36C26322Q0448 SF1449 RADIATION PROTECTION SURVEY SERVICE.pdf

PAGE 1 OF 1. REQUISITION NO.

2. CONTRACT NO. 3. AWARD/EFFECTIVE DATE 4. ORDER NO. 5. SOLICITATION NUMBER 6. SOLICITATION ISSUE DATE

a. NAME b. TELEPHONE NO. (No Collect Calls) 8. OFFER DUE DATE/LOCAL

TIME

9. ISSUED BY CODE 10. THIS ACQUISITION IS UNRESTRICTED OR SET ASIDE: % FOR:

SMALL BUSINESS

HUBZONE SMALL

BUSINESS

SERVICE-DISABLED

VETERAN-OWNED

SMALL BUSINESS

WOMEN-OWNED SMALL BUSINESS

(WOSB) ELIGIBLE UNDER THE WOMEN-OWNED

SMALL BUSINESS PROGRAM

EDWOSB

8(A)

NAICS:

SIZE STANDARD:

11. DELIVERY FOR FOB DESTINA-

TION UNLESS BLOCK IS

MARKED

SEE SCHEDULE

12. DISCOUNT TERMS

13a. THIS CONTRACT IS A

RATED ORDER UNDER

DPAS (15 CFR 700)

13b. RATING

14. METHOD OF SOLICITATION

RFQ IFB RFP

15. DELIVER TO CODE 16. ADMINISTERED BY CODE

17a. CONTRACTOR/OFFEROR CODE FACILITY CODE 18a. PAYMENT WILL BE MADE BY CODE

TELEPHONE NO. DUNS: DUNS+4:

PHONE: FAX:

17b. CHECK IF REMITTANCE IS DIFFERENT AND PUT SUCH ADDRESS IN OFFER

18b. SUBMIT INVOICES TO ADDRESS SHOWN IN BLOCK 18a UNLESS BLOCK BELOW IS CHECKED

SEE ADDENDUM

19. 20. 21. 22. 23. 24.

ITEM NO. SCHEDULE OF SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE AMOUNT

(Use Reverse and/or Attach Additional Sheets as Necessary)

25. ACCOUNTING AND APPROPRIATION DATA 26. TOTAL AWARD AMOUNT (For Govt. Use Only)

27a. SOLICITATION INCORPORATES BY REFERENCE FAR 52.212-1, 52.212-4. FAR 52.212-3 AND 52.212-5 ARE ATTACHED. ADDENDA ARE ARE NOT ATTACHED.

27b. CONTRACT/PURCHASE ORDER INCORPORATES BY REFERENCE FAR 52.212-4. FAR 52.212-5 IS ATTACHED. ADDENDA ARE ARE NOT ATTACHED

28. CONTRACTOR IS REQUIRED TO SIGN THIS DOCUMENT AND RETURN _______________ 29. AWARD OF CONTRACT: REF. ___________________________________ OFFER COPIES TO ISSUING OFFICE. CONTRACTOR AGREES TO FURNISH AND DATED ________________________________. YOUR OFFER ON SOLICITATION DELIVER ALL ITEMS SET FORTH OR OTHERWISE IDENTIFIED ABOVE AND ON ANY (BLOCK 5), INCLUDING ANY ADDITIONS OR CHANGES WHICH ARE ADDITIONAL SHEETS SUBJECT TO THE TERMS AND CONDITIONS SPECIFIED SET FORTH HEREIN IS ACCEPTED AS TO ITEMS:

30a. SIGNATURE OF OFFEROR/CONTRACTOR 31a. UNITED STATES OF AMERICA (SIGNATURE OF CONTRACTING OFFICER)

30b. NAME AND TITLE OF SIGNER (TYPE OR PRINT) 30c. DATE SIGNED 31b. NAME OF CONTRACTING OFFICER (TYPE OR PRINT) 31c. DATE SIGNED

AUTHORIZED FOR LOCAL REPRODUCTION (REV. NOV 2021)

PREVIOUS EDITION IS NOT USABLE Prescribed by GSA - FAR (48 CFR) 53.212

7. FOR SOLICITATION

INFORMATION CALL:

STANDARD FORM 1449

SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES

OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24, & 30

636-22-3-2301-0258

36C26322Q0448 04-15-2022

John Becker 605-336-3230 04-29-2022

11:00 AM CDT

Department of Veterans Affairs

NETWORK 23 CONTRACTING OFFICE

2501 W. 22nd St.

Sioux Falls SD 57105 John Becker john.becker3@va.gov

X 100

X

541380

$16.5 Million

N/A

X

Nebraska Western Iowa Health Care System Omaha, Grand Island, Lincoln NE 4101 Woolworth Ave Omaha NE 68105

NETWORK 23 CONTRACTING OFFICE

2501 W. 22nd St.

Sioux Falls SD 57105

Tungsten Electronic Invoicing VA Tungsten Number: AAA544240062 Refer to VAAR Clause 852.232.72

877-353-9791 512-460-5540

See CONTINUATION Page

RADIATION PROTECTION SURVEY SERVICE to support the Nebraska Western Iowa Health Care System for the Omaha, Grand Island, and Lincoln NE VA Hospitals.

See Statement of Work and Price/Cost Schedule for specific requirements.

Period of Performance:

Base Period - 6/1/2022 to 5/31/2023 Option Period 1 - 6/1/2023 to 5/31/2024 Option Period 2 - 6/1/2024 to 5/31/2025 Option Period 3 - 6/1/2025 to 5/31/2026 Option Period 4 - 6/1/2026 to 5/31/2027 Options to be exercised at the Government's discretion.

Offeror shall verify exemption from the Department of Labor Service Contract Act. If not exempt, offeror shall immediately notify the Contracting Officer.

100% set-aside for Service Disabled Veteran Owned Business Offeror shall be listed as verified in the VIP database and the System for Award Management (SAM) at the time of submission of offer and prior to award.

Subcontracting limitations apply; maximum limit is 50%.

