36C25519Q0382-001.pdf

SUPPLIES OR SERVICES AND PRICES/COSTS

Contractor shall furnish assisted wheelchair van transportation for eligible beneficiaries of the VA Medical Center, St. Louis, Missouri (herein after referred to as VAMC). The VAMC St.

Louis has two divisions located as follows: John Cochran Division (JC), 915 North Grand Blvd., St. Louis, MO 63106 and Jefferson Barracks Division (JB), #1 Jefferson Barracks Drive, St. Louis, MO 63125. Services shall be provided in accordance with all terms, conditions, provisions and the schedule of this solicitation. The primary intent of this contract is for prearranged non-emergency transportation.

DESCRIPTION/SPECIFICATIONS/WORK STATEMENT

Contractor shall provide assisted wheelchair van transportation services for beneficiaries of the VA Medical Center, St. Louis, MO. The Government intends to award a Requirements type contract, Fixed Price with Economic Price Adjustment.

Definition(s):

Addresses:

John Cochran (JC) 915 North Grand St Louis, Missouri 63106

Jefferson Barracks (JB) 1 Jefferson Barracks Drive St. Louis, Missouri 63125

St. Clair Community Based Clinic (CBOC) 1190 Fortune Blvd Shiloh, IL 62269

St. Louis CBOC 6854 Parker Road Florissant, MO 63033

St. Charles CBOC 844 Waterbury Drive O’Fallon, MO 63368

Washington Avenue Annex 2727 Washington Ave.

St. Louis, MO 63101

Manchester Avenue Annex

4974 Manchester Avenue St. Louis, MO 63101

Women’s Clinic 3615 Olive St.

St. Louis, MO 63108

St. Louis University Hospital 3635 Vista Ave St. Louis, MO 63110

Barnes-Jewish Hospital One Barnes-Jewish Hospital Plaza St. Louis, MO 63110

Missouri (MO) Veterans Home 10600 Lewis and Clark Blvd.

St. Louis, MO 63136

St. Joseph Hills Infirmary 400 Eagle Point Landing Drive Eureka, MO 63025

Missouri (MO) Veterans Home 620 North Jefferson Street St. James, MO 65559

John J. Pershing VA Medical Center 1500 North Westwood Blvd.

Poplar Bluff, MO 63901

VA Medical Center 2401 West Main Street Marion, IL 62959

Add on service – Service not pre-scheduled but provided to the contractor daily requiring a 45 minute response time or better. These are services which are needed after the scheduling deadline provided by hospital staff (i.e. emergency room runs, clinic add on appointments, transfers to or from other facilities, etc.) An add-on form will be completed by the driver and submitted to COR or designee (staff who requested the add-on) for signature/concurrence.

Administrative Officer of the Day (AOD) – VA employee that acts as the administrator during all hours that are other than normal working hours. Normal working hours are 8:00 a.m. to 4:30 p.m. Monday through Friday, excluding holidays.

Base Rate – Base rate is defined as the rate paid for one-way transportation for one (1) beneficiary from a designated pick-up point to a designated delivery point. This rate will be paid for all authorized one-way trips ordered under the contract action, with employees receiving at minimum the Department of Labor Service Contract Act wage rates (included herein), during all phases of the trip made on behalf of the Government. Attached Service Contract Act wage rate determinations will be updated each option year when/if new revisions are issued. The Base Rate shall constitute full compensation for one-way trips which do not exceed the “Mileage threshold”.

Beneficiary – Veterans and other members determined to be eligible for benefits by the VA.

Contracting Officer – VA official with the authority to enter into, administer, and/or terminate contracts and make related determinations and findings.

Contracting O ffic er’s Repr esentative (COR ) – A person delegated by the Contracting Officer to act for him/her in furnishing technical guidance and advice or generally supervise the work to be performed under the contract.

Gender – For the purpose of equal rights, wherever the masculine gender is used in this solicitation, and the resulting contract, it shall be considered to include both masculine and feminine gender.

Mileage Rate – Mileage rate for wheelchair van transportation services is the rate paid for each mile traveled beyond the specified Mileage Threshold. This rate applies to loaded, one-way transportation, as well as no load trips outside of the City limits of St. Louis, MO. In no event shall the Contractor receive this rate for miles traveled within the specified mileage threshold.

