORM employee will not be available. The work schedule of the ORM employee will be provided to the contractor.

The contractor personnel’s work days and hours are subject to change in the event of travel and/or training is required. The Government will provide the contractor with at least ten (10) business days’ notice of any travel required.

The ten (10) Federal holidays set by law (5 U.S.C. §6103) that are followed by VA:

H. Changes to the Statement of Work:

Any changes to this Statement of Work (SOW) shall be authorized and approved only through written correspondence from the CO. Change orders will be monitored by the CO. Costs incurred by the contractor through the actions of parties other than the CO shall be borne by the contractor.

I. Reporting Requirements:

The contractor shall provide monthly written progress reports. These shall be sent electronically to the COR on the 5th day of each month.

The progress report shall cover all work completed during the preceding month. This report shall also identify any problem(s) that arose, along with a statement explaining how the problems were resolved. This report shall also identify any problem(s) that have arisen but have not yet been resolved.

J. Travel:

Limited travel is expected to accompany the visually impaired employee to training and other work-related functions as needed, approximately three (3) trips annually, no longer than one (1) week in duration each.

Travel must be authorized in writing by the CO via the COR five (5) business days prior to travel departure date.

Travel and per diem shall be reimbursed in accordance with Federal Travel Regulations (FTR). The website for FTR can be found at: http://www.gsa.gov/portal/content/104790 Travel to work site location and from home shall not be permitted for reimbursement.

K. Government Furnished Equipment:

The VA will provide the on-site space, office equipment, including laptop/desktop, supplies, and phone for the Reader Assistant contractor support personnel.

L. Confidentiality and Non-disclosure:

The preliminary and final deliverables and all associated working papers, application source code, and other materials deemed relevant by the VA, which has been generated by the contractor personnel in performance of this contract are the exclusive property of the U.S. Government and shall be submitted to the CO at the conclusion of this contract.

The CO will be the sole authorized official to release verbally or in writing any data, draft or final deliverables, or any other written or printed materials pertaining to this contract. No information shall be released by the contractor. Any request for information relating to this contract presented to the contractor shall be submitted to the CO for response. No printed or electronic documentation related to this project shall be publicized without prior written approval from the CO.

M. Contractor Personnel Security Requirements:

All contractor employees who require access to the Department of Veterans Affairs’ computer systems shall be the subject of a background investigation and must receive a favorable adjudication from the VA’s Office of Security and Law Enforcement prior to contract performance.

This requirement is applicable to subcontractor personnel requiring the same access.

1. Position Sensitivity – The position sensitivity has been designated as low risk.

2. Background Investigation – The level of background investigation commensurate with the required level of access is National Agency Check with Written Inquiries.

3. Contractor Responsibilities:

a. The contractor shall prescreen all personnel requiring access to the computer systems to ensure they maintain a U.S. citizenship, and are able to read, write, speak and understand the English language.

b. The contractor shall submit or have their employees submit the required forms (SF 86 or SF 85P, SF 85P-S, FD 258, Contractor Fingerprint Chart, VA Form 0710, Authority for Release of Information Form, and Optional Forms 306 and 612) to the VA Office of Security and Law Enforcement within 30 days of receipt for processing.

c. The contractor, when notified of an unfavorable determination by the Government, shall withdraw the affected employee from working under the contract.

d. Failure to comply with contractor personnel security requirements may result in termination of the contract for default.

e. The contractor will provide a qualified alternate that possess proper security credentials for access to Government IT system, in the event the primary employee is unable or unavailable to work the normal scheduled hours.

N. Government Responsibilities:

a. The VA Office of Security and Law Enforcement will provide the necessary forms to the contractor, or to the contractor’s employees, after receiving a list of names and addresses.

b. Upon receipt, the VA Office of Security and Law Enforcement will review completed forms for accuracy and forward the forms to the Office of Personnel Management (OPM) to conduct background investigations.

c. The VA Office of Security and Law Enforcement will notify the CO, and contractor, of adjudication results received from OPM.

d. Upon being notified about a favorable determination, the CO may issue a notice to proceed to the contractor.