See CONTINUATION Page

636-3620160-2301-822200-2520-010055543 636-22-3-2301-0258

X X

X one(1)

John Becker

VA-VHA-2020-BEE57D1B

36C26322Q0448

Table of Contents

SECTION A

A.1 SF 1449 SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL PRODUCTS

AND COMMERCIAL SERVICES

SECTION B - CONTINUATION OF SF 1449 BLOCKS

B.1 CONTRACT ADMINISTRATION DATA

B.2 STATEMENT OF WORK

B.3 PRICE/COST SCHEDULE

SECTION C - CONTRACT CLAUSES

C.1 52.212-4 CONTRACT TERMS AND CONDITIONS—COMMERCIAL PRODUCTS

AND COMMERCIAL SERVICES (NOV 2021)

C.2 52.252-2 CLAUSES INCORPORATED BY REFERENCE (FEB 1998)

C.3 52.217-8 OPTION TO EXTEND SERVICES (NOV 1999)

C.4 52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000) ...33

C.5 52.223-99 ENSURING ADEQUATE COVID-19 SAFETY PROTOCOLS FOR

FEDERAL CONTRACTORS (OCT 2021) (DEVIATION)

C.6 SUPPLEMENTAL INSURANCE REQUIREMENTS

C.7 VAAR 852.211-72 TECHNICAL INDUSTRY STANDARDS (NOV 2018)

C.8 VAAR 852.212-70 PROVISIONS AND CLAUSES APPLICABLE TO VA

ACQUISITION OF COMMERCIAL ITEMS (APR 2020)

C.9 VAAR 852.219-74 LIMITATIONS ON SUBCONTRACTING—MONITORING AND

COMPLIANCE (JUL 2018)

C.10 VAAR 852.219-77 VA NOTICE OF LIMITATIONS ON SUBCONTRACTING—

CERTIFICATE OF COMPLIANCE FOR SERVICES AND CONSTRUCTION (SEP 2021)

(DEVIATION)

C.11 52.212-5 CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT

STATUTES OR EXECUTIVE ORDERS—COMMERCIAL ITEMS (JAN 2021) (JUL 2020)

(DEVIATION)

SECTION D - CONTRACT DOCUMENTS, EXHIBITS, OR ATTACHMENTS

ATTACHMENT 1: RECORDS MANAGEMENT OBLIGATIONS

ATTACHMENT 2: VAAR 852.219-77 VA NOTICE OF LIMITATIONS ON

SUBCONTRACTING

ATTACHMENT 3: VA HANDBOOK 6500.6 APPENDIX C – ACCESS TO VA

INFORMATION

ATTACHMENT 4: VA HANDBOOK 6500.6 APPENDIX D – CONTRACTOR RULES OF

BEHAVIOR

SECTION E - SOLICITATION PROVISIONS

E.1 52.212-1 INSTRUCTIONS TO OFFERORS—COMMERCIAL PRODUCTS AND

COMMERCIAL SERVICES (NOV 2021)

E.2 52.252-1 SOLICITATION PROVISIONS INCORPORATED BY REFERENCE (FEB

1998)

E.3 52.204-24 REPRESENTATION REGARDING CERTAIN TELECOMMUNICATIONS

AND VIDEO SURVEILLANCE SERVICES OR EQUIPMENT (NOV 2021)

E.4 52.216-1 TYPE OF CONTRACT (APR 1984)

E.5 52.233-2 SERVICE OF PROTEST (SEP 2006)

E.6 52.212-2 EVALUATION—COMMERCIAL PRODUCTS AND COMMERCIAL

SERVICES (NOV 2021)

E.7 52.212-3 OFFEROR REPRESENTATIONS AND CERTIFICATIONS—

COMMERCIAL ITEMS (FEB 2021) (JUL 2020) (DEVIATION)

SECTION B - CONTINUATION OF SF 1449 BLOCKS

B.1 CONTRACT ADMINISTRATION DATA

1. Contract Administration: All contract administration matters will be handled by the following individuals:

a. CONTRACTOR:

Business Name:

DUNS Number:

Contact Person:

Email:

Phone:

b. GOVERNMENT: Contracting Officer

Name: John Becker, Contracting Officer

Email: John.becker3@va.gov

Phone: 605-336-3230 ext 7960

2. CONTRACTOR REMITTANCE ADDRESS: All payments by the Government to the contractor will be made in accordance with:

[X] 52.232-33, Payment by Electronic Funds Transfer—System for Award Management

3. INVOICES: Invoices shall be submitted in arrears:

• Upon Completion of Work

• Contractor shall submit final invoice on any services performed no later than 30 days after end of the period of performance of the purchase order or contract. This ensures timely closeout of purchase orders and/or contracts.

4. GOVERNMENT INVOICE ADDRESS: All Invoices from the contractor shall be submitted electronically in accordance with VAAR Clause 852.232-72 Electronic Submission of Payment Requests.

Tungsten Electronic Invoicing VA Tungsten Number: AAA544240062 va.registration@tungsten-network.com Refer to VAAR Clause 852.232-72

5. INVOICING: All invoices from the contractor shall be submitted electronically in accordance with VAAR Clause 852.232-72 Electronic Submission of Payment Requests. VA’s Electronic Invoice Presentment and Payment System. The FSC uses a third-party contractor, Tungsten, to transition vendors from paper to electronic invoice submission. Please go to this website: http://www.tungsten-network.com/US/en/veterans-affairs/ to begin submitting electronic invoices, free of charge.

mailto:John.becker3@va.gov http://www.tungsten-network.com/US/en/veterans-affairs/

• Tungsten Network web link. Website: http://www.tungsten-network.com/customer-campaigns/veterans-affairs/

• Tungsten’s Email Assistance: VA.Registration@tungsten-network.com

• Tungsten’s Contact Phone: 1-877-489-6135 for support or 1-877-752-0900 for Client

Services.

• VA Financial Services Center is available at http://www.fsc.va.gov/einvoice.asp.

• VA FSC email: vafsccshd@va.gov

• VA FSC Contact Phone: 877-353-9791

6. VA ISSUED BADGE: Contract employees may be required to obtain a VA Identification

Badge. Determination of badging will be made by the VA Health Care System Technical Representative.