Mileage Threshold – The mileage threshold is defined as within the City Limits of the St. Louis, MO using the latest version of Microsoft Streets and Trips computer software. For all one-way trips and no loads within the City Limits of St. Louis, MO, the contractor will receive the flat rate awarded for that trip. The Contractor will also receive the mileage charge awarded for any one-way trips and no loads in excess of the flat rate outside the city limits of the St. Louis, MO.

In no event shall the Contractor receive reimbursement for mileage charge for any mileage inside the city limits of the St. Louis, MO. Mileage charges are only applicable outside the city limit radius of St. Louis, MO.

No service or no load charge – A no service mileage rate is applicable when a driver is dispatched to pick up a patient and for various possible reasons, the run is not completed, at no fault of the driver. A no service form will be completed by the driver and submitted to COR or designee (staff who approved the no-service) for signature/concurrence. When the VAMC travel office provides reasonable notification, a no load charge will not apply. Reasonable notification is defined as when the travel office notifies the contractor of cancellation within 30 minutes of the pickup time for trips within city limits and prior to driver departure for trips beyond the city limits.

Prorated trips – Any trip in which more than one veteran is transported by a single driver, allowing only the mileage to be claimed to the farthest destination of the run.

Excess Waiting/Waiting Grace Period – Excess Waiting as used in this contract is defined as the time required and verified by authorized medical facility personnel, for the Contractor to wait at designated pick-up and/or delivery points in performing contract services. Waiting will be charged in fifteen (15) minute increments. Waiting Grace Period – The waiting grace period is defined as fifteen (15) minutes prior to the time waiting charges commence. The base rate for medical transportation services shall include a fifteen (15) minute waiting grace period at origin and destination.

Special Mode Transportation - Special mode transportation as it pertains to this contract is considered a wheelchair van. A special modified, privately-owned vehicle, with special adaptive equipment and/or capable of transporting disabled persons is not a special mode of transportation for these purposes. The wheelchair van contract transportation services will transport patients who have been:

a. determined by a VA-clinician as having a medical condition that requires special mode wheelchair transport, and,

b. determined as administratively beneficiary travel eligible by the VA Mobility Manager or designee.

A. QUALIFICATIONS:

A.1. Proposals will be considered only from offerors who are regularly established in the business called for and who are financially responsible and have the necessary equipment and personnel to furnish service in the volume required for all the items under this contract.

Subcontracting of services shall not be authorized for the transportation of wheelchair patients without prior approval. Successful offeror shall meet all requirements of Federal, State, or City codes regarding operations of this type of service.

A.2 Offerors must submit with proposal a letter fully describing the following information:

REQUIRED SUBMISSIONS: The successful offeror shall submit the following information to the Contracting Officer prior to contract award and prior to exercise of any option to this contract:

(1) A letter fully describing the make of vehicle(s), model, year, and ID number vehicle(s) which the offeror intends to furnish under this proposal. The Contractor shall notify the Contracting Officer in writing of any vehicle(s) added, removed, or altered after award of contract.

(2) The letter shall include location and telephone number of offeror’s establishment where calls will be received and vehicle(s) will be available for dispatch.

(3) The letter shall also contain certain information as to the metering device or method offeror proposed to use in determining mileage.

(4) The offeror shall submit a copy of the current annual safety inspections, required by the

State of Missouri, for each vehicle.

(5) The offeror shall submit the completed General Inspection Checklist of each vehicle.

The inspections must be completed by a certified mechanic at any State (Missouri) licensed inspection facility. The offeror shall furnish proof of compliance to the Contracting Officer prior to award of contract. State vehicle inspection requirements shall not be accepted as sole certification of vehicle safety.

(6) Certificate of Insurance as described in statement of work, paragraph O.4.

A.3. MILEAGE: To determine what is considered reasonable mileage, VA will utilize the latest version of Microsoft Streets and Trips computer software, quickest route computations. Unless specifically approved by Travel for extenuating circumstances, requests for payment of mileage determined not reasonable by the VA will not be paid. Contractor must ensure that pickups and drop-offs are scheduled so that the total distance traveled will result in the most economical charges to the Government.

A.4. INSPECTION OF CONTRACTOR FACILITES/VEHICLES: The Government reserves the right to thoroughly inspect and investigate the facilities, vehicles, and business references, of any offeror and to reject any offer, irrespective of price, that shall be administratively determined to be lacking in any of the essentials necessary to ensure acceptable standards of performance.

