36C24419R0069-001.docx
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36C24419R0069 P01 SOW for Wayfinding Signage 3-20-19.docx
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Erie VA Medical Center Erie, PA 16504
Design Scope of Work:
Signage & Wayfinding Improvements Project - Project No. 562-17-301
TABLE OF CONTENTS
| SECTION | TITLE | Page | |||
| 1.0 | SCOPE OF WORK | 2 | |||
| A. Interior Tasks | 4 | ||||
| B. Exterior | Tasks | 5 | |||
| 2.0 | PHASES OF WORK: | ||||
| Phase 1: Design Development | 6 | ||||
| Phase 2: Schematic Design | 7 | ||||
| Phase 3: 50% Contract Document | 8 | ||||
| Phase 3: 90% Contract Document | 9 | ||||
| Phase 4: 100% Contract Document | 10 | ||||
| Phase 5: Final Contract Bid Documents for Procurement | 11 | ||||
| 3.0 | CONSTRUCTION PERIOD SERVICES: | ||||
| Contract Procurement | 12 | ||||
| Construction Administration and Submittal Review | 12 | ||||
| Site Visits | 13 | ||||
| As Built Drawings | 13 | ||||
| 4.0 | PRIVACY TRAINING | 14 |
1.0 Scope of Work
The Architect/Engineering firm selected for this project will be required to evaluate the current exterior and interior signage system at the VA campus in Erie, PA. The purpose is to identify aspects of the existing system that requires improvement and provide a general solution, once approved, develop the complete working drawings, specifications, cost estimate, and construction period services for a construction contract for the demolition and installation of the new exterior and interior signage as well as wayfinding campus wide.
Design a complete and functional user-friendly environmental designs that, provides flexibility to allow for in-house maintenance and updating, larger wayfinding signs at key locations, updating current signage to have a hierarchy; most important information being the most visible, with secondary and tertiary information being smaller, on-campus directional signage to be located at or immediately preceding decision points and not obscured in any locations, and in accordance with all National Architecture, Electrical, Mechanical, and Building Codes, ADA Requirements, Fire/Life/Safety, and Security Codes, JACHO Compliance, Manual on Uniform Traffic Control Devices (MUTCD) and VA Standards.
1. The Architect/Engineer (AE) shall develop all Field Reports, Phasing Plans, Construction Documents, Construction Administration Services, Technical Specifications, and Cost Estimates, for the "Signage & Wayfinding Improvements Project.” at the Veteran’s Affairs (VA) Medical Center – Erie, Pennsylvania (Station 562).
2. The AE must be or represent a combined primary business in the field of Environmental Graphic Design/Signage performing the work of sign programming and design. The VA Graphic Style guidelines and The VA Wayfinding Report and Chapters for Signage Guideline must be used in all envelopment of signage package and regulations. https://www.cfm.va.gov/til/index.asp or https://downloads.va.gov/files/CFM-TIL/signs/
3. Project Manager must be assigned to the project to oversee signage planning, wayfinding and programming must have extensive experience with programming the room and informational signing for the interior and exterior of large medical centers.
4. All submissions and documents are to be provided in hard copy and electronically. This includes but is not limited to PDFs, Word Documents, and AutoCAD 2016 (dwg files), etc.
5. Drawing Data Information - Shall list all basic information including but limited to the following: File names, fonts, layer names/types color, blocks used, hatches, etc. See https://www.cfm.va.gov/TIL/sDetail.asp
6. The VA has ownership of the rights at the date of Closeout Submittal to all CAD files and Facility Data developed for the Project. The VA may make use of this data following any deliverables.
7. Applicable chapters of VA Master Construction Specifications will be prepared by the AE, including any necessary adaptations. See https://www.cfm.va.gov/TIL/spec.asp. Specifications must include Templates for each signage to reprint room names must be provided by the signage vendor as part of the package. Specifications must call out Training to be provided at least twice for usage and maintenance on product that is installed in the facility for all signage types
8. All submitted construction drawings shall minimally conform to the content requirements defined in the VA standards for construction. Specifically, the content features of PG-18-15 Minimum requirements for AE submissions. See https://www.cfm.va.gov/til/aeDesSubReq.asp
9. The AE shall develop and furnish an owners project requirements (OPR) document that details and logs the development of salient features of the project design. Comments for document will be given verbally and formal written will be via email. A/E to maintain OPR documents at all times not the VA.