• Background investigations and special agreement checks: All contractor personnel are subject to the same level of investigation as VA employees who have access to VA Sensitive Information. The level of background investigation commensurate with the level of access needed to perform the statement of work is: National Agency Check (NAC). Contract employees may be required to submit fingerprints and undergo a background check.

• This requirement is applicable to all subcontractor personnel requiring the same access.

7. VHA Supplemental Contract Requirements for Combatting COVID-19.

a. Contractor employees who work in or travel to VHA locations must comply with the following:

(1) Documentation requirements:

(a) If fully vaccinated, shall show proof of vaccination

i. NOTE: Acceptable proof of vaccination includes a signed record of immunization from a health care provider or pharmacy, a copy of the COVID-19 Vaccination Record Card (CDC Form MLS-319813_r, published on September 3, 2020), or a copy of medical records documenting the vaccination

(2) If unvaccinated and granted a medical or religious exception, shall show negative COVID-19 test results dated within three calendar days prior to desired entry date.

Test must be approved by the Food and Drug Administration (FDA) for emergency use or full approval. This includes tests available by a doctor’s order or an FDA approved over-the-counter test.

(3) Documentation cited in this section shall be digitally or physically maintained on each contractor employee while in a VA facility and is subject to inspection prior to entry to VA facilities and after entry for spot inspections by Contracting Officer Representatives (CORs) or other hospital personnel.

(4) Documentation will not be collected by the VA; contractors shall, at all times, adhere to and ensure compliance with federal laws designed to protect contractor employee health information and personally identifiable information.

b. Contractor employees are subject to daily screening for COVID-19 and may be denied entry to VA facilities if they fail to pass screening protocols. As part of the screening process contractors may be asked screening questions found on the following website:

COVID-19 Screening Tool. Regularly check the website for updates.

(1) Contractor employees who work away from VA locations, but who will have direct patient contact with VA patients shall self-screen utilizing the COVID-19 Screening Tool, in advance each day that they will have direct patient contact and in accordance with their person or persons who coordinate COVID-19 workplace safety efforts at covered contractor workplaces. Contractors shall, at all times, adhere to http://www.tungsten-network.com/customer-campaigns/veterans-affairs/ http://www.tungsten-network.com/customer-campaigns/veterans-affairs/ mailto:VA.Registration@tungsten-network.com http://www.fsc.va.gov/einvoice.asp mailto:vafsccshd@va.gov https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.va.gov%2Fcovid19screen%2F&data=04%7C01%7C%7C180e5dd7385a45f5f9d008d98dcf9308%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C637696745032835994%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=RjM8G3wtcdUl2EgrU7ne4TYJ3m1ypptmAQYiJNIyqdE%3D&reserved=0 https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.va.gov%2Fcovid19screen%2F&data=04%7C01%7C%7C180e5dd7385a45f5f9d008d98dcf9308%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C637696745032835994%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=RjM8G3wtcdUl2EgrU7ne4TYJ3m1ypptmAQYiJNIyqdE%3D&reserved=0 https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.va.gov%2Fcovid19screen%2F&data=04%7C01%7C%7C180e5dd7385a45f5f9d008d98dcf9308%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C637696745032835994%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=RjM8G3wtcdUl2EgrU7ne4TYJ3m1ypptmAQYiJNIyqdE%3D&reserved=0 and ensure compliance with federal laws designed to protect contractor employee health information and personally identifiable information.

c. Contractor must immediately notify their COR or Contracting Officer if contract performance is jeopardized due to contractor employees being denied entry into VA Facilities.”

d. For indefinite delivery contracts: Contractor agrees to comply with VHA Supplemental Contract Requirements for any task or delivery orders issued prior to this modification when performance has already commenced.

8. CONTRACTOR ATTIRE AND IDENTIFICATION. The Contractor shall wear industry clothing that enables easy recognition as a “Contract Employee.” Clothing shall present a neat, distinctive appearance; shall be clean and maintained in good repair; and shall be worn as designed by the manufacturer. The Contractor shall wear appropriate clothing with logo identifying the contractor’s and employee’s name. The Contractor’s attire and presentation shall be appropriate per industry standard.

9. EMERGENCY PROCEDURES. The Contractor shall take such safety precautions as necessary to protect the lives and health of occupants of the buildings. The Contractor shall comply with applicable Federal, State, Local and facility safety and fire regulations and codes which are in effect at the beginning of the contract period. The Contractor shall keep abreast of and comply with changes in these regulations and codes applicable to the contract. The Contractor shall follow applicable facility policies concerning fire and/or disaster events. The Contractor shall display approved warning devices in all areas where operations may cause traffic obstruction or personnel hazard.

10. SERVICE CONTRACT LABOR STANDARDS REQUIREMENT, if applicable. Contractor shall provide hourly wages in accordance with U.S. Department of Labor (USDOL) Wage Determinations and FAR Subpart 22.10 (Service Contract Labor Standards); USDOL Wage Determinations are attached in Section D below. For guidance on Service Contract Labor Standards and to find the nearest USDOL resource, please refer to https://www.dol.gov/whd/local/index.htm.

11. VETS-4212 REPORTING REQUIREMENTS, if applicable. (for contracts awarded over

$150,000.00). Contractor shall complete VETS-4212 reporting in accordance with FAR requirements. Reference. Please refer to https://www.dol.gov/agencies/vets/programs/vets4212 for guidance on completing the required VETS-4212 report.

• FAR 52.222-35, Equal Opportunity for Veterans

• FAR 52.222-37, Employment Reports on Veterans

12. SERVICE CONTRACT REPORTING (for contracts awarded over $500,000.00), if applicable.

Service Contract reporting, to be completed by the contractor, is required for service contracts and orders as following are checked off under Section C, FAR 52.212-5 (Contract Terms and Conditions Required to Implement Statutes or Executive Orders--Commercial Items). The contractor shall report the information via the System for Award Management (SAM) at https://beta.sam.gov. The information is collected through SAM and included in the agency service contract inventory. Contractors shall log in annually to their SAM profile to complete the service contract inventory reporting requirements. Contractors performing on covered contracts must report their information between October 1 and October 31 each year. Agencies are required to review contractor input and work with them to make revisions, if and as necessary, by November 30 each year.