B. PASSENGER TRANSPORTION:

B.1. Contractor shall provide wheelchair van service seven (7) days per week (including holidays), twenty-four (24) hours per day, three hundred sixty-five (365) days per year, for the term of this contract. The majority of requests for service will be between the hours of 6:00 a.m. and 6:00 p.m. Monday through Friday. The contractor shall provide the VA Medical Center with the method of contacting the Contractor on a twenty-four (24) hour per day basis.

Access into the John Cochran Division can be obtained through the wheelchair ramp and door access located at the Ambassador’s Suite on the south side of the building (facing Enright Ave.)

near the Emergency Room entrance. Access to the Jefferson Barracks Division shall be obtained through the wheelchair entrance at the main entrance to each building.

B.2. Transportation, as defined in this contract, shall include the driver escorting wheelchair patients from inside the Residence, Medical Center, or Nursing Home facility, to the vehicle, transporting the patient to delivery point and escorting the patient from the vehicle to the destination. The wheelchair patient shall be delivered to an authorized care giver or medical staff at the specified area and under no circumstances shall a patient be left unattended at any point. Wheelchair patients shall be escorted individually to and from the vehicle and under no circumstances shall a patient be permitted to push or attend to another patient. Hereafter, for the purpose of clarification, wherever the description “patient(s)” is used in this solicitation, it shall be considered to include wheelchair patient.

B.3. If a patient being transported declines to be properly belted or removes the securing devices himself, the driver will notify the COR or designee of this fact prior to departure or upon arrival at destination. The Contractor is not required to transport any VA patient who refuses to be properly secured while being transported.

B.4. Contractor shall provide “through the door” service for all patients to and from their designated appointments. Patients shall be picked up on the ward, in their homes, in the clinics, or at other areas designated by the VA and taken to the authorized destination or appointment.

All patients shall be attended by an authorized responsible party at all times. Assistance in maneuvering stairs and other barriers shall be provided by the driver and/or authorized attendant when necessary. When the patient is delivered to a destination (i.e., a clinic or other appointment), an authorized care giver or medical staff at the destination must be informed of the patient’s arrival by the Contractor’s driver or authorized attendant. Authorized attendants must be pre-approved by the Travel Clerk, to be reimbursed in accordance with the schedule.

B.5. The Contractor’s driver (or authorized attendant) shall observe the patient during transport. Any indication of a significant change in the patient’s condition (i.e., sudden onset of rapid or labored respiration, complaints or chest pains, etc.) shall be communicated immediately to the VA Medical Center Emergency Room staff, at (314) 289-6610. Diversion from destination shall only be authorized by the travel clerk, VA emergency room staff, or the Administrative Officer of the Day (AOD).

B.6. Should the Contractor’s driver encounter any problems with transporting of patients, the driver shall contact the Travel Clerk, John Cochran Division, at (314) 652-4100, extension 56415, during the hours of 8:00 a.m. to 4:30 p.m. During irregular tour of duty (4:30 p.m. to 8:00 a.m.), the driver shall contact the Administrative Officer of the Day (AOD) at

(314) 289-6412. VA will provide a list of individuals (other than the COR or designee) authorized to contact the Contractor.

B.7. Drivers shall notify the COR or designee, of any unusual events, including but not limited to accidents and/or safety problems that occur, which involve any VA patient being transported under this contract. The COR or designee shall be notified within one (1) hour of the occurrence of the incident(s) by telephone and a written report of the incident(s) will be delivered to the COR or his/her designee by close of business the next working day. Failure to comply with provisions may be grounds for termination (FAR 52.212-4(m).

B.8. When there is a need to transport medical records with the patient the Contractor’s driver will assure that the locked carrying pouch containing the records is secure and delivered with the patient to the destination.

B.9. RESTRICTIONS: The Contractor may not carry non-VA contract beneficiaries or private-pay patients with VA Beneficiaries under this contract. No beneficiary en-route in any transport shall be transferred from the original vehicle to another vehicle at a location other than the destination address supplied by the Travel Office, unless extraordinary, urgent need situations arise. All such events must be reported to the Travel Office. Drivers shall not make non-emergent stops for any reason, during any patient transport under this contract.

B.10. While transporting VA patients under this contract, only authorized drivers or attendants, or patient’s family member or representative shall be allowed in the vehicle.