10. SCHEDULE OF SUBMITTALS: AE shall note that the below schedule is for guidance only. This schedule may be adjusted to meet the needs of the VA Medical Center/ project needs.
a. Notice to Proceed……………………………………................................................................0days
b. Phase 1 Space Submission & Meeting …………………………............................................45 days
c. Phase 2 Submission & Meeting..............................................................................................100 days
d. Phase 3 Submission & Meeting ………………….……… ...................................................130 days
e. Phase 4 Submission & Meeting ………………….………....................................................170 days
f. Phase 5 Submission & Meeting .............................................................................................210 days
g. Phase 6 Submission & Meeting ……………………………….……………………………240 days
11. The design will generally define the various types of signs that will be used throughout the project along with issues of image, materials, finishes, typography and layout, and color. Terminology, names and titles, flexibility of the system, form and scale, and legibility will also be considerations in installation and other design details. The documents will include an elevation drawing of each sign type with applicable size and layout dimensions and any necessary side, top, and back views.
12. The AE will provide a minimum of two design options for each signage type and major design feature within the project. The AE shall provide sufficient data and information to allow for the VA to compare and contrast the options and make an informed decision: information that shall be included, but not limited to initial construction costs, annualized maintenance costs, expected maintenance activities, expected life span and pros and cons of the system.
13. The AE will provide phasing recommendations and bid alternates information in written form for VA consideration.
14. AE shall develop a phasing plan recommendation as all signage cannot be installed at the same time. The AE shall also develop deduct bid alternates for project award which will be based upon available construction funding of $1,200,000.
A. INTERIOR TASKS - The interior signage area is defined as the interior of the medical center complex. Which includes, but not limited to Main hospital, Building 1 floors SB, B 1, 2, 3, 4, 5, 6, 7, 8- Penthouse, Building 8 floors 1-2, Buildings 6,7,9,11,12, and Building 14 CLC.
1. Review the existing room numbering for all rooms and floors of the medical center. This room numbering system is one that is to be directed toward visitors and staff. The A/E will review and propose recommendation of changes to the room numbering.
2. All signage must be tamper proof; multiple options of securing the signage must be explored and provided to the VA for final decision.
3. Design must include demolition of all old signage and repair work of building materials, etc. All interior walls where signage is being removed/replaced. Walls must be repaired with patching and repainting to match the existing substrate. Plans must indicate areas of repair and how the repair should be addressed to match existing substrate a general note to match substrate will not be accepted.
4. The AE shall design, program, or exercise:
a. An interior room building identification sign program to include but not limited to the following:
i. Room identification for patient rooms -single & double occupancy, offices – single & multi-person offices, conference rooms, department identifications, in-use signs and schedule signs.
b. Detailed information identifying problems at the facilities that need to be changed and improved to provide better identification, circulation and communication of services for patients and visitors for consideration by the VA.
c. Engineering judgement and analysis when determining locations for major design features and if other alternatives exist for the features.
d. Wayfinding elements that define different areas floors with signage being color coded and materials different on signage.
e. Applied graphics to elevator doors to indicate floor level with images.
f. Dimensional letters and instructional signage throughout the facility
g. A life safety, code and regulatory sign program.
h. A directional wayfinding for wall, ceilings, and a floor map “you are here” sign program.
i. Including floor signs with department listings and directions.
i. Pictorial signage will be required for stairs, elevators, baby changing stations, in case of fire etc.
j. Signs designed with consideration given to the guideline for accessible signage related to the Americans with Disabilities Act.
B. EXTERIOR TASKS: An exterior building identification sign program which would replace all existing signage and provide new signage as required and needed. For buildings sign 1, 6, 7, 8, 9, 11, 12, 14, and parking garage.
