36C26121Q0018 - PWS.pdf

PERFORMANCE WORK STATEMENT

EMERGENCY POWER SUPPLY SYSTEM SERVICE

VA SIERRA NEVADA HEALTH CARE SYSTEM

Part 1

General Information

1. General: This is a non-personnel services contract to provide Emergency Power Supply System (EPSS) Service.

The government shall not exercise any supervision or control over the contract service providers performing the services herein. Such contract service providers shall be accountable solely to the contractor who, in turn is responsible to the government.

1.1 Description of Services/Introduction: The contractor shall provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non-personal services necessary to perform 654-21- 6093-0001 EPSS Service as defined in this Performance Work Statement (PWS) except for those items specified as government furnished property and services. The contractor shall perform to the standards in this contract.

1.2 Background: The emergency generators, Automatic Transfer Switch (ATS)’s, and Uninterrupted Power Source (UPS)’s at the VA Sierra Nevada Health Care System (VASNHCS) is paramount to ensuring continued care for the patients in case of a power outage or disruption. Therefore, it’s imperative that the government maintains the generators, ATS’s, and UPS’s in accordance with (including, but not limited to) The Joint Commission (TJC), National Fire Protection Association (NFPA) 70, NFPA 99, NFPA 110, manufacturer’s, Federal, State, and local agencies standards and the most current editions of the publications. In addition to Veterans Health Administration (VHA) Directive 1028, Facility Electrical Power Systems.

1.3 Objectives: To ensure compliance with TJC Environment of Care Standards (EC.02.05.07, dtd 3-15-2020 (or most current version)), NFPA 70, NFPA 99, NFPA 110, manufacturer’s, Federal, State, and local agencies standards and the most current editions of the publications for the emergency generators and ATS’s, to include VHA Directive 1028.

Rationale for EC.02.05.07: Emergency EPSS may fail during a power disruption, leaving the hospital unable to deliver safe care, treatment, and services to patients. Testing these systems for sufficient lengths of time at regular frequencies increases the likelihood of detecting reliability problems and reduces the risk of losing this critical resource when it is most needed.

1.4 Scope:

1. Elements of Performance (EPs) for emergency generators and automatic and manual transfer switches: (Note: Due to ensuring that patient care is mitigated to the least impact, some of the tests and/or inspections will be done on a Saturday or before/after normal work hours.)

a. EP 4: WEEKLY – Every week, the hospital inspects the EPSS, including all associated components and batteries. The results and completion dates of the weekly inspections are documented.

i. Service is to be completed on the same day of the week, 52 times per year.

1. Note: If a holiday occurs on the day of testing or inspection, the service is to be completed the day before or after.

ii. For full text, refer to NFPA 110-2010: 8.3.1; 8.3.3; 8.3.4; 8.4.1 – or the most current edition.

iii. VASNHCS will provide test forms electronically that will be used for reporting.

b. EP 5: MONTHLY – Test each emergency generator beginning with a cold start under load for at least 30 continuous minutes. The cooldown period is not part of the 30 continuous minutes. The test results and completion dates are documented.

i. Service is to be completed once per month, same day of the same week, monthly (i.e, 3rd Wednesday of each month,12 times per year).

1. Note: If a holiday occurs on the day of testing or inspection, the service is to be completed the weekday before or after.

ii. For full text, refer to NFPA 99-2012, 6.4.4.1 – or the most current edition.

c. EP 6: MONTHLY – Diesel powered emergency generators are conducted with a dynamic load that is at least 30% of the nameplate rating of the generator or meets the manufacturer’s recommended prime movers’ exhaust gas temperature. If the hospital does not meet either 30% of nameplate rating or the recommended exhaust gas temperature during any test in EC.02.05.07, EP 5, then it must test the emergency generator once every 12 months using supplemental (dynamic or static) loads of 50% of nameplate rating for 30 minutes, followed by 75% of nameplate rating for 60 minutes, for a total of 1 ½ continuous hours.

i. Note: Tests for non-diesel-powered generators need only be conducted with available load.

ii. Service is to be completed once per month, same day of the same week monthly (i.e, 3rd Wednesday of each month,12 times per year).

1. Note: If a holiday occurs on the day of testing or inspection, the service is to be completed the weekday before or after.

iii. For full text, refer to NFPA 99-2012, 6.4.4.1 – or the most current edition.

d. EP 7: MONTHLY – Test all automatic and manual transfer switches on the inventory. The test results and completion dates are documented.

i. Service is to be completed once per month, same day of the same week monthly (i.e, 3rd Wednesday of each month,12 times per year).