C. DRIVERS AND AUTHORIZED ATTENDANTS:

All Contractor’s drivers and attendants shall be required to wear, in a readily observable area on the employee, a Contractor supplied photo identification badge containing the name of the driver or attendant, and the Contractor’s business name, or company uniform, that is acceptable to the Contracting Officer, which identifies the drivers and attendants while performing any aspect of service prescribed in this contract. Records of each employee as to character (criminal background check performed) and physical capabilities (Health Certificate or statement of health from a private physician) must be maintained and made available to the Contracting Officer upon request. Failure to comply with this provision may be grounds for termination (FAR 52.212-4(m).

C.1. All Contractor’s drivers and attendants shall have passed the American Red Cross First Aid Course and have on file a current certificate (renewable every three years) to be included with offeror’s technical proposal. During contract performance documentation must be made available to the Contracting Officer upon request.

C.2. All Contractor’s drivers and attendants shall have passed the American Red Cross Adult CPR course and have on file a current certificate (renewed annually). Copies shall be included with offeror’s technical proposal. During contract performance documentation must be made available to the Contracting Officer upon request.

C.3. All Contractor’s drivers and attendants shall have the physical capabilities to provide special assistance to the patients when transporting patients to the medical center, university hospital, private residence, nursing homes, etc. It is the driver’s responsibility to assess the special assistance needs of each patient, for which transportation has been requested, and to obtain approval from the Travel Clerk as to whether an attendant will be authorized for the specific trip.

Failure to comply with this provision may result in the driver or attendant being prohibited from performing any aspect of service prescribed by the contract. The Contracting Officer reserves the right to prohibit specific drivers from participating in the loading, transporting, and unloading of patients should it be determined the driver has engaged in unsafe practices. This determination will be at the sole discretion of the Contracting Officer and will be based upon documented evidence.

C.4. All drivers and attendants, prior to commencing work and thereafter on an annual basis, shall demonstrate to the VA Rehabilitation Medicine Service at the Jefferson Barracks Division, the individual ability to safely load and unload patients, and the proper techniques and procedures to be followed during transportation of patients. A driver or attendant demonstrating an inability to perform patient handling procedures will be required to obtain additional training.

If the Contractor is unable to secure training in the private sector, Rehabilitation Medicine Service, JB Division may provide the training at a cost of $50 per hour per physical therapist. It is estimated to be a one- (1) hour training program. Proof of such training will be made available to the Contracting Officer, and re-testing will be scheduled through Rehabilitation Medicine Service, JB Division. Failure to comply with this provision may be grounds for termination (FAR 52.212-4(m).

C.5. All Contractor’s drivers shall maintain a valid operator or chauffeur’s license, required to operate the type of vehicle necessary to perform the service, as required by the State of Missouri.

Copies to be included with offeror’s technical proposal for all drivers performing under this contract. During contract performance documentation must be made available upon request of the Contracting Officer.

C.7 The COR, or designee, may authorize a VA employee or family member other than the driver to accompany a patient at no additional charge incurred by the Government. This is an exception to CLIN 0015A, B, C, D and E.

D. VEHICLES:

D.1 Each vehicle shall be equipped at all times when transporting a patient in the performance of this contract with equipment as required by Federal, 49 CFR Parts 27, 37 and 38, Transportation for Individuals with Disabilities (most current volume), State and Local laws, ordinances, codes, rules or regulations and must have a minimum of the following:

D.2 The wheelchair van transport vehicle shall be of model and make to insure safe and comfortable transportation of wheelchair bound patients. Tie downs for wheelchairs are to consist of a leverage lock with a safety catch requiring physical unlatching. Locks shall be affixed to frame of vehicle.

Many types and styles of locks are acceptable. Any type or style offering complete patient safety that will prevent any motion of the wheelchair within the vehicle will be acceptable. Those considered lacking in this essential shall not be used for patient transport under this contract unless and until replaced with an acceptable tie down system. Seatbelts and shoulder harnesses shall be maintained in each vehicle in order to seat belt each passenger while in his/her wheelchair.

Additional transfer belts will be used at all times when loading and unloading passengers in wheelchairs. Each vehicle and all accessories and systems must be clean and shall meet all maintenance standards of the manufacturer. All preventive maintenance shall be documented, and records included in offeror’s technical proposal. Wheelchair vans must be designed so that patients are restrained by a seat belt at all times the vehicle is in motion.

D.3 Each vehicle shall contain a minimum of 1 (one) wheelchair in the event a prospective passenger does not own or have access to one for transportation purposes. At no time shall a patient be transported in a moving vehicle while seated on a motorized cart. Patients who are scheduled to be transported and are on a cart must sit in a standard wheelchair or vehicle seat and the cart must be secured in the vehicle.

