Performance Work Statement - Offsite Record Storage.pdf

PERFORMANCE WORK STATEMENT – Offsite Record Storage Philadelphia VAMC

GENERAL REQUIREMENT

Contractors and contractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel.

CONTRACT ADMINISTRATION

Notwithstanding the Contractor's responsibility for total management during the performance of this contract, the administration of the contract will require maximum coordination between the Government and the Contractor. The Contracting Officer is the only person authorized to approve changes or modify any of the requirements of this contract. The Contractor shall communicate with the Contracting Officer on all matters pertaining to contract administration. Only the Contracting Officer is authorized to make commitments or issue changes that shall affect price, quantity or quality of performance of this contract.

The Corporal Michael J. Crescenz VA Medical Center (CMCVAMC) in Philadelphia PA, Health Information Management Services (HIMS) department requires an offsite NARA approved records storage facility.

The facility would need to have the ability to store immediately 5,978.60 cubic feet of records and films.

The Storage facility must supply transportation to pick up records which are currently being stored at the following four (4) locations:

1. 3433 PROGRESS DR, Bensalem, PA 19020-5803

2. 811 STATE ROUTE 33, Freehold, NJ 07728-8431

3. 26 S MIDDLESEX AVE, Monroe, NJ 08831-3724

4. 549 MILL RD, Edison, NJ 08837-3854

The contractor storage site should be no more than 125 miles from the CMC Philadelphia Corporal M.

Crescenz VA Medical Center 3900 Woodland Ave, Philadelphia Pa 19104-4551. The Contractor will provide space, security, storage, retrieval and transfer services for the CMCVAMC. These boxes must be stored to allow for retrieval by the box. These sensitive files must be secure from fire, water, and other elements that can cause damage to the records. The contractor must also have the ability to complete a full inventory/indexing of all files and thereafter conduct a disposition/destruction of all files.

APPLICABLE DOCUMENTS

Contractor shall adhere to all VA Directives, policies, handbooks, memorandums, or facility standard operating procedures, as well as any federal or state regulations regarding record retention, security, and destruction. This includes but is not limited to, VHA Records Control Schedule (RCS) 10-1, the National Archives and Records Administration (NARA), General Records Schedule (GRS), or any other appropriate records schedule must be used to determine retention and disposition requirements for VHA records.

PERFORMANCE DETAILS

The Contractor shall make certain that appropriate physical care and security measures are taken to ensure that documents and health records and the VA information they contain are not damaged or compromised throughout the entire process from the point of receipt through the return shipment. The Contractor shall be compliant with all VA established security policies to ensure VA data, whether captured electronically or on paper or other media are not compromised.

The Contractor shall adhere to established VA physical security policy prior to receipt and while in possession of all radiology film and health records documentation off site.

Services shall include picked up from locations listed below, and brought to contractor site to be inventory, stored and disposition. Contractor shall provide a National Archival Record Administration (NARA) compliant record storage facility. The contractor shall provide personnel who has an understanding of the VA Records Control Schedule (RCS)10-1 Federal General Schedule of Records and name a Record Manager as a single point of contact for intake/processing of new material and client education.

RECORD PICKUP LOCATIONS

The contractor will pick up records from the following locations:

Primary Location 3433 PROGRESS DR, Bensalem, PA 19020-5803 Secondary Location 811 STATE ROUTE 33, Freehold, NJ 07728-8431 26 S MIDDLESEX AVE, Monroe, NJ 08831-3724 549 MILL RD, Edison, NJ 08837-3854

When transporting VA documents, a high-level of security is required. Documents shall be transported in enclosed, locked vehicles by the Contractor’s permanent staff. All vehicles must be always secured, whether parked or in transit. This includes having all windows closed, all doors locked, and the alarm system engaged.

SCOPE OF WORK

SPECIFIC TASK AND DELIVERABLES

The Contractor shall provide, at a minimum, all tasks and deliverables described within this document.

All deliverables shall be submitted to the CMCVA point of contact. Unless otherwise stipulated, written deliverables shall be phrased in plain English. Statistical and other technical terminology shall not be used without providing a glossary of terms.

The overall tasks associated with this procurement include: record pickup and transportation to contractor NARA compliant facility, an inventory and indexing of all records (within 180 days), destruction of appropriated records, and final transportation of appropriate records to Silver Recovery Distribution Center in Hine, IL; when scheduled.

Paper records need to be separated from Xray’s due to the fact Silver Recovery will not accept shipments containing paper records. This would also constitute the unnecessary disclosure of Personally Identifiable Information (PII).