1. New signage should have better legibility and visibility
2. New directional signs with modern, complimentary graphics
3. Repair work to any existing landscape that may cause problems with new sign install or removal.
4. Building entrance door identification to be included on any building without information.
5. All signage must be tamper proof; multiple options of securing the signage must be explored and provided to the VA for final decision.
6. Site identification signs for proper wayfinding throughout campus on the exterior.
7. Any foundation and footings for all Signage as required within design and calculate the wind and structural load stability to be provided for all exterior signage.
8. Design must include repair work to any existing landscape that may be caused by new sign install or removal. Including addressing building materials, removing concrete footers etc. Plans must indicate areas of repair and how the repair should be addressed to match existing substrate a general note to match substrate will not be accepted.
9. The AE shall design, program, develop, report, coordinate, incorporate, or provide:
A. Parking Lots:
1. Identifying site circulation issues for both vehicles and pedestrians that can be improved with signage to provide better access, circulation and communication for patients and visitors.
2. Review the locations of the Handicap/Van parking spots and requirements per code.
3. Parking lot signage, Dedicated parking spots, reserved parking spots. Patient parking only signs etc.
4. Vehicular and pedestrian wayfinding and orientation
5. Identify all parking lots in consistent manner
6. Existing roadway striping is deployed in some areas, but could be added in other locations to help with navigation and Mixed-use roadway (vehicle/pedestrian) presents an opportunity for catastrophe without proper barriers in place.
7. Traffic regulations signs as stop signs, speed limits, pedestrians crossing etc.
8. Provide locations and designs for new small motivational flags to be distributed throughout the campus on light posts etc.
B. Building signs:
1. Implement building identification signage that communicates a consistent message, with building function
2. Freestanding, wall or building mounted identification and directional signs;
3. Large VA Facade on rooftop that is lighted.
4. Backlighted entrances signage at the 2 entrances into the hospital.
5. Mandatory notice signage at entrances of building and facility main entrances.
6. Electronic Display board at front Entrance with coordination of power and data to support board.
i. Program control system and training must be approved and provide to the VA on electronic signage.
B. Parking Garage:
1. Level, stairs, elevations signage.
2. Column wraps for parking marking.
3. Overhead directional signage for Garage.
4. Room signage etc.
2.0 PHASES OF WORK
1. PHASE 1 – DESIGN DEVELOPMENT - Reviewing the scope of work of the project in greater detail and the responsibilities of the contractor/project manager and facility staff regarding input, design, documentation, coordination, direction and approvals.
A. A project schedule will be reviewed for approval which relates to the project’s sequence of events and priorities of importance.
B. The AE shall present a preliminary cost estimate predicated on the assessment made during the conceptual design phase.
C. Deliverables:
1. Review the options provided for signage and schemes development
2. Field Report – follow up from surveys and investigations done including keynoted photos
3. AE findings and recommendations as well as descriptions for all structural, electrical, and telecommunications systems considered.
4. Images of all sign types must be provided in relationship to buildings on campus for approval.
2. PHASE 2 – SCHEMATIC DESIGN - PRELIMINARY PROGRAMMING AND DESIGN
A. The contractor will survey and review the project for sign locations, text, and placements.
1. With the exterior signs, evaluations will be made regarding sign illumination requirements.
2. For the exterior directional signs, evaluations will involve analyzing public, employee and vehicular circulation and traffic flow patterns around the project site.
3. Based on information gathered in these activities and in the Planning Phase, the contractor will develop the schematic design scheme for the “look” of the sign program.
B. The contractor will identify finishes, trims, types of signs and other design details.
1. This will all be based upon a component based sign system as identified in the VA Sign Design Guide, created for the Department of Veterans Affairs.
2. Emphasis will be placed on developing a sign program that provides the facility with a progressive professional look, coordinated with the building’s interior design and architecture.
3. For both the interior of the buildings and the exterior signs for the campus, a preliminary sign location plan will be prepared along with a preliminary sign message schedule.
C. The schematic design scheme, preliminary sign location plan and preliminary message schedule will be presented to Facility, coordinated by the facility project manager, for their review and comment.