1. Note: If a holiday occurs on the day of testing or inspection, the service is to be completed the day before or after.

ii. For full text, refer to NFPA 99-2012, 6.4.4.1 – or the most current edition.

e. EP 9: EVERY THREE YEARS – Test each emergency generator for a minimum of 4 continuous hours. The test results and completion dates are documented.

i. Service is to be completed every three years +/- 45 days from the last completed.

(i.e., April 15, 2017, no sooner than the 45 days prior to and no later than 45 days after April 15, 2020).

ii. For additional guidance, see NFPA 110-2010, Chapter 8 – or most current edition.

f. EP 10: EVERY THREE YEARS – The 36-month diesel-powered emergency generator test uses a dynamic or static load that is at least 30% of the nameplate rating of the generator or meets the manufacturer’s recommended prime mover’s exhaust gas temperature.

i. Service is to be completed every three years +/- 45 days from the last completed.

(i.e., April 15, 2017, no sooner than the 45 days prior to and no later than 45 days after April 15, 2020).

ii. Note: Tests for non-diesel-powered generators need only be conducted with available load.

iii. For additional guidance, see NFPA 110-2010, Chapter 8 – or most current edition.

2. Liebert NX (38SA120A0A00) UPS Battery Replacement and Testing/Inspection Requirements:

a. The batteries for UPS’s A & B will need to be replaced per the 5-year manufacturer’s requirement and as per the dates listed on pages 11-14.

i. UPS-A batteries will need to be replaced within 30 days of June 6, 2024

ii. UPS-B batteries will need to be replaced within 30 days February 28, 2025.

b. UPS A & B Semi-annual and Annual inspection requirements

i. EC.02.05.07/EP3 Requirements:

1. The hospital performs a functional test of Level 1 stored emergency power supply systems (SEPSS) on a monthly basis and performs a test of Level 2 SEPSS on a quarterly basis. Test duration is for five minutes or as specified for its class (whichever is less). The hospital performs an annual test at full load for 60% of the full duration of its class. The test results and completion dates are documented.

2. Semi-annual service/maintenance (the annual inspection/service/maintenance shall serve as the 2nd semi-annual requirement).

a. Service is to be performed during the 2nd week of April (annual) and October (semi-annual).

3. Qualifications of contractors

a. Contractors shall have the Engine Manufacture certification or equivalent training for the maintenance on the emergency generators, ATS’s, and UPS’s at VASNHCS, and completed the Occupational Safety & Health Administration (OSHA) approved 10-hour construction safety training.

b. Contractors shall have technical trainings and track records of working experience in maintenance, inspection, and testing of the Emergency EPSS and its components in healthcare, industrial, educational, and commercial facilities for a minimum of three continuous years.

c. Contractors shall have safety training, either on-the-job or class-room type in electrical safety outlined in the OSHA Standard 29 Code of Federal Regulations (CFR) 1910 Subpart S

- Electrical and the NFPA 70E - Standard for Electrical Safety in the Workplace. The contractor’s employees shall have a certified Electrical Contractor License for the state of Nevada. Training certifications shall be submitted to the Department of Veteran’s Affairs (VA) Contracting Officer (CO) prior to work. If no training certifications are available, the contractor shall certify that the service technician has met this requirement in writing and submit it to the VA CO prior to work.

d. Contractors shall demonstrate familiarity and have ready access to the latest versions of the following references:

i. NFPA 70, National Electrical Code.

ii. NFPA 70B, Recommended Practice for Electrical Equipment Maintenance.

iii. NFPA 70E, Standard for Electrical Safety for the Workplace.

iv. NFPA 110, Standard for Emergency and Standby Power System.

v. OSHA Standard 29 CFR 1910, Subparts I & S.

vi. Operating/Maintenance manuals and specifications of the emergency generators and all associated electrical equipment to be maintained and tested. These documents may be obtained from the VASNHCS, or the equipment manufacturers.

vii. VHA Directive 1028, Facility Electrical Power Systems.

e. Contractors must provide and shall be equipped with all the necessary tools, equipment, and personal protective equipment (PPE) to perform the work safely, effectively, and timely. Tools, equipment, and PPE shall comply with the requirements of OSHA Standard 29CFR 1910, Subpart I, and NFPA 70E/NFPA 110.