D.4 The wheelchair vans provided under the terms of this contract shall be licensed and meet the minimum requirements as mandated by the State of Missouri. All vans shall be equipped with raised roofs to accommodate wheelchair patients. Raised roofs shall be of reinforced steel or have reinforcing steel beam. Clearance must accommodate an average patient sitting in a standard wheelchair without tilting the chair, i.e., average height of patient is considered by be 5’10” to 6’.

D.5 All wheelchair vans shall be equipped to allow for direct communication, at all times, between the drivers and staff of the VA Medical Center. This equipment may be mobile telephone, cellular telephone, or radio dispatch which would allow linking to the VA Medical Center by telephone.

Contractor shall provide any telephone numbers or special access codes or devices to Travel Section in order to comply with the provision for direct communication.

D.6 All wheelchair vans shall be equipped with a wheelchair lift or lowered floor ramp.

a. The wheelchair van with vehicle lift shall meet specifications as designated by 49 CFR Parts 27, 37, and 38. The wheelchair lift shall be equipped with the following:

(1) A safety bar or wheel catch secured to the outside perimeter of the lift to prevent the wheelchair from rolling off.

(2) The lift controls will be located in such a position that the operator can work the controls while keeping one hand on the wheelchair at all times.

(3) The lift shall operate in such a manner that when going up or down it will remain parallel with the ground.

(4) The lift shall be located as to receive the wheelchair and patient from the rear or passenger side of the vehicle.

(5) The lift shall have slip-proof surface.

(6) The lift shall have a minimum design load of 600 lbs.

(7) The lift must be a minimum of 28 inches.

b. All lowered floor ramp wheelchair vans shall be equipped with the following:

(1) Height at floor to ceiling at center of van must be 58 ¾”.

(2) Must have lowered floor from firewall to rear axle.

(3) ) Must have manual swing ramp with 30” usable width.

(4) Must have multiple wheelchair locations

(5) Must have ADA compliant interlock

(6) Must have ADA ramp and door entrance lighting

(7) Must have emergency rear hatch release

Use of the lowered floor ramp wheelchair van versus the raised roof wheelchair van will be determined by the contractor based on the individual needs of the VA patient.

D.7 All wheelchair vans shall be equipped with properly functioning heater and/or air conditioning, with adequate capacity to maintain the comfort level of the patient during transport. Contractor shall not place a vehicle into service of this contract that does not protect the patient from outside temperatures that are not suitable for the patient’s well being. Each vehicle shall contain a minimum of two (2) sanitary blankets. Failure to comply with the provision may be grounds for termination (FAR 52.212-4(m).

D.8 All wheelchair vans shall be equipped with secured fire extinguishers, first aid kits, and two

(2) flashlights that are readily available and operable for use in event of an emergency.

D.9 Each vehicle shall be equipped with flashing warning lights activated by the opening of loading doors and a properly functioning audible back up signal.

D.10 Wheelchair vans shall be well maintained in a clean and orderly condition.

Wheelchair vans must be free from physical damage; odor, debris and accumulation (which may constitute an accident or fire hazard).

D.11 All wheelchair vans shall be smoke free and provide the proper ventilation for the patient.

D.12 All wheelchair vans shall be maintained with a professional appearance that is representative of the services being performed on behalf of the Department of Veterans Affairs.

D.13 The Contracting Officer reserves the right to prohibit specific vehicles from being used to perform wheelchair patient transportation. This determination will be at the sole discretion of the

Contracting Officer and will be based on documented evidence.

E. MANTOUX TESTING:

E.1. Contractor must provide evidence of negative Purified Protein Derivative (PPD) test within fourteen (14) calendar days prior to employee beginning service. If an earlier PPD test was given over twelve (12) months previously, the current test shall be a 2-step Mantoux test.

E.2. Contractor must provide medical evidence that employee is disease free for those employees having a positive PPD.

E.3. Regular annual re-testing program for TB must be established and maintained for all contract employees that may be used in performance of this contract. Contractor must provide evidence of re-tests for each contract employee to the Contracting Officer within ten (10) calendar days of retest.

E.4. The Mantoux testing requirements apply to Contractor employees providing services during any absence from duty of scheduled employees for any reason.

E.5. In no circumstance will an employee be allowed to begin duty without prior submission of the required testing certification.