• FAR 52.204-14, Service Contract Reporting Requirement https://www.dol.gov/whd/local/index.htm https://www.dol.gov/agencies/vets/programs/vets4212 https://beta.sam.gov/

• FAR 52.204-15, Service Contract Reporting Requirements for Indefinite-Delivery Contracts (as applicable) Contractors shall log in annually to their SAM profile to complete the service contract inventory reporting requirements. Contractors performing on covered contracts must report their information between October 1 and October 31 each year. Agencies are required to review contractor input and work with them to make revisions, if and as necessary, by November 30 each year.

13. ACKNOWLEDGMENT OF AMENDMENTS: The offeror acknowledges receipt of amendments to the Solicitation numbered and dated as follows:

AMENDMENT NO DATE

B.2 STATEMENT OF WORK

RADIATION PROTECTION SURVEYS

Provide all tools, transportation, test equipment, and labor to perform initial, unscheduled, and annual testing of diagnostic imaging systems for Magnetic Resonance, Radiographic, Fluoroscopic, Computed Tomography, Positron Emission Tomography, SPECT and/or Planar Nuclear Medicine Imaging Equipment located at VA Nebraska Western Iowa Health Care System (VA NWIHCS) Medical Facilities located in Omaha, Lincoln and Grand Island, Nebraska. Vendor will not have access to ePHI except for working in a clinical area, where unavoidable, or as otherwise directed per contracted services and abiding by all related VHA requirements.

1. SCOPE OF WORK

The Contractor shall furnish all labor, material, supplies, equipment, and qualified personnel to provide on-site diagnostic medical physics support or services for the Veterans Health Administration (VHA), under the terms and conditions stated herein and must adhere to the most up to date version of applicable VHA publications such as, but not limited to:

1. VHA Directive 1105, Management of Radioactive Materials; (last updated February 24, 2021)

2. VHA Directive 1105.03, Mammography Program Procedures & Standards; (last updated May 21, 2018)

3. VHA Directive 1105.04, Fluoroscopy Safety; (last updated June 18, 2018)

4. VHA Directive 1105.05, Magnetic Resonance (MR) Safety; (last updated May 29, 2018)

5. VHA Directive 1129, Radiation Protection for Machine Sources of Ionizing Radiation; (last updated February 5, 2015) The Contractor shall comply with radiation protection standards in 29 CFR 1910.1096 and immediately report any unsafe conditions with the potential to adversely impact the facility radiation workers, patients or general-public, to the Radiation Safety Officer (RSO) as well as Biomedical Engineering.

1.1 Performance

All work shall be performed by a qualified diagnostic medical physicist. A qualified diagnostic medical physicist is a person who is certified by the American Board of Radiology (ABR), American Board of Medical Physics, the Canadian College of Physicists in Medicine, or as defined by the American College of Radiology (ACR) in lieu of board certification. For diagnostic Nuclear Medicine Imaging, work may also be performed by individuals board certified by the American Board of Science in Nuclear Medicine. For mammography, a qualified medical physicist must meet the training and experience requirements outlined in the Mammography Quality Standards Act (MQSA). For diagnostic Magnetic Resonance Imaging (MRI), a qualified medical physicist can meet the requirements for an MRI Scientist as defined by the American College of Radiology (ACR) in lieu of board certification. For diagnostic computed tomography (CT) a qualified medical physicist can meet the following requirements in lieu of board certification:

• A graduate degree in physics, medical physics, biophysics, radiation health physics, medical health physics, or a closely related science or engineering discipline from an accredited college or university.

• Formal graduate-level coursework in the biological sciences with at least one course in biology or radiation biology and one course in anatomy, physiology, or a similar topic related to the practice of medical physics.

• Documented experience in a clinical environment conducting at least 10 CT performance evaluations under the direct supervision of a board-certified medical physicist.

Medical physicists are accountable for equipment performance testing and evaluation. However, the qualified medical physicist may be assisted with the testing and evaluation of the equipment performance by individuals who have the required training and skills, as determined by the medical physicist. When nationally recognized accreditation bodies require the physical presence of the qualified medical physicist, that person must suffice all such requirements by being physically on-site for all required portions of equipment testing.

1.2 Mandatory Services to be Performed

a. The qualified diagnostic medical physicist shall perform imaging equipment (x-ray equipment, PET and/or nuclear medicine cameras, as well as MRIs) inspections to ensure compliance with the current American College of Radiology (ACR) and Mammography Quality Standards Act (MQSA) requirements. Any deficiencies or non-conformances discovered during the inspection shall be verbally communicated to the Biomedical Engineering Chief, Imaging service supervisor and/or RSO prior to the qualified diagnostic medical physicist leaving the facility. Deficiencies or non-conformances which represent unsafe conditions with the potential to adversely impact the facility radiation workers or patients shall be reported to the RSO immediately upon discovery.