The Contractor shall provide all management, labor, resources, and specialized equipment needed to provide Scanning and/or Importing and Indexing of Records, and Project Management. The Contractor shall define a VA-approved project workflow that shall not impede the day-to-day operations of the specific department. The workflow shall specify the expected turnaround time for each ordered service and any facility specific standards. When the Contractor cannot meet the specified deadline, they must inform the facility point of contact immediately and no later than twenty-four (24) hours prior to the deadline. If the Contractor is uncertain concerning a policy or procedure, the Contractor shall consult with the facility point of contact for clarification. Indexing of Records shall be completed within 180 days of all records being moved to new NARA compliant facility.

The Contractor is responsible for the management of its staff, and the Contractor is responsible for training its staff on VA policy and procedures, with the assistance of the Health Information Management (HIM) Department.

The Contractor shall bear the costs of any other training. The Contractor is responsible for performing quality reviews of staff work. The Contractor shall bear the cost of any re-work and/or corrections and take corrective action when services are found deficient or substandard.

The Contractor shall attend a kick-off meeting within five (5) business days after contract award date.

The Contractor shall perform the tasks and complete the associated deliverables by the scheduled dates within the overall period of performance. The service categories are: Storage, Inventory and disposition of Records, and Project Management.

STORAGE OF RECORDS

Ability to store immediately 5,978.60 cubic feet of records and films.

INVENTORY AND INDEXING OF RECORDS

Contractor shall retrieve all the inventory being held at 4 locations previously mentioned.

Contractor shall have the ability to perform an inventory listing of boxes stored at their facility that will include the following: patient full name (last, first, middle initial) Social Security Number, Date of Birth, Media type, volume of records, and Date of Xray/Report.

Contactor shall have completed the inventory of all records and boxes no later than 180 days of receipt of boxes.

Provide an inventory control and reporting system to identify the inventory levels of records stored on-site. The inventory levels should be detailed by box and records category. The inventory system must allow for easily accessible records by box. The Contractor will update the inventory control and reporting system within 48 hours of boxes being removed from inventory to allow the government to identify the current inventory levels of publications and records remaining on-site.

The reporting system must allow for reports detailing inventory by box number, description of publication or record type, date box was added, removed or destroyed from inventory. The Contractor shall provide detailed reports on an as needed basis for review upon request by authorized Government POC, project manager, and approved personnel.

The contractor shall provide other required reports on an as needed basis for review by the authorized POC, project manager, approved personnel.

Inventory reports can be provided by email, fax, or by customer internet account. Reports may also be provided by mail when the report size is substantial and not conducive to electronic transmission.

The contractor shall provide an updated listing when additional records are added to storage.

Records received at the commercial records storage facility shall be verified against the shipping list and a copy of the complete list given to the facility point of contact.

Established quality control and assurance program implemented. Contractor shall provide quality assessment of their inventory services in a format and frequency identified by the point of contact.

Quality benchmarking shall be equal or better than 95% accuracy of the established indexing parameters and nomenclature along with meeting established deadlines for inventory indexing and disposition/destruction of files.

PREPARING RECORD FOR DISPOSITION TRANSFER

Contractor shall prepare boxes for shipping according to industry standards and provide pallets and shrink-wraps for transporting as necessary. In coordination with the Government (CMCVAMC), the Contractor will transport eligible X-Ray files from their current storage facility to Silver Recovery in Hines IL. Disks and X-Rays must be kept for 5 years after the date of the last exposure, except for teaching files, which must be retained for 10 years. Specific eligibility will be discussed with contract point of contact. Disposition of all records shall be completed by the end of the contract period (base + 1 option year).

The contractor shall provide qualified personnel to perform inventory, prepare records for transfer.

The contractor shall provide an inventory of all records prior to removal from contractor location and an updated list after arrival and inventory at the contractor’s facility.

Contractor shall prepare files for disposition and transport to Silver Recovery Program at the VA Service and Distribution Center (SOC) in Hines IL when notified by the facility RMO. The contractor shall consider a box or file destroyed or disposed of when the box or file has been permanently removed from the inventory system. This action can only be taken after receiving the signature from Facility RMO approving the destruction of the cited records. The inventory reports must reflect the removal of destroyed records within 7 business days after the Government has provided destruction authority.

Paper records shipped to CMCVAMC as permanent withdrawal are to be reported as dispositioned records no destruction approval is required.

The contractor will update transmittal history sheets and provide detailed inventory of each box of files stored at contractor location reports to CMCVAMC of all existing inventory quarterly.