F. HEPATITIS B VACCINATION:

F.1. The employer shall make available the Hepatitis B vaccine and vaccination series within ten

(10) days of employment to all contract employees who have occupational risk and follow-up to all contract employees who have an exposure incident.

F.2. The Contractor shall bear all costs associated with vaccinations.

F.3. V A Form 10-5549c, Information about Hepatitis B Vaccine (Recombinant), Consent Form, or VA Form 10-5549d. Hepatitis B Vaccine Declination (Mandatory) shall be submitted to the Contracting Officer within thirty (30) days of waiver, or completion of the first in the series of the Hepatitis B Vaccine, and at completion of the vaccination series. These forms shall be provided to the contractor upon award of the contract.

G. JOINT COMMISSION FOR ACCREDITATION OF HEALTH CARE ORGANIZATIONS

(JCAHO) COMPETENCY REQUIREMENTS: The contractor shall be responsible to ensure that his/her employees coming to the work site shall receive the information required to perform their duties.

G.1. Contractor shall attend a pre-work orientation meeting prior to the commencement of work onsite. The VA shall schedule this meeting and it shall include discussion of the following topics: Fire and Safety, Infection Control and Disaster procedures.

G.2. Contractor shall be responsible to ensure his/her employees who are providing work on this contract are fully trained and completely competent to perform the required work.

H. INFECTION CONTROL COMPLIANCE: Contractor shall provide written certification of training to employees used in performance of this contract and Contractor compliance with the Blood Borne Pathogens Standards. 29 CFR Part 1910.1030 (copy available on request).

Certification must be received by the Contracting Officer prior to employee being assigned for duty.

H.1. The infection control compliance requirements apply to Contractor employees providing services during any absence from duty of scheduled employees for any reason.

H.2. In no circumstance will an employee be allowed to begin duty without prior submission of the required training certification.

H.3. 29 CFR part 1910.1030 is OSHA’s standard requiring employers to:

• Develop written exposure-control plans;

• Train all employees on occupational risks;

• Maintain records on employee training;

• Use warning labels;

• Implement proper work methods including “Universal Precautions”, (i.e.

proper care and disposal of personal protective equipment such as the use and disposal of latex gloves);

• Offer Hepatitis B Vaccine (HBV) to employees;

• Provide medical evaluations following employee’s exposure incident; and,

• Supply personal protective clothing and equipment (i.e., gloves and goggles

I. CONTRACT SECURITY

I.1 HIPAA COMPLIANCE:

a. As a covered entity, the Department of Veterans Affairs (VA) is required to by law to obtain satisfactory assurance of a Business Associate that the Business Associate appropriately safeguards protected health information it receives or creates on behalf of the covered entity.

Contractors and any subcontractors must adhere to the provisions of Public Law 104-191, Health Insurance Portability and Accountability Act (HIPAA) of 1996 to include the Administrative Simplification Provisions of the law and associated rules and regulations published by the Department of Health and Human Services (HHS). The Contractor shall comply with all HIPAA-related rules and regulations to include Electronic Transactions, the Standards of Privacy of Individually Identifiable Health Information and the Security Standards. This included both the Privacy and Security Rules published by the Department of Health and Human Services (HHS). As required by HIPAA, HHS has promulgated rules governing the use and disclosure of protected health information by covered entities. The covered entity component of the Department of Veterans Affairs is the Veterans Health Administration (VHA). In accordance with HIPAA, the Contractor may be required to enter into a Business Associate Agreement (BAS) with VHA. A sample template of this agreement is enclosed herein and identified as Attachment IV.

b. Business associates must follow VHA privacy policies and practices. All contractors and business associates must receive privacy training annually. For contractor and business associates who do not have access to VHA computer systems, this requirement is met by completing VHA National Privacy Policy training, other VHA approved privacy training or contractor furnished training that meets the requirement of HHS Standards for Privacy of Individually Identifiable Health information as determined by VHA. For contractors and business associates who are granted access to VHA computer systems, this requirement is met by completing VHA National Privacy Policy training or other VHA approved privacy training.

Proof of training is required.

c. Any violation of HIPAA will be reported to the Contracting Officer in writing within twenty-four (24) hours of the Contractor’s discovery of an occurrence. Included in the report will be a description of the occurrence, patient names (if known), location, date and time. A copy of any filed police report will be provided by the Contractor to the Contracting Officer within twenty-four (24) hours of completion.