O. VA Internet and Intranet Standards:

The contractor personnel shall comply with the Department of Veterans Affairs (VA) Directive 6102 and VA Handbook 6102 (Internet/Intranet Services). VA Directive 6102 sets forth policies and responsibilities for the planning, design, maintenance support, and any other functions related to the administration of a VA Internet/Intranet Service Site or related service (hereinafter referred to as the Internet). This directive applies to all organizational elements in the department. This policy applies to all individuals designing and /or maintaining VA Internet Service Sites; including but not limited to, full-time and part-time employees, contractor personnel, interns, and volunteers. This policy applies to all VA Internet/Intranet domains and servers that utilize VA resources. This includes, but is not limited to, va.gov and other extensions such as, .com, .edu, .mil, .net, and .org, as well as personal Internet service pages managed from individual workstations. VA Handbook 6102 establishes department-wide procedures for managing, maintaining, establishing, and presenting VA Internet/Intranet Service Sites or related services. The handbook implements the policies contained in VA Directive 6102, Internet/Intranet Services. This includes, but is not limited to, File Transfer Protocol (FTP), Hypertext Markup Language (html), Simple Mail Transfer Protocol (SMTP), web pages, Active Server Pages (ASP), email forums, and list servers.

VA Directives 6102 and VA Handbook 6102 are available at: http://www.research.va.gov/pride/policy/#directives

P. Contractor Systems Security:

The contractor shall ensure adequate LAN/internet, data, information and system security in accordance with VA standard operation procedures and Federal standards, laws, and regulations. All Government data shall be protected behind an approved firewall. Any security violations or attempted violations shall be reported to the COR immediately upon detection. The contractor shall adhere to applicable VA policies and procedures governing information security.

SECURITY

1. GENERAL

Contractors, contractor personnel, subcontractors, and subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security.

2. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS

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

b. All contractors, subcontractors, and third-party servicers and associates working with VA information 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. The contractor or subcontractor must notify the Contracting Officer immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the contractor or subcontractor’s employ. The Contracting Officer must also be notified immediately by the contractor or subcontractor prior to an unfriendly termination.

3. VA INFORMATION CUSTODIAL LANGUAGE

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

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

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

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

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

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

g. If a VHA contract is terminated for cause, the associated BAA must also be terminated and appropriate actions taken in accordance with VHA Handbook 1600.01, Business Associate Agreements. Absent an agreement to use or disclose protected health information, there is no business associate relationship.

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

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

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

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

l. For service that involves the storage, generating, transmitting, or exchanging of VA sensitive information but does not require C&A or an MOU-ISA for system interconnection, the contractor/subcontractor must complete a Contractor Security Control Assessment (CSCA) on a yearly basis and provide it to the COTR.

4. INFORMATION SYSTEM HOSTING, OPERATION, MAINTENANCE, OR USE

a. VA prohibits the installation and use of personally-owned or contractor/subcontractor owned equipment or software on VA’s 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.

5. SECURITY INCIDENT INVESTIGATION

a. The term “security incident” means an event that has, or could have, resulted in unauthorized access to, loss or damage to VA assets, or sensitive information, or an action that breaches VA security procedures. The contractor/subcontractor shall immediately notify the COTR and simultaneously, the designated ISO and Privacy Officer for the contract of any known or suspected security/privacy incidents, or any unauthorized disclosure of sensitive information, including that contained in system(s) to which the contractor/subcontractor has access.

b. To the extent known by the contractor/subcontractor, the contractor/subcontractor’s notice to VA shall identify the information involved, the circumstances surrounding the incident (including to whom, how, when, and where the VA information or assets were placed at risk or compromised), and any other information that the contractor/ subcontractor considers relevant.

c. With respect to unsecured protected health information, the business associate is deemed to have discovered a data breach when the business associate knew or should have known of a breach of such information. Upon discovery, the business associate must notify the covered entity of the breach. Notifications need to be made in accordance with the executed business associate agreement.

d. In instances of theft or break-in or other criminal activity, the contractor/subcontractor must concurrently report the incident to the appropriate law enforcement entity (or entities) of jurisdiction, including the VA OIG and Security and Law Enforcement. The contractor, its employees, and its subcontractors and their employees shall cooperate with VA and any law enforcement authority responsible for the investigation and prosecution of any possible criminal law violation(s) associated with any incident. The contractor/subcontractor shall cooperate with VA in any civil litigation to recover VA information, obtain monetary or other compensation from a third party for damages arising from any incident, or obtain injunctive relief against any third party arising from, or related to, the incident.