1. The A/E will assist the facility in the review of the documents and the assemblies of the facilities review comments.
D. Review of Phasing Plans documents on how the project would be implemented E. Deliverables:
1. Field Report – follow up from surveys and investigations done including keynoted photos
2. AE findings and recommendations as well as descriptions for all structural, electrical, and telecommunications systems considered.
3. Drawings illustrating the proposed room numbering scheme.
4. Drawings illustrating the proposed look, color, trim, etc. of the interior and exterior sign program Preliminary sign location plan and message schedule.
5. Renderings of all sign types must be provided; exterior renderings must be provided for every sign type in relationship to buildings on campus for approval.
| Quantity |
| Address List |
1 Set Spec’s 1 Full size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
1 sets Spec’s 1 Half Size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
| 1 |
| Via e-mail to CO & COR |
3. PHASE 3 – CONSTRUCTION DOCUMENTS 50% - REVIEW
A. Provide complete sets of specifications, drawings, and cost estimate in quantity as required by the table below. Submissions shall be FedEx or other overnight delivery service to the address listed below.
B. Submittal letter: A/E shall provide a submittal letter stating document submitted for the first construction document review.
C. Specifications: A/E shall provide full sets of edited, bound, assembled and typed project specifications included all legal documents provided by Contracting Officer.
D. Drawings: A/E shall provide full sets of project drawings showing the basic plan for each discipline involved and as follows:
1. A title sheet with drawing index and department index for all drawings.
2. Measured drawings of existing systems and facilities to be demolished or retained.
3. All drawings developed for the first review shall be detailed showing all utilities, services, and sizes as well as other required construction details.
4. Show complete all rooms titles, room numbers, sizes, door schedules, finish schedules, elevations, legends, and other schedule information.
5. Also show complete details, notes, sizing computations of new services, equipment schedules, control diagrams, sections, and locations.
6. All work to be in accordance with VA CADD layer guidelines.
7. All drawings must be clearly marked “Construction Documents 50% Review”.
E. Cost Estimates: A/E shall provide a detailed cost estimate and ensure that the following items are included:
1. Certification that the quantities have been checked and found to be correct.
2. All estimates shall be used on the most up-to-date working drawings available and shall be current as of the date of submission.
3. Cost totals should reflect labor and materials separately and should be formatted as follows:
a. Format estimate using Excel.
b. Organize estimate according to the VA MasterFormat.
c. Breakdown of all significant items by branch of work.
d. Totals-Labor and material for all branches of work.
e. Overhead & profit – 10% each of reflect variations of trades, project size, competition, etc.
f. Total Estimated Cost.
Cost estimate work sheet HO-18B form available at https://www.cfm.va.gov/til/dManual/dmCost.pdf
| Quantity |
| Address List |
1 Set Spec’s 1 Full size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
1 sets Spec’s 1 Half Size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
| 1 |
| Via e-mail to CO & COR |
4. PHASE 4 – CONTRACT DOCUMENTS 90% - FINAL PROGRAMMING and DESIGN A. After the 50% construction documents the contractor will proceed to develop the draft of the sign project documents involving the sign type drawings and specifications.
1. These documents will show preliminary illustrations of all interior and exterior sign types in the sign program.
2. A preliminary draft of the specifications and budget will be developed that will define the cost of implementing the program.
B. The contractor will revise the sign location plan and message schedule. These documents will be presented to appropriate facility staff for review and comment.
C. Phasing Plans for project documents.
D. Submittal letter: A/E shall provide a submittal letter stating document submitted for the 90% construction document review.
E. Deliverables:
1. Field Report – follow up from surveys and investigations done including keynoted photos.
2. AE findings and recommendations as well as descriptions for all structural, electrical, and telecommunications systems considered.
3. Drawings illustrating the proposed room numbering scheme.
4. Drawings illustrating the proposed look, color, trim, etc. of the interior and exterior sign program Preliminary sign location plan and message schedule.
5. Renderings of all sign types must be provided; exterior renderings must be provided for every sign type in relationship to buildings on campus for approval.