The contractor shall ensure each record being transferred has a disposition date and information in accordance with The Department of Veterans Affairs Records Control Schedule (RCS) 10-1. RCS 10-1 is the main authority for the retention and disposition requirements of VA records. It provides a brief description of the records, states the retention period and disposition requirements.

DISPOSITION OF RECORDS

Contractor shall ensure each record being transferred has a disposition date and information in accordance with The Department of Veterans Affairs Record Control Schedule (RCS) 10.1. The RCS https://www.va.gov/vhapublications/rcs10/rcs10-1.pdf

10.1 is the main authority for the retention and disposition requirements of VA records. It provides a brief description of the records, states the retention period and disposition requirements.

DESTRUCTION OF RECORDS

The contractor shall provide a report of records that are available for destruction as scheduled by the Government, and the Veterans Health Administration Records Control Schedule 10-1 (RCS 10-1). The Contractor shall issue to the government a certificate of destruction for all terminated records of filings.

The contractor shall send monthly an alert/reminder notification stating that the approaching records are eligible for destruction when it is time for destruction of records. This notification shall be sent via email to the records manager and contract point of contact at their VA email address.

The contractor shall destroy records only after receiving the signature of the facility point of contact or the Facility Records Management Officer approving the destruction of the cited records. The inventory reports must reflect the removal of destroyed records within seven (7) business days after the Government provided destruction authority.

The contractor shall not destroy or dispose of any records without authorization and provide a digital record of all records for disposition according to the RCS 10-1 to the facility Record Management Officer by email. All records shall be created into a digital record, provided to the VA facility Record Management Officer, and physical records destroyed by the end of the contract period (base + 1 option year).

OPERATIONS

Contractors shall be available during regular business hours from 8:00 am to 4:30 pm EST, Monday through Friday. This excludes federally recognized holidays. Contractor shall provide off-hour, weekend, and holiday coverage for emergency operations.

Contractor and CMCVAMC must agree on the method of emergency contact. Contractor will provide CMCVAMC with contact information within 5 business days of contract implementation and confirm during kick-off meeting. Records shall be delivered via method indicated by facility point of contact. This may include contractor-owned and staffed vehicles, via facsimile, or via document version and archive to image repository. After completion of inventory and indexing, the contractor is expected to respond to emergency requests within 3 hours of notification from the facility Record Management Officer or designee.

The contractor shall provide a secure web (Internet) based interface to facilitate the record retrieval and delivery. In addition, contractor shall allow requests to be made through the web-based system, fax, or telephone. 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.

The contractor shall provide a secure web (Internet) based interface to facilitate the record retrieval and delivery. In addition, contractor shall allow requests to be made through the web-based system, fax, or telephone. 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.

DATA BREACH AND SECURITY

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.

BILLING AND PAYMENTS

Invoices shall be submitted monthly, in arrears, and shall include at a minimum: Date of Invoice, Contract Number, Purchase Order Number, Vendor Name, Invoice Number, CUN, and Date of Service.

GENERAL RESPONSIBILITIES OF THE GOVERNMENT

a The facility (CMCVAMC) will review the updated inventory information provided by the contractor and alert the contractor as soon as possible which of the current X-rays are eligible for transfer to Silver Recovery.

b Provide a listing of any inactive files and a schedule of upcoming disposition via transfer to Silver Recovery.

c Provide a schedule for the permanent withdrawal of paper records to be returned to CMCVAMC.

d Provide technical directions to the contractor. The purpose of this direction is to re-prioritize efforts to meet organizational goals and mission priorities. Technical direction will originate from the COR, Record Management Officer or members from radiology management staff.

Record Management Language Obligations

A. Applicability

This clause applies to all Contractors whose employees create, work with, or otherwise handle Federal records, as defined in Section B, regardless of the medium in which the record exists.

B. Definitions “Federal record” as defined in 44 U.S.C. § 3301, includes all recorded information, regardless of form or characteristics, made or received by a Federal agency under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the United States Government or because of the informational value of data in them.

The term Federal record:

1. Includes VHA records.

2. Does not include personal materials.

3. Applies to records created, received, or maintained by Contractors pursuant to their VHA contract.

4. May include deliverables and documentation associated with deliverables.

C. Requirement

1. Contractor shall comply with all applicable records management laws and regulations, as well as

National Archives and Records Administration (NARA) records policies, including but not limited to the Federal Records Act (44 U.S.C. chs. 21, 29, 31, 33), NARA regulations at 36 CFR Chapter XII Subchapter B, and those policies associated with the safeguarding of records covered by the Privacy Act of 1974 (5 U.S.C. 552a). These policies include the preservation of all records, regardless of form or characteristics, mode of transmission, or state of completion.