4. Scope of work

a. The contractor will provide all the necessary supervision, labor, tools, travel, equipment and materials to accomplish the emergency generator, ATS, and UPS maintenance on 10 generators, two portable generators, two DUV “Swat Bus”, 29 ATS’s*, and two UPS’s at the VASNHCS. Services include weekly and monthly inspections, annual service, 4-hour load bank testing (LBT) (Tri-annual), the annual load test, annual ATS test, and semi-annual/annual UPS test. Most testings will occur during normal work hours Monday-Friday with the exception of:

i. *Note (ATS): There will be 9 ATS’s that will require Saturday testing.

1. 2 Sat (0800-0830)

2. 4 Sat (0800-1100)

3. 3 Sat (1100-1400)

ii. *Note (ATS): There will be 6 ATS’s that will require before hours testing.

1. 4 (0530-0730)

2. 1 (0530-0731)

3. 1 (0530-0732)

b. The contractor must have at least two years of previous experience maintaining and repairing hospital generators in the Reno Nevada Area. Some maintenance and testing may occur outside of normal work hours, such as: starting with the patient care generators 4, 8, and 10, maintenance and testing will begin at 5:30 am the third Friday of the month. Frequency and days of service are noted in this PWS para 1.4, section 1a, 1b, 1c, 1d, 1e, and 1f. (Elements of Performance, EP4, EP5, EP6, EP7, EP9, & EP10)

c. The contractor shall have a 24-hour per day, 7-days per week, 365 days a year presence in the Reno area to be available for emergencies. The contractor shall be available to respond to emergency calls within 1-hour.

d. The contractor shall provide the following service, in intervals as recommended by the manufacturer and based on current equipment hours:

i. Replace the oil, oil filters, fuel filters, coolant, coolant filters, clean exterior of radiator, replace belts, check associated duct work and louvers and clean as necessary, check louver motors and controls and verify proper operation.

ii. Replace any leaking coolant gaskets, check block heater and repair any leaks.

iii. Check for correct thermostat operation, adjust as necessary, check and replace flexible fuel, coolant lines as necessary.

iv. Test for excessive back pressure on the exhaust system, check the exhaust system hangers and supports.

v. Check flexible exhaust section, tighten control and power wiring connections, check safeties and alarms for proper operation and calibration and notify as necessary.

vi. Calibrate all voltage sensing relays/devices, test generator wiring for insulation breakdown, replace air cleaner, replace governor oil, test injector pump and injectors for flow rate and/or spray pattern.

vii. Check and adjust valve clearances, torque head-bolts, clean and check brush length, notify as necessary.

viii. Check and clean rotor and stator, check and clean commutator and slip rings.

ix. Check bearings and notify as necessary, grease bearings, check and clean exciter and voltage regulator, megger (insulation tester) the windings and record the resistance readings.

x. Check water pumps for leaks, notify as necessary, check clean, and vacuum boxes, panels and cabinets.

xi. Clean and scrub down the prime mover with moist rags and a biodegradable detergent.

xii. Clean and scrub the concrete floor directly under the genset where accessible.

xiii. Maintain all batteries and associated chargers and controls.

e. Transfer switches shall be subjected to one major maintenance and three minor inspections per year.

i. Annual major maintenance to include:

1. Check connections

2. A thermograph or temperature scan shall be done under normal condition load prior to transfer. All wiring harnesses, circuit boards, feeder wires, transformers, circuit boards, relays, controllers, PLC’s, contacts, major mechanical components and any other internal components shall have a thermograph scan. This scan shall be repeated while the EPSS is under load in emergency position. Any temperature of components greater than 650C shall be documented and reported.

3. With power connected to the normal source, measure and record milli-volt drop across each pole. Any reading greater than 25% of the average of all the poles shall be inspected with the ATS de-energized.

4. With power connected to the emergency source, measure and record milli-volt drop across each pole. Any reading greater than 25% of the average of all the poles shall be inspected with the ATS de-energized.

5. With EPS in off position breakers between the EPS and the load terminals of the ATS shall be exercised.

6. The bypass isolation feature shall be operated between normal to emergency and back again. Refer to NFPA 110 A.8.3.5 (1)(D) for testing procedures of said feature.

7. Inspect or test for evidence of overheating or excessive contact corrosion.

8. Inspect insulating materials and/or standoff insulators for signs of contamination (i.e,. dirt, grime, oil). The combination of high humidity and moisture could lead to tracking and or breakdown of the insulating material.

Insulators are to be cleaned by an approved solvent and/or alcohol.