A written report of the results shall be provided to the service supervisor and RSO within 20 working days after completion of the inspection. All imaging equipment (except ultrasound which is semi-annually) shall be inspected at least annually, not to exceed 14 months. Nuclear Medicine and PET cameras shall have evaluations performed semi-annually or per ACR requirements. Currently all equipment is due for annual inspection in September 2022.

b. The qualified diagnostic medical physicist shall perform acceptance testing of all new or relocated imaging equipment prior to first clinical use. The acceptance testing shall comply with ACR and/or MQSA requirements. Any deficiencies or non-conformances discovered during the inspection shall be verbally communicated to the service supervisor or RSO prior to the qualified diagnostic medical physicist leaving the facility. Deficiencies or non-conformances which represent unsafe conditions with the potential to adversely impact the facility radiation workers or patients shall be reported to the RSO immediately upon discovery. A written report of the results shall be provided to the service supervisor and RSO within 20 working days after completion of the inspection. It is anticipated that no more than 5 inspections of this type will need to be performed per year

c. The qualified diagnostic medical physicist shall perform a full inspection of imaging equipment after repairs or modifications that may affect the radiation output or image quality. The inspection shall be completed within 48 hours after the facility contacts the contractor. Any deficiencies or non-conformances discovered during the inspection shall be verbally communicated to the service supervisor or RSO prior to the qualified diagnostic medical physicist leaving the facility. Deficiencies or non-conformances which represent unsafe conditions with the potential to adversely impact the facility radiation workers or patients shall be reported to the RSO immediately upon discovery. A written report of the results shall be provided to the service supervisor and RSO within 20 working days after performing of the inspection. It is anticipated that no more than 5 inspections of this type will need to be performed per year

d. The qualified diagnostic medical physicist shall review CT protocols at least annually.

e. The qualified diagnostic medical physicist shall assist in the development of a comprehensive technical quality assurance (QA) program (e.g., technique charts, repeat/reject analysis monitoring, monitoring of exposure indices to radiographic image receptors, QA program for display monitors, QA for CT, monitoring of dose metrics from fluoroscopy studies), which complies with ACR recommendations, for all modalities. The qualified diagnostic medical physicist shall review at least annually the QA program. A written report of the results shall be provided to the service supervisor or RSO within 20 working days after performing of the inspection.

1.3 Shielding Evaluation, Survey and Reporting Designs to National Health Physics Program (NHPP)

a. The qualified diagnostic medical physicist, medical health physicist, or radiological physicist shall provide shielding design calculations for each new, replaced, or relocated x-ray imaging system.

The calculations and subsequent reports for each shall comply with the National Council for Radiation Protection and Measurements (NCRP) Report No. 147, and, for dental units, NCRP Report No. 145. The reports shall be documented in written form which includes a diagram showing adjacent areas. The qualified diagnostic medical physicist, medical health physicist, or radiological physicist shall perform a shielding survey to verify the structural shielding was installed per the shielding design report and complies with the design goals. If not performed by the RSO, a written report of the shielding survey shall be provided to the RSO within 20 workings days after the shielding survey has been completed. It is anticipated that no more than 5 inspections of this type will need to be performed per year.

b. If applicable, the qualified diagnostic medical physicist, medical health physicist, or radiological physicist shall perform a follow-up inspection to verify compliance of any necessary corrective action performed to correct deficiencies found.

c. The qualified diagnostic medical physicist, medical health physicist, or radiological physicist shall provide consultation for additional services as needed (i.e., safety training).

1.4 Contract Period: See Price/Cost Schedule.

2. EQUIPMENT INSPECTIONS

2.1. The Contractor shall conduct equipment inspections or quality control surveys of the imaging equipment listed in Statement of Work Attachment 1, Imaging Equipment.

2.2. The equipment list includes current manufacturer and model. Over the life of this contract some units will be replaced, but the basic function of each device should not.

2.3. Compliance with Relevant Professional Guidance Documents and Technical Standards. The Contractor shall ensure the imaging equipment’s compliance with applicable Federal regulations and ACR recommendations, and shall include, but not be limited to, monitoring the following basic performance characteristics.

A. Radiographic and Fluoroscopic Equipment

Physics inspections of radiographic and fluoroscopic equipment shall comply with the ACR Technical Standard for Diagnostic Medical Physics Performance Monitoring of Radiographic and Fluoroscopic Equipment. The performance of each radiographic and fluoroscopic unit must be evaluated at least annually. This evaluation should include, but not be limited to, the following tests (as applicable).

(1) Integrity of unit assembly.

(2) Collimation and radiation beam alignment.

(3) Fluoroscopic system spatial resolution.

(4) Automatic exposure control system performance.

(5) Fluoroscopic automatic brightness control performance (high-dose-rate, pulsed modes, field-of-view [FOV] variation).

(6) Image artifacts.

(7) Fluoroscopic phantom image quality.

(8) kVp accuracy and reproducibility.

(9) Linearity of exposure versus mA or mAs.

(10) Exposure reproducibility.

(11) Timer accuracy.

(12) Beam quality assessment (half-value layer).

(13) Fluoroscopic entrance exposure rate (or air kerma rate). Maximum output and output using a phantom representing a standard size patient for all clinically used settings. [The mode of operation [e.g., magnification mode, frame rate, and any other mode selected) must be documented for each measurement.]

(14) Fluorographic (image recording) entrance exposure rate (or air kerma rate) for cine imaging, if performed and entrance exposure (or air kerma) for spot images (if performed).

Maximum output and output using a phantom representing a standard size patient for all clinically used settings. [The mode of operation (e.g., magnification mode, frame rate, etc.)

must be documented for each measurement.]

(15) Image receptor entrance exposure.

(16) Equipment radiation safety functions.

(17) Patient dose monitoring system calibration. This includes, for radiographic systems, the metric of dose to the image receptor (IEC Exposure Index or proprietary index) and, for fluoroscopy systems, the displays of cumulative air kerma and, if available, DAP.

(18) Display monitor performance.

(19) Digital image receptor performance.

(20) Grids used with portable x-ray units shall be imaged for uniformity.

(21) For radiographic units, measurement of entrance skin exposure (or air kerma) for a standard size patient for common radiographic projections and comparison to published diagnostic reference levels and achievable doses (e.g., ACR practice parameter).

Note: The information on entrance exposure rates (or air kerma rates) from fluoroscopy and from fluorography, in Items (13) and (14) above, for each fluoroscope, shall be in a format suitable for providing to the physicians who operate the fluoroscope.

B. Computed Radiography (CR) and Digital Radiography (DR) Physics inspections of CR and DR equipment shall comply with the American Association of Physicist in Medicine (AAPM) Report Number 93, Acceptance Testing and Quality Control of Photostimulable Storage Phosphor Imaging Systems. The performance of CR and DR must be evaluated at least annually. This evaluation should include, but not be limited to, the following tests (as applicable).