6. LIQUIDATED DAMAGES FOR DATA BREACH

a. Consistent with the requirements of 38 U.S.C. §5725, a contract may require access to sensitive personal information. If so, the contractor is liable to VA for liquidated damages in the event of a data breach or privacy incident involving any SPI the contractor/subcontractor processes or maintains under this contract.

b. The contractor/subcontractor shall provide notice to VA of a “security incident” as set forth in the Security Incident Investigation section above. Upon such notification, VA must secure from a non-Department entity or the VA Office of Inspector General an independent risk analysis of the data breach to determine the level of risk associated with the data breach for the potential misuse of any sensitive personal information involved in the data breach. The term 'data breach' means the loss, theft, or other unauthorized access, or any access other than that incidental to the scope of employment, to data containing sensitive personal information, in electronic or printed form, that results in the potential compromise of the confidentiality or integrity of the data. Contractor shall fully cooperate with the entity performing the risk analysis. Failure to cooperate may be deemed a material breach and grounds for contract termination.

c. Each risk analysis shall address all relevant information concerning the data breach, including the following:

(1) Nature of the event (loss, theft, unauthorized access);

(2) Description of the event, including:

(a) Date of occurrence;

(b) Data elements involved, including any PII, such as full name, social security number, date of birth, home address, account number, disability code;

(3) Number of individuals affected or potentially affected;

(4) Names of individuals or groups affected or potentially affected;

(5) Ease of logical data access to the lost, stolen or improperly accessed data in light of the degree of protection for the data, e.g., unencrypted, plain text;

(6) Amount of time the data has been out of VA control;

(7) The likelihood that the sensitive personal information will or has been compromised (made accessible to and usable by unauthorized persons);

(8) Known misuses of data containing sensitive personal information, if any;

(9) Assessment of the potential harm to the affected individuals;

(10) Data breach analysis as outlined in 6500.2 Handbook, Management of Security and Privacy Incidents, as appropriate; and

(11) Whether credit protection services may assist record subjects in avoiding or mitigating the results of identity theft based on the sensitive personal information that may have been compromised.

d. Based on the determinations of the independent risk analysis, the contractor shall be responsible for paying to the VA liquidated damages in the amount of $37.50 per affected individual to cover the cost of providing credit protection services to affected individuals consisting of the following:

(1) Notification;

(2) One year of credit monitoring services consisting of automatic daily monitoring of at least 3 relevant credit bureau reports;

(3) Data breach analysis;

(4) Fraud resolution services, including writing dispute letters, initiating fraud alerts and credit freezes, to assist affected individuals to bring matters to resolution;

(5) One year of identity theft insurance with $20,000.00 coverage at $0 deductible; and

(6) Necessary legal expenses the subjects may incur to repair falsified or damaged credit records, histories, or financial affairs.

7. TRAINING

a. All contractor employees and subcontractor employees requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and its systems:

(1) Sign and acknowledge (either manually or electronically) understanding of and responsibilities for compliance with the Contractor Rules of Behavior, Appendix E relating to access to VA information and information systems;

(2) Successfully complete the VA Cyber Security Awareness and Rules of Behavior training and annually complete required security training;

(3) Successfully complete the appropriate VA privacy training and annually complete required privacy training; and (4) Successfully complete any additional cyber security or privacy training, as required for VA personnel with equivalent information system access [to be defined by the VA program official and provided to the contracting officer for inclusion in the solicitation document – e.g., any role-based information security training required in accordance with NIST Special Publication 800-16, Information Technology Security Training Requirements.]

b. The contractor shall provide to the contracting officer and/or the COTR a copy of the training certificates and certification of signing the Contractor Rules of Behavior for each applicable employee within 1 week of the initiation of the contract and annually thereafter, as required.

c. Failure to complete the mandatory annual training and sign the Rules of Behavior annually, within the timeframe required, is grounds for suspension or termination of all physical or electronic access privileges and removal from work on the contract until such time as the training and documents are complete.