9. Inspect control connections, plugs, and harnesses for signs of corrosion, heat. contamination and so forth.

10. Remove all dust and debris in the ATS cabinet, transfer switch mechanism, bus and so forth.

11. Inspect cabinets for proper sealing. Knock out and penetrations in cabinet need to be sealed as well as appropriate gasketing to prevent the introduction of dust and debris.

12. Observe any other proper manufacturers procedure and/or recommendation.

13. Verify control and feature setpoints and operation

14. Measure and record the following data and setpoints:

a. Normal source voltage phase to phase, phase to ground and phase to neutral

b. Engine start time

c. Emergency source voltage phase to phase, phase to ground and phase to neutral

d. Total load current

e. Transfer time delay

f. Return to normal time delay

g. Engine cooldown

h. Verify proper setpoints of all values as recommended in NFPA 110

8.4.5

i. Verify proper operation of all indicator lights, meters, and controls.

f. All LBT shall include the buildings emergency load with additional loading from a load bank machine supplied by the contractor. All LBT shall be coordinated and confirmed with the Contracting Officers Representative (COR) of each division before starting the test. The contractor shall provide and connect or disconnect a temporary emergency generator whenever required to ensure emergency standby power at all times. This includes any scheduled maintenance that requires taking the generator off-line. The contractor shall not interrupt any electrical service without the consent of the COR. The contractor shall be responsible for correcting any incorrect information on the existing equipment list.

i. Monthly testing is performed with building load and remote load banking equipment.

ii. EP6 Annual and EP9 Tri-Annual are performed with remote load bank equipment only to avoid multiple transfer of ATS’s. The connected equipment must be connected so that if a loss of normal power occurs during testing, it will automatically disconnect so that the EPSS will function properly.

g. Liebert UPS A & B testings:

i. Tests shall include all manufacturer recommendations, but is not limited to:

1. For semi-annual service:

a. Equipment Readings:

i. I/O Frequency

ii. Input Volts L/L

iii. Input Volts L/N

iv. Input Current

v. Output Volts L/L

vi. Output Volts L/N

vii. Output Current

viii. Load Percent

ix. Input Filter

x. Output Filter

xi. Battery Voltage

b. Battery Cabinet:

i. Record Model #

ii. Serial #

iii. Strings

iv. Quantity of batteries in string

v. Battery type

vi. Battery date

vii. Recommended replacement date

c. Unit Testing:

i. Test all batteries with midtronics voltage and conductance test.

ii. Test battery string at 60% or greater.

iii. Provide battery test results.

iv. Perform visual and IR scan of UPS unit.

v. Inspect event/alarm logs, report all of concern.

vi. Ensure unit is working properly and online when complete.

2. For annual service:

a. Equipment Readings:

i. I/O Frequency

ii. Input Volts L/L

iii. Input Volts L/N

iv. Input Current

v. Output Volts L/L

vi. Output Volts L/N

vii. Output Current

viii. Load Percent

ix. Input Filter

x. Output Filter

b. Battery Cabinet:

i. Record Model #

ii. Serial #

iii. Strings

iv. Quantity of batteries in string

v. Battery type

vi. Battery date

vii. Recommended replacement date

c. Unit Testing:

i. Check event log and alarms, report any concerns.

ii. Test batteries under 60% or greater load. Report all warnings or failures.

iii. Test all battery string and provide report for each battery.

iv. Perform visual and IR scan inspection of entire unit.

v. Transfer unit to static by-pass, report results.

vi. Ensure unit is operating properly and online.

vii. Check air flow of room.

viii. Check and clean air filters, replace as necessary.

ix. Ensure room temperature is satisfactory.

x. Check time in unit.

xi. Report amount of transfers.

3. Other maintenance/service requirements:

a. Batteries shall be replaced when necessary due to failures and end of life requirement.

i. The batteries for UPS’s A & B will need to be replaced per the 5-year manufacturer’s requirement and as per the dates listed on pages 11-14.

1. UPS-A batteries will need to be replaced within 30 days of June 6, 2024

2. UPS-B batteries will need to be replaced within 30 days of February 28, 2025.

ii. Contractor/vendor shall include in their proposal all battery replacement cost to include battery, labor, and proper disposal of replaced batteries.

iii. Additionally, any materials required for testing or recommended for replacement during these services should be included.