(1) Component and imaging plate physical inspection and inventory.

(2) Imaging plate dark noise and uniformity.

(3) Exposure indicator calibration.

(4) Linearity and auto-ranging response.

(5) Laser beam function.

(6) Limiting resolution and resolution uniformity.

(7) Noise and low-contrast resolution.

(8) Spatial A\accuracy.

(9) Erasure thoroughness.

(10) Aliasing/grid response.

(11) IP throughput.

(12) Positioning and collimation errors.

C. CT Scanners The physics inspection shall conform to the most current ACR Computed Tomography Quality Control Manual and requirements of The Joint Commission, at the time of the test. The performance of each CT scanner shall be evaluated at least annually. This evaluation should include, but not be limited to, the following tests (as applicable).

(1) Review of clinical protocols

(2) Scout prescription and alignment light accuracy

(3) Image thickness – axial mode

(4) Table travel accuracy

(5) Radiation beam width

(6) High-contrast resolution

(7) Low-contrast resolution

(8) Spatial resolution

(9) CT number accuracy

(10) Artifact evaluation

(11) CT number uniformity/imagine uniformity

(12) Geometric or distance accuracy

(13) Slice thickness accuracy

(14) Slice position accuracy (when prescribed from a scout image)

(15) Dosimetry (the scanner displayed CTDIvol values must be within +/- 20% of the measured

CTDIvol values).

(16) Gray level performance of CT acquisition display monitors.

D. Dental The physics inspection shall conform to the Conference of Radiation Control Program Directors (CRCPD), Quality Control Recommendations for Diagnostic Radiography Volume 1 Dental Facilities July 2001. The performance of dental x-ray inspections shall be at least every 2 years.

This evaluation should include, but not be limited to, the following tests (as applicable).

(1) Collimation.

(2) Beam quality (half value layer).

(3) Timer accuracy and reproducibility.

(4) kVp accuracy and reproducibility.

(5) mA or mAs linearity.

(6) Exposure reproducibility.

(7) Entrance skin exposure evaluation, with comparison to published diagnostic reference levels and achievable doses (e.g., NCRP Report No. 172).

(8) Technique chart evaluation.

(9) Image uniformity (artifact evaluation).

Dental CBCT Acceptance and Performance Testing

a. Acceptance Testing. Acceptance testing and measurements of air kerma at the isocenter for each kVp station for a range of clinically used mAs settings will performed initially when the CBCT unit is installed and following any move of the CBCT to another area inside or outside the initial clinical site. This testing is to ensure that the equipment performance agrees with the manufacturer’s technical specifications.

b. Performance Testing. Each CBCT unit shall undergo periodic quality control tests to ensure that the performance of the machine has not significantly deteriorated and is operating within the manufacturer’s technical specifications. This performance testing is performed by a qualified expert annually, at intervals not to exceed 14 months, and after repairs to the CBCT unit that may affect the radiation output or image quality.

c. Some manufacturers provide a phantom and procedures to perform machine specific quality assurance (QA) tests. In cases where the manufacturer provides a phantom and procedures to perform specific tests, but the tests are not included in this SOW, then the manufacturer’s machine-specific QA tests shall be performed in addition to the QA tests in this SOW.

Dental CBCT Acceptance and Annual Physics Testing

a. Radiation output Repeatability Make four measurements of the air kerma at the isocenter at a clinically used setting.

The measurements should be less than +/-5% of the average of the five measurements and the measurements should be less than +/- 5% of the previous year’s measurement.

b. Radiation Output Reproducibility Measure the air kerma at the isocenter for each kVp station and a range of clinically used mAs setting. Compare the results to the baseline values established at the initial acceptance testing. The values should be +/-5% of the baseline.

c. kVp Accuracy Measure the kVp at all clinically used settings. The measured kVp should be +/-5% of the selected kVp.

d. kVp Repeatability Make five kVp measurements each for two clinically used kVp settings. All measured values should be +/-5% of the mean kVp.

e. kVp Reproducibility Measure the kVp at all available kVp settings. The measured values should be +/-5% of the baseline.

f. Beam quality Measure the half value layer (HVL) for aluminum. The minimum shall comply with Section F.4.d of the Suggested State Regulations for Control of Radiation, Conference of Radiation Control Program Directors.

g. Radiation field of view (FOV) Measure the width of the radiation field at the isocenter. The width of the beam should be 3 mm or 30% of the total nominal collimated width.

h. Image Quality Image the phantom provided by the manufacturer or another suitable phantom. Assess high contrast spatial resolution, uniformity of trans axial images, and image noise.

Imaging uniformity shall be assessed over the entire range of axial images.

i. Accuracy of Linear Measurements Using images of an appropriate phantom, assess the accuracy of distance measurements.

j. Accuracy of Patient Dose Metric Indication Assess the accuracy of the indicated dose metric (typically DAP).

k. Patient Dose Assessment From a scan or scans using the facility’s standard techniques, record the dose metric (typically DAP) and compare to achievable levels and diagnostic reference levels (if available)

l. Review of the technical QA program The qualified expert shall review the technical QA program. The review shall include a trend analysis of the QA data. The results of the technical QA program review shall be included in the written report. Any trends that identify problems shall be included in the report along with recommended corrective actions.

m. Display Monitors Perform a visual analysis of the SMPTE test pattern.

1. Display the test pattern on the imaging console. Set the display window width/level to the manufacturer-specified values for the pattern. Do not set the window/level by eye; doing so invalidates the procedure.

2. Examine the pattern to confirm that the gray level display in the imaging console is subjectively correct.

i. Review the line pair patterns in the center and at each of the corners.

ii. Review the black-white transition.

iii. Look for any evidence of “scalloping” (loss of bit depth) or geometric distortion.

3. Use a photometer to measure the maximum and minimum monitor brightness (0% and 100% steps)

4. Measure additional steps within the pattern to establish a response curve.

5. Measure the brightness near the center of the monitor and near all 4 corners (or all

4 sides, depending on the test pattern used).

n. Viewing Conditions

Assess the viewing conditions for the area in which the monitor used to evaluation the CBCT studies is located.