6. Preliminary version of the sign project manual showing all the sign types, revised sign location plans and message schedule; Preliminary specifications and costs for signage.
| Quantity |
| Address List |
1 Set Spec’s 1 Full size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
1 sets Spec’s 1 Half Size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
| 1 |
| Via e-mail to CO & COR |
5. PHASE 5 – 100% CONSTRUCTION DOCUMENTS
A. In this phase, the firm refines and finalizes the physical design of the signs, based upon client input from 90% construction documents. The facility project coordinator will return the 90% submission sign type drawings, sign location plan and message schedule to the AE with comments and revisions.
B. The AE will prepare the final contract documents for 100% bid documents and supporting specs, project manuals, landscaping, electrical, detailed sign type drawings, defining all the signs in the hierarchy of the sign program, selected sign construction details, sign installation details and specifications.
1. The sign type drawings will include elevation drawings of each sign type with applicable size and layout dimensions and any necessary side, top and back views.
2. It will also contain the interior and exterior sign message schedule, which defines the wording of each sign, referenced to the sign type and location.
3. Final specifications will be provided for both the interior and exterior signs. Final sign location plans, in the form of AUTO CAD files will be provided for both the interior and exterior sign locations.
C. Deliverables:
1. Detailed Final specifications (1 copy).
2. Detailed final cost estimates.
3. Detailed scope of work.
4. Detailed phasing plan.
5. Specifications and drawing files on CD-ROM (If requested).
6. All submitted information shall be made available for secure download to the VA.
7. Field Report – follow up from surveys and investigations done including keynoted photos.
8. Design Narrative identifying AE findings and recommendations as well as descriptions for all structural, electrical, and telecommunications systems considered.
| Quantity |
| Address List |
1 Set Spec’s 1 Full size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
1 sets Spec’s 1 Half Size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
| 1 |
| Via e-mail to CO & COR |
6. PHASE 6 CONTRACT BID DOCUMENTS FOR PROCUREMENT
A. A. AE will incorporate any comments as per the review meeting of the phase 5 submission. This set should have no errors and all final information for bid documents.
B. Deliverables:
1. Final Edited specifications (2 copy).
2. Final detailed cost estimates.
3. Final detailed scope of work.
4. Final detailed phasing plan.
5. Final Specifications and drawing files on CD-ROM.
| Quantity |
| Address List |
2 Set Spec’s 1Full size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
4 sets Spec’s 4 Half Size Dwgs Department of Veterans Affairs Medical Center, FMS 138 ATTN: COR of Project, 135 E 38th St., Erie, PA 16504
| 1 |
| Via e-mail to CO & COR |
6. All submitted information shall be made available for secure download to the VA.
3.0 CONSTRUCTION PERIOD SERVICES
A. Contract Procurement:
1. Attend contractor's Pre-Bid site visit and respond with recommendations to any questionable items. If necessary, develop amendments or assist with project procurement. A written response is required.
2. Attend one (1) pre-construction meeting, meeting after award of construction contract.
3. Attend project weekly schedule coordination meeting after award of construction contract (telephone attendance mandatory, site attendance as requested by VAMC).
B. Construction Administration and Submittal Review:
1. The AE firm shall review and respond to all:
a. Submittals.
b. RFI.
c. change orders (construction materials and equipment and proposed by the contractor for use in construction of this project).
d. All submittals and change order proposals will be reviewed for compliance with the specifications and reasonable costs and returned to Engineering Service within five (5) calendar days after receipt.
2. The AE shall support inquiries related to the designed mechanical, electrical, fire/Life safety protection, lighting, and other building systems included in this project’s scope.
C. Site Visits (In addition to site visits listed in Item ‘A’ above):
1. The AE shall visit the site at the request of the Contracting Officer to answer technical questions and/or provide clarification to documents due to errors or omissions at no additional cost to the government. These meetings will not count against required meetings set forth below.
2. One Pre-Construction site visit. Attend and assist with site inspections at each phase as indicated and a final phase inspection an end of each phase.
3. Spot checking of contractor’s progress (Intermediate Inspections) based on four different four-hour site visits when requested by the VAMC Contracting Officer. These meetings may also be used to answer technical questions and/or develop minor changes due to site conditions, etc. This is in addition to item C.a and C.b above.