2. In accordance with 36 CFR 1222.32, all data created for Government use and delivered to, or falling under the legal control of, the Government are Federal records subject to the provisions of 44 U.S.C. chapters 21, 29, 31, and 33, the Freedom of Information Act (FOIA) (5 U.S.C. 552), as amended, and the Privacy Act of 1974 (5 U.S.C. 552a), as amended and must be managed and scheduled for disposition only as permitted by statute or regulation.

3. In accordance with 36 CFR 1222.32, the Contractor shall maintain all records created for Government use or created in the course of performing the contract and/or delivered to, or under the legal control of the Government and must be managed in accordance with Federal law. Electronic records and associated metadata must be accompanied by sufficient technical documentation to permit understanding and use of the records and data.

4. VHA and its contractors are responsible for preventing the alienation or unauthorized destruction of records, including all forms of mutilation. Records may not be removed from the legal custody of VHA or destroyed in accordance with the provisions of the agency records schedules and with the written concurrence of the Head of the Contracting Activity. Willful and unlawful destruction, damage, or alienation of Federal records is subject to the fines and penalties imposed by 18 U.S.C. 2701. In the event of any unlawful or accidental removal, defacing, alteration, or destruction of records, the Contractor must report to VHA. The agency must report promptly to NARA in accordance with 36 CFR 1230.

5. The Contractor shall immediately notify the appropriate Contracting Officer upon discovery of any inadvertent or unauthorized disclosures of information, data, documentary materials, records, or equipment. Disclosure of non-public information is limited to authorized personnel with a need-to-know as described in the [contract vehicle]. The Contractor shall ensure that the appropriate personnel, administrative, technical, and physical safeguards are established to ensure the security and confidentiality of this information, data, documentary material, records, and/or equipment is properly protected. The Contractor shall not remove material from Government facilities or systems, or facilities or systems operated or maintained on the Government’s behalf, without the express written permission of the Head of the Contracting Activity. When information, data, documentary material, records, and/or equipment is no longer required, it shall be returned to VHA control, or the Contractor must hold it until otherwise directed. Items returned to the Government shall be hand-carried, mailed, emailed, or securely electronically transmitted to the Contracting Officer or address prescribed in the [contract vehicle]. Destruction of records is EXPRESSLY PROHIBITED unless in accordance with Paragraph (4).The Contractor is required to obtain the Contracting Officer's approval prior to engaging in any contractual relationship (sub-contractor) in support of this contract requiring the disclosure of information, documentary material, and/or records generated under, or relating to, contracts.

The Contractor (and any sub-contractor) is required to abide by Government and VHA guidance for protecting sensitive, proprietary information, classified, and controlled unclassified information.

6. The Contractor shall only use Government IT equipment for purposes specifically tied to or authorized by the contract and in accordance with VHA policy.

7. The Contractor shall not create or maintain any records containing any non-public VHA information that is not specifically tied to or authorized by the contract.

9. The Contractor shall not retain, use, sell, or disseminate copies of any deliverable that contains information covered by the Privacy Act of 1974 or that which is generally protected from public disclosure by an exemption to the Freedom of Information Act.

10. The VHA owns the rights to all data and records produced as part of this contract. All deliverables under the contract are the property of the U.S. Government for which VHA shall have unlimited rights to use, dispose of, or disclose such data contained therein as it determines to be in the public interest. Any Contractor rights in the data or deliverables must be identified as required by FAR 52.227-11 through FAR 52.227-20.

11. Training. All Contractor employees assigned to this contract who create, work with or otherwise handle records are required to take VHA-provided records management training. The Contractor is responsible for confirming training has been completed according to agency policies, including initial training and any annual or refresher training. [Note: To the extent an agency requires contractors to complete records management training, the agency must provide the training to the contractor.]

12. Flow down of requirements to subcontractors

The Contractor shall incorporate the substance of this clause, its terms, and requirements including this paragraph, in all subcontracts under this [contract vehicle], and require written subcontractor acknowledgment of same.

Violation by a subcontractor of any provision set forth in this clause will be attributed to the Contractor.

The contractor shall incorporate the substance of this clause, its terms and requirements including this paragraph, in all subcontracts under this contract document, and require written subcontractor acknowledgment of same.

Violation by a subcontractor of any provision set forth in this clause will be attributed to the contractor.