E. Mammography The qualified diagnostic medical physicist inspecting mammography equipment must meet the qualifications outlined in the MQSA and shall provide the facility with up-to-date documentation demonstrating the qualified diagnostic medical physicist is MQSA qualified. Inspections of mammography equipment must comply with the latest requirements posted on the ACR Web site for the manufacturer of the digital mammography unit being inspected. Inspection items may include:

(1) Mammographic Unit Assembly Evaluation.

(2) Collimation assessment.

(3) Artifact evaluation.

(4) kVp accuracy and reproducibility.

(5) Beam quality assessment – HVL measurements.

(6) Evaluation of system resolution.

(7) Automatic Exposure Control (AEC) function performance .

(8) Breast entrance exposure, AEC reproducibility, and average glandular dose.

(9) Radiation output rate.

(10) Phantom image quality evaluation.

(11) Signal–to–noise ratio and contrast–to noise ratio measurements.

(12) View box luminance and room illuminance.

(13) Review Workstation (RWS) tests.

F. MRI

The physics inspection shall conform to the 2015 ACR Magnetic Resonance Imaging Quality Control Manual and requirements of The Joint Commission. The performance of each MRI scanner shall be evaluated at least annually. This evaluation should include, but not be limited to, the following tests (as applicable).

(1) Magnetic field homogeneity

(2) Slice position accuracy

(3) Slice thickness accuracy

(4) RF coil performance.

(a) Volume coil tests (including but not limited to image uniformity and signal-to-ratio for all coils used clinically)

(b) RF array coil tests (including but not limited to image uniformity and signal-to-ratio for all coils used clinically)

(c) Surface coil tests (including but not limited to image uniformity and signal-to-ratio for all coils used clinically)

(5) Soft-copy quality control

(6) Alignment light accuracy

(7) High-contrast resolution

(8) Low-contrast resolution

(9) Geometric or distance accuracy

(10) Artifact evaluation

(11) MR Safety Program Assessment

G. PET

The physics inspection shall conform to the ACR PET Phantom Instructions for Evaluation of PET Images, ACR Nuclear Medicine Accreditation Program PET Module. The performance of each PET scanner shall be evaluated at least semi-annually and preferably quarterly. For PET/CT units the CT must be inspected at least annually per Item C above. This evaluation should include, but not be limited to, the following tests (as applicable).

(1) Imaging uniformity/system uniformity

(2) High-contrast resolution/system spatial resolution

(3) Low-contrast resolution

(4) Artifact evaluation

(3) SUV analysis

H. Nuclear Medicine The physics inspection shall conform to the ACR annual performance tests for nuclear medicine cameras and the requirements for The Joint Commission. The qualified diagnostic medical physics shall also perform the quarterly testing as outlined by the ACR. The performance of each nuclear medicine scanner shall be at least semi-annually and preferably quarterly. This evaluation should include, but not be limited to, the following tests (as applicable).

(1) Image uniformity/system uniformity

(2) High-contrast resolution/system spatial resolution

(3) Artifact evaluation

(4) Intrinsic uniformity

(5) Relative sensitivity

(6) Energy resolution

(7) Count-rate performance

(7) Formatter/video display

(8) Overall system performance for SPECT

(9) System interlocks

(10) Dose calibrators (Geometry, if applicable, Accuracy)

(11) Thyroid uptake and counting systems

J. Display Monitors The annual performance evaluation conducted by the diagnostic medical physicist includes testing of image acquisition display monitors for maximum and minimum luminance, luminance uniformity, resolution, and spatial accuracy. The image acquisition display monitors for nuclear medicine, PET, CT, and MRI units shall be tested.

3. Definitions/Acronyms:

3.1. NWIHCS - Nebraska Western Iowa Health Care System. Consists of 3 main campuses: Omaha Campus - 4101 Woolworth Ave, Omaha, NE 68105 (phi 402.995.3040); Grand Island Campus - 2201 N Broadwell Ave, Grand Island, NE 68803 (308-382-3660 ext 2491); and Lincoln Campus – 420 Victory Park Drive, Lincoln, NE 68510 (ph 402.489.3802 ext 6437)

3.2. CO – Contracting Officer, VA Omaha/Purchasing and Contracting Division, Bldg 6, Room 103, telephone number 402 346-8800 ext 4505.

3.3. COR – Contracting Officer’s Representative.

3.4. IAW – In Accordance With

3.5. 21 CFR 803.3 – Code of Federal Regulations, Title 21, Chapter 803

3.6. 38 USC 7301 – United States Code, Title 38, Chapter 73

3.7. ESR – Vendor Engineering Service Report. A documentation of the services rendered for each incidence of work performance under the terms and conditions of the contract.

3.8. HHS – Health and Human Services.

3.9. BESS — Biomedical Equipment Support Specialist. VA employee responsible vendor coordination of survey for VA owned medical equipment.

3.10. TJC – The Joint Commission. A nationally recognized hospital accreditation organization.

3.11. ACR – American College of Radiology. A nationally recognized diagnostic imaging accreditation organization.

3.12. NCRP – National Council on Radiation Protection. A national agency tasked with developing standards for the safe use of ionizing radiation.