4. Final inspection of construction –prepare a report noting deficiencies and corrections necessary for the installers to complete on the project. – One team visit
5. Post-construction and weekly project meetings required – AE to provide all meeting minutes from all meeting held using VA template. Site Attendance is mandatory for all weekly meetings to address concerns, issues and attend site of visits for work progress. Meetings may be able to be conference meetings when the project is not in full construction per the VA approval.
D. As Built Drawings:
1. The AE shall modify design drawings based on marked drawings supplied by the contractor and are to be verified by the AE in field.
a. As-Built to include all addendums and Bulletins issued by the VA and the A/E during construction.
b. The changes shall be incorporated into the final CAD and Project Drawings with the revision documented on the title block as appropriate.
c. These changes shall be bubbled and dated.
d. The AE is to reformat the drawings based on the VA layering system before final submission.
e. The AE will receive these required layer standards under a separate cover.
f. A reproducible hardcopy and the electronic model of the “As-Built” are to be submitted to the COTR on CD-ROM.
g. Any approved shop drawings with major differences from contract drawings, supplemental agreements processed change orders, etc., shall be incorporated.
2. The AE shall deliver completed as-built drawings no later than construction close out.
4.0 PRIVACY TRAINING
A. VA Privacy and Information Security Awareness and Rules of Behavior Course (text version) must be completed by all contractors and subcontractor employees assigned to VA accounts prior to delivery of service and annually thereafter as long as the contract is in place.
B. The contractor shall provide to the VA COR a copy of the completed training certificate(s).
C. Certification and accreditation requirements do not apply, and a Security Accreditation Package is not required. At no time will the vendor be in contact or have access to VA sensitive information. VA sensitive information procedures will be followed per VA Handbook 6500.6.
Expectation: The generalized privacy training “VA Privacy Training for Personnel Without Access to VA Computer Systems or Direct Access or Use to VA Sensitive Information” must be completed by all contractors and subcontractor employees assigned to VA accounts prior to delivery of service and annually thereafter as long as the contract is in place.
1. The contractor shall provide to the VA COR a copy of the completed training certificate(s).
SOW Signage & Wayfinding Improvements - Project 562-17-301 image1.emf
VA Privacy Training No PHI or Access final 4 7 14.doc
VA Privacy Training for Personnel without Access to VA Computer Systems or Direct Access or Use to VA Sensitive Information
The Department of Veterans Affairs, VA must comply with all applicable privacy and confidentiality statutes and regulations. One of the requirements in VA is to have all personnel trained annually on privacy requirements. “Privacy” represents what must be protected by VA in the collection, use, and disclosure of personal information whether the medium is electronic, paper or verbal.
This document satisfies the “basic” privacy training requirement for a contractor, volunteer, or other personnel only if the individual does not use or have access to any VA computer system such as Time and Attendance, PAID, CPRS, VistA Web, VA sensitive information or protected health information (PHI), whether paper or electronic. You will find this training outlines your roles and responsibility for protecting VA sensitive information (medical, financial, or educational) that you may incidentally or accidentally see or overhear.
If you have direct access to protected health information or access to a VA computer system where there is protected health information such as CPRS, VistA Web, you must take “Privacy and HIPAA Focused Training” (TMS 10203). “VA Privacy and Information Security Awareness and Rules of Behavior” (TMS 10176) is always required in order to use or gain access to a VA computer systems or VA sensitive information, whether or not protected health information is included. Both trainings are located within the VA Talent Management System (TMS): https://www.tms.va.gov
What is VA Sensitive Information/Data?
All Department information and/or data on any storage media or in any form or format, which requires protection due to the risk of harm that could result from inadvertent or deliberate disclosure, alteration, or destruction of the information. The term includes not only information that identifies an individual but also other information whose improper use or disclosure could adversely affect the ability of an agency to accomplish its mission, proprietary information, and records about individuals requiring protection under applicable confidentiality provisions.
What is Protected Health Information?
The HIPAA Privacy Rule defines protected health information as Individually Identifiable Health Information transmitted or maintained in any form or medium by a covered entity, such as VHA.
What is an “Incidental” Disclosure?