5. Notification of environmental spills and damage

a. The contractor shall have in their possession, safety data sheets for every chemical item they bring on station.

b. The contractor shall properly dispose of all hazardous materials including, but not limited to all oils, coolant, fuels, filters, contaminated rags, and adsorbent, per the federal, state and local codes.

c. In the event the contractor spills or releases any un-permitted substance, hazardous substance, or hazardous waste into the environment, the contractor shall immediately report the incident to the contracting officer’s representative, fire department, and the local authority having jurisdiction. The contractor shall be liable for the costs of clean-up and remediation of any spill or release of such substance into the environment.

d. In the event the contractor damages any equipment or property, the contractor shall be held liable for the cost of repair and/or replacement.

6. Report requirements

a. Provide a comprehensive written report of the work completed.

b. Provide four hard three ring binders with all the oil test results, maintenance logs and load bank test sheets plus a CD.

c. The contractor will not have any access to a VA system or VA sensitive information.

7. Frequency documentation

a. Weekly = Same day of the week. 52 times per year. (If a holiday occurs on the day of testing or inspection, the service is to be completed the day before or after.)

b. Monthly = Once per month. Same day of the same week monthly (i.e, 3rd Wednesday of each month), 12 times per year. (If a holiday occurs on the day of testing or inspection, the service is to be completed the weekday before or after.)

c. Semi-annual = Twice a year +/- 20 days from the last completed. (i.e. October 15, 2017, April 15, 2017. No sooner than the 20 days prior to and no later than 20 days after the day of the month listed.)

d. Annual = Once per year, +/- 30 days from the last completed. (i.e, April 15, 2017. No sooner than 30 days prior to and no later than 30 days after April 15, 2018)

e. Tri-annual = 36 months/every 3 years. +/- 45 days from the last completed. (i.e, April 15, 2017. No sooner than the 45 days prior to and no later than 45 days after April 15, 2020)

8. Contractor and their employee(s) responsibility

a. The contractor shall abide by the rules of the station, which will be provided in the pre-work meeting.

i. Comply with all VASNHCS regulations at all times and conduct themselves in a professional manner.

1. This includes parking in the appropriate spaces. Parking in veteran and/or patient designated parking spaces is prohibited.

2. Smoking is not allowed on any part of the VASNHCS facility, to include the parking garage or outside areas.

ii. Proper badges (above the waist) and good behavioral conduct shall be mandatory. If badges are not immediately available, then the contractor must check-in to the VA Police to get a one-day pass that must be worn on the person at all times. Proper identification (Federal/State issued ID) is required for the badge. If the 24 hour period has expired, then the contractor must return to the VA Police office for another pass.

iii. VASNHCS may demand the contractor remove any persons who pose a threat to the health, safety, or security of the staff, customers, and/or property of VASNHCS.

b. The contractor and the COR shall be jointly responsible to track all additional charges and repairs that are not covered by this contract. A proposal will be required for any service/repair outside the scope of the contract prior to any work being completed.

c. The contractor and their employees will not be in any patient care spaces, therefore, a ***** and Security disclaimer is not required.

9. RECORDS MANAGEMENT DISCLAIMER:

a. RECORDS MANAGEMENT:

i. 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.

ii. 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.

1. The term Federal record:

a. includes VA records.

b. does not include personal materials.

c. applies to records created, received, or maintained by contractors pursuant to their VA contract.

d. may include deliverables and documentation associated with deliverables.

iii. Requirements:

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. Chapters. 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. The VA Sierra Nevada Health Care System (VASNHCS) 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 VASNHCS or destroyed except for 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.

5. In the event of any unlawful or accidental removal, defacing, alteration, or destruction of records, the contractor must report to VASNHCS. The agency must report promptly to NARA in accordance with 36 CFR 1230.

6. The contractor shall immediately notify the appropriate Contracting Officer (CO) 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 documents. 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 VASNHCS 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 CO or address prescribed in the contract documents. Destruction of records is EXPRESSLY PROHIBITED unless in accordance with Paragraph (4).

7. The contractor is required to obtain the CO'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 VASNHCS guidance for protecting sensitive, proprietary information, classified, and controlled unclassified information.

8. The contractor shall only use Government IT equipment for purposes specifically tied to or authorized by the contract and in accordance with VASNHCS policy.

9. The contractor shall not create or maintain any records containing any non-public VASNHCS information that are not specifically tied to or authorized by the contract.

10. 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 FOIA.

11. VASNHCS 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 VASNHCS 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.

12. 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.

13. Flow down of requirements to Subcontractors:

a. 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.

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