3.13. ABSNM – The American Board of Science in Nuclear Medicine. A nationally recognized physics board certification.

3.14. ABHP – The American Board of Health Physics. A nationally recognized physics board certification.

3.15. ABR – The American Board of Radiology. A nationally recognized physics board certification.

3.16. ABMP – The American Board of Medical Physicists. A nationally recognized physics board certification.

3.17. AAPM – American Association of Physicists in Medicine. A nationally recognized physics society.

3.18. CHP – Certified Health Physicist

3.19. QMP – Qualified Medical Physicist

3.20. MHP – Medical Health Physicist

4. Conformance Standards:

4.1. Contract service shall ensure that the equipment functions within manufacturer’s specifications and must operate within manufacturer’s specified parameters. All contract service shall be in conformance with pertinent aspects of:

a) 38 U.S.C. § 7301(b).

b) 10 C.F.R. 1208(a), 20.1208, 20.1301, 20.2003, and 35.75.

c) 21 C.F.R. 803.3.

d) 29 C.F.R. 1910.1096

e) Federal Guidance Report No. 14, Radiation Protection Guidance for Diagnostic and

Interventional X-Ray Procedures, dated November 2014.

f) VHA Directive 1105, Management of Radioactive Materials,

g) VHA Directive 1105.03, Mammography Program Procedures & Standards,

h) VHA Directive 1105.04, Fluoroscopy Safety,

i) VHA Directive 1105.05, Magnetic Resonance (MR) Safety,

j) VHA Directive 1129, Radiation Protection for Machine Sources of Ionizing Radiation,

k) VHA Directive 1200.01, Research and Development Committee,

l) Conference of Radiation Control Program Director’s (CRCPD) Suggested State Regulations for

Control of Radiation, Part F, Diagnostic X-rays, and Imaging Systems in the Healing Arts,

m) National Council on Radiation Protection and Measurements Report Number 145, Radiation

Protection in Dentistry, and

n) National Council on Radiation Protection and Measurements Report Number 147, Structural

Shielding Design for Medical X-Ray Imaging Facilities.

5. Hours of Coverage:

5.1. All surveys will normally need to be performed after 1400 hours on normal business days (M-F), or on weekends/Federal Holidays due to the high use of this patient care equipment.

5.2. Federal holidays observed by VANWIHCS are:

New Year’s Day Labor Day Martin Luther King Day Columbus Day President’s Day Veteran’s Day Memorial Day Juneteenth

Thanksgiving Day Independence Day Christmas Day Any other day specifically designated by the President of the United States.

6. Documentation/Reports:

6.1. Formal documentation (no hand-drawn diagrams; professional generated with scale information) should follow relevant professional guidance documents such as the AAPM, ACR, or NCRP and shall include, but is not limited to:

a) Name of Facility

b) Physical Address

c) Date of testing

d) Date of Report

e) Room Number

f) Equipment manufacturer and model where appropriate

g) Equipment identification number as specified by Biomedical Engineering

h) Name of persons present on site during time of equipment testing

i) Name of reviewer(s)

j) Reports involving calculations should show all methods and assumptions per professional standards

k) Room and/or equipment drawings should be to scale

l) Room drawings should identify “North” on the drawing

m) Manufacturer, model, serial number and calibration due dates of test equipment used

n) A physical or electronic signature of the persons completing the documentation and person responsible for oversight if applicable. Electronic signature shall be in the form of an industry recognized e-signature.

6.2. Any additional charges claimed will be approved by the CO via the COR before service is completed.

7. Reporting Requirements:

7.1. Upon arrival at VA Omaha the contractor shall be required to log in with Biomed in room B556 for Omaha, room C09 for Grand Island, and room 1902 for Lincoln. This log in is mandatory as well as wearing the contractor badge issued upon log in. Contractor personnel shall always wear visible identification while on the premises of the VA. Identification shall include, as a minimum, the employee’s name, position, and the contractor’s trade name. In addition, the contractor shall submit fingerprints through the VA police for issuance of a VA identification badge that shall be worn at all time while working at a VA facility.

8. Services Beyond the Contract Scope:

8.1. Contractor shall immediately, but not later than 24 consecutive hours after discovery, notify the CO and COR, (in writing), of the existence of the development of any defects in, or repairs required to, the scheduled equipment which the contractor considers he/she is not responsible for under the terms of the contract.

9. Test Equipment:

9.1. Test equipment calibration shall be traceable to National Institutes of Standard Technology standards. All reports shall include test equipment used, serial number and calibration date.

10. Identification, Parking, Smoking, and VA Regulations:

10.1. Contractor’s staff shall always wear visible identification while on the premises of the VA.

Identification shall include, as a minimum, the employee’s name, position, and the contractor’s trade name. In addition, the contractor shall complete requirements for assigned staff to obtain VA PIV cards, so they have physical access privileges on VA property.

10.2. It is the responsibility of the contractor to park in the appropriate designated parking areas.

Information on parking is available from VA Police Service. VA will not invalidate or make reimbursement for parking violations of the contractor under any conditions.

10.3. Smoking is prohibited inside all VA buildings.

10.4. Possession of weapons is prohibited. Enclosed containers, including tool kits, shall be subject to search.

10.5. Violations of VA regulations may result in citation answerable in the United States (Federal) District Court, not a local district, state, or municipal court.

11. Contractor Qualifications: The contractor must submit documentation proving the person who is performing the inspection (s) is qualified as per requirements in this statement of work.

12. Quality Assurance Surveillance Plan

Performance Objective SOW Para Performance Threshold Scheduled Inspections 7.1 No more than 1 COR write-up per quarter.

Repeat complaints/ discrepancies for the same area/ facility will result in an unacceptable rating for the month.

Reporting Requirements 11.2 No more than 1 COR write-up per quarter.

Repeat complaints/ discrepancies for the same area/ facility will result in an unacceptable rating for the month.

Test Equipment 14.1 No more than 1 COR write-up per quarter.

Repeat complaints/ discrepancies for the same area/ facility will result in an unacceptable rating for the month.

ATTACHMENT 1: IMAGING EQUIPMENT LISTING

# Asset Description Mfg. Name Model Serial # Location

1 357508

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F9807 NE101-001-GI

2 357514

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F9809 NE103-001-GI

3 357241

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F10333 122-6-OM

4 357231

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F10330 126-6-OM

5 357246

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F9810 121-6-OM

6 357236

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F10334 125-6-OM

7 357518

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F10242 NE110-001-GI

8 357504

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F10325 NE101-001-GI

9 357267

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F10327 124-6-OM

10 360522

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F14060 112-6-OM

11 361792

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F14621 NE112-001-GI

12 360517

RADIOGRAPHIC UNITS: DENTAL,

FOCUS

Instrumentarium Dental Inc FOCUS F14061 113-6-OM

13 361797

RADIOGRAP…