An incidental disclosure is one where an individual’s information may be disclosed incidentally even though appropriate safeguards are in place. Due to the nature of VA communications and practices, as well as the various environments in which Veterans receive healthcare or other services from VA, the potential exists for a Veteran’s protected health information or VA sensitive information to be disclosed incidentally.
For example:
· You overhear a healthcare provider’s conversation with another provider or patient even when the conversation is taken place appropriately.
· You may see limited Veteran information on sign-in sheets or white boards within a treating area of the facility.
· Hearing a Veteran’s name being called out for an appointment or when the Veteran is being transported/escorted to and from an appointment.
Safeguards You Must Follow To Secure VA Sensitive Information:
· Secure any VA sensitive information found in unsecured public areas (parking lot, trash can, or vacated area) until information can be given to your supervisor or Privacy Officer. You must report such incidents to your Privacy Officer timely.
· Don’t take VA sensitive information off facilities grounds without VA permission unless the VA information is general public information, i.e., brochures/pamphlets.
· Don’t take pictures using a personal camera without the permission from the Medical Center Director.
· Any protected health information overheard or seen in VA should not be discussed or shared with anyone who does not have a need to know the information in the performance of their official job duties, this includes spouses, employers or colleagues.
· Do not share VA access cards, keys, or codes to enter the facility.
· Immediately report lost or stolen Personal Identity Verification (PIV) or Veteran Health Identification Cards (VHIC), any VA keys or keypad lock codes to your supervisor or VA police.
· Do not use a VA computer using another VA employee’s access and password.
· Do not ask another VA employee to access your own protected health information. You must request this information in writing from the Release of Information section at your facility.
What are the Six Privacy Laws and Statutes Governing VA?
1. Freedom of Information Act (FOIA) compels disclosure of reasonably described VA records or a reasonably segregated portion of the records to any person upon written request unless one or more of the nine exemptions apply.
2. Privacy Act of 1974 provides for the confidentiality of personal information about a living individual who is a United States citizen or an alien lawfully admitted to U.S. and whose information is retrieved by the individual’s name or other unique identifier, e.g. Social Security Number.
3. Health Insurance Portability and Accountability Act (HIPAA) provides for the improvement of the efficiency and effectiveness of health care systems by encouraging the development of health information systems through the establishment of standards and requirements for the electronic transmission, privacy, and security of certain health information.
4. 38 U.S.C. 5701 provides for the confidentiality of all VA patient and claimant information, with special protection for their names and home addresses.
5. 38 U.S.C. 7332 provides for the confidentiality of drug abuse, alcoholism and alcohol abuse, infection with the human immunodeficiency virus (HIV) and sickle cell anemia medical records and health information.
6. 38 U.S.C. 5705 provides for the confidentiality of designated medical-quality assurance documents.
What are the Privacy Rules Concerning Use and Disclosure?
You are not authorized to use or disclose protected health information. In general, VHA personnel may only use information for purposes of treatment, payment or healthcare operations when they have a need-to-know in the course of their official job duties. VHA may only disclose protected health information upon written request by the individual who is the subject of the information or as authorized by law.
How is Privacy Enforced?
There are both civil and criminal penalties, including monetary penalties that may be imposed if a privacy violation has taken place. Any willful negligent or intentional violation of an individual’s privacy by VA personnel, contract staff, volunteers, or others may result in such corrective action as deemed appropriate by VA including the potential loss of employment, contract, or volunteer status.
Know your VA/VHA Privacy Officer and Information Security Officer. These are the individuals to whom you can report any potential violation of protected health information or VA sensitive information, or any other concerns regarding privacy of VA sensitive information.
YOU ARE RESPONSIBLE FOR PROTECTING THE CONFIDENTIAL INFORMATION OF OUR VETERANS
Employee (Print Name)
Date
Employee Signature
Print Name of Contract Agency, if contractor
Print Name of VHA Department/Supervisor/Contracting Officer
PROVIDE A COPY OF THIS FORM TO YOUR SUPERVISOR/CONTRACTING OFFICER
FOR DATA ENTRY INTO TALENT MANAGEMENT SYSTEM
File details come from the government source that posted it.