Attachment C_1 - 590-25-101 Security Badge Requirement.docx

Security – Background PIV requirement In accordance with VHAPM Part 822.18 CONTRACTOR PERSONNEL SECURITY AND SUITABILITY SOP Part B:

1.4, Deputy Under Secretary for Health and Operations and Management (10N) Memorandum, Contractors Excepted from Background Investigation and Screenings, dated February 8, 2007, specifies that the following low risk or non-sensitive contractor positions are excepted from the requirement to have a background investigation:

1.4.1. Contract personnel not accessing VA information resources such as personnel hired to maintain the medical facility grounds, construction contractors, utility system contractors, etc.

1.4.2. Contract personnel with limited and intermittent access to equipment connected to facility networks where limited Personal Health Information (PHI) is available, including contractors who install, maintain and repair networked building equipment such as fire alarm, heating ventilating and air conditioning equipment, elevator control systems, etc. If equipment to be repaired is located within sensitive areas (e.g. computer room/communications closets) VA IT staff must escort contractors while on site.

1.4.3. Contract personnel with limited and intermittent access to equipment connected to facility networks where limited PHI may be resident, including medical equipment contractors who install, maintain and repair networked medical equipment such as CT Scanners, EKG Systems, ICU monitoring, etc. Here, medical facilities must have a VA Business Associate Agreement (see VHAPM Part 839.105-70) if appropriate with the vendor to assure compliance with the requirements of the Health Insurance Portability and Accountability Act of 1996. Contract personnel, if on site, should be escorted by VA IT staff.

1.5. Special Agreement Check (SAC) Requirements and Exemptions: If it is determined that an exemption to a background investigation applies, the CO and COR shall determine whether or not a Special Agreement Check is required. All contract personnel who are exempt from a background investigation and who provide direct and/or ancillary health care services at VA facilities or have access to VA information systems or sensitive information must have a SAC completed unless an exemption applies. Deputy Under Secretary for Health and Operations and Management (10N) Memorandum, Contractors Excepted from Background Investigation and Screenings, dated February 8, 2007, specifies that the following low risk or non-sensitive contractor positions are excepted from the requirement to have a background screening (Special Agreement Check):

1.5.1. Contract personnel not accessing VA information resources such as personnel hired to maintain the medical facility grounds, construction contractors, utility system contractors, etc.

1.5.2. Contract personnel with limited and intermittent access to equipment connected to facility networks where limited Personal Health Information (PHI) is available, including contractors who install, maintain and repair networked building equipment such as fire alarm, heating ventilating and air conditioning equipment, elevator control systems, etc. If equipment to be repaired is located within sensitive areas (e.g. computer room/communications closets), VA IT staff must escort contractors while on site.

1.5.3. Contract personnel with limited and intermittent access to equipment connected to facility networks where limited PHI may be resident, including medical equipment contractors who install, maintain and repair networked medical equipment such as CT Scanners, EKG Systems, ICU monitoring, etc. Here, medical facilities must have a VA Business Associate Agreement (see VHAPM Part 839.105-70 of this SOP) if appropriate, with the vendor to assure compliance with the requirements of the Health Insurance Portability and Accountability Act of 1996. Contract personnel, if on site, should be escorted by VA IT staff.

Therefore, it is determined that this project is excepted from the background investigation and screening requirements. No access to VA Sensitive Information or access to VA network is required under this contract. Designers shall only be required to obtain flash badges for this project.

Attachment C | 590-25-101 Renovate Bldg. 135 | Page 1 of 2