Amendment 0002 - Attachment 2 - 852.204-72.pdf

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Attached to
Y1DA--518-22-700 EHRM Infrastructure Upgrades Construction Bedford VAMC
Solicitation number
36C77626R0003
Issued by

About this file

This is a federal contracting clause—VAAR 852.204-72 Personnel Vetting and Credentialing (effective March 2026)—that establishes mandatory background investigation and security requirements for contractor personnel working with the Department of Veterans Affairs (VA).

The clause requires all contractor and subcontractor personnel assigned to perform work for or on behalf of VA to undergo background investigations commensurate with the risk and sensitivity level of their assigned positions. Personnel are designated into four risk tiers: Tier 1/Low Risk (non-sensitive positions), Tier 2/Moderate Risk, Tier 4/High Risk, and Tier 3/Tier 5 designations for positions requiring security clearances (Confidential, Secret, or Top Secret). The contracting officer must specify which positions or tasks fall into each tier category. Fitness determinations follow 5 CFR Part 731.202 standards and are separate from job qualifications. Contractors must immediately remove any employee deemed unfit and restrict their logical and physical access to VA facilities and systems, with no government reimbursement for replacement costs.

The clause mandates that fit personnel receive Personal Identification Verification (PIV) cards or other identification cards for physical access to VA facilities and logical access to VA data and information systems. Contractors must prominently display these cards at all times while on VA premises and surrender them upon employment termination, contract completion, or when no longer needed. Contractors must report lost or stolen cards immediately to government authorities and submit incident reports within 48 hours, with copies of police reports if applicable. Additionally, contractors must submit quarterly status reports to the PIV Sponsor within five working days after each calendar quarter, detailing each employee's name, assigned VA facility, background check and card issuance dates, card number, and return dates. The clause must be flowed down to all subcontractors, third-party agreements, and business associate agreements involving personnel with physical or logical access to VA facilities and systems.

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File Type Posted
36C77626R0003 0009.pdf PDF
36C77626R0003 0008.pdf PDF
36C77626R0003 0007.pdf PDF
36C77626R0003 0006.pdf PDF
Amendment 6 - ATT 1 - RFI Responses updated 033126.pdf PDF
Amend 5 - ATT 1 - 518-22-700.Summary Log_ADD1.20260225.pdf PDF
Amend 5 - ATT 4 - 08 87 33 - Decorative Film.pdf PDF
Amend 5 - ATT 9 -518-22-700.Bedford.EHRM.IFC.Add1.B04.20260225.pdf PDF
Amend 5 - ATT 14-518-22-700.Bedford.EHRM.IFC.Add1.B09.20260225.pdf PDF
Amend 5 - ATT 15-518-22-700.Bedford.EHRM.IFC.Add1.B10.20260225.pdf PDF
Amend 5 - ATT 19-518-22-700.Bedford.EHRM.IFC.Add1.B16.2060225.pdf PDF
Amend 5 - ATT 20-518-22-700.Bedford.EHRM.IFC.Add1.B17.20260225.pdf PDF
Amend 5 - ATT 27-518-22-700.Bedford.EHRM.IFC.Add1.B62.20260225.pdf PDF
Amend 5 - ATT 31-518-22-700.Bedford.EHRM.IFC.Add1.B81.2060225.pdf PDF
Amend 5 - ATT 5 - 34 71 13 PASSIVE VEHICLE BARRIERS.pdf PDF
Amend 5 - ATT 6 -518-22-700.Bedford.EHRM.IFC.Add1.B01.20260225.pdf PDF
Amend 5 - ATT 12-518-22-700.Bedford.EHRM.IFC.Add1.B07.20260225.pdf PDF
Amend 5 - ATT 30-518-22-700.Bedford.EHRM.IFC.Add1.B80.2060225.pdf PDF
Amend 5 - ATT 32-518-22-700.Bedford.EHRM.IFC.Add1.B82.2060225.pdf PDF
Amend 5 - ATT 33-518-22-700.Bedford.EHRM.IFC.Add1.BCH.2060225.pdf PDF
Amend 5 - ATT 34-518-22-700.Bedford.EHRM.IFC.Add1.MCR.2060225.pdf PDF
36C77626R0003 0004.pdf PDF
36C77626R0003 0003.pdf PDF
Amendment 0003 - ATT 2 - 518-22-700.Summary Log_ADD2.20260312.pdf PDF
Amendment 0003 - ATT 4 - 28 13 00 - Phys Access Cont Syst.ADD.pdf PDF
Amendment 0002 - Attachment 1 - Spec 01 32 16.15 Updated.pdf PDF
36C77626R0003 0002.pdf PDF
Amendment 0002 - Attachment 1 - Spec 01 32 16.15 Updated.pdf PDF
Attachment 02 - Site Visit - Bedford.pdf PDF
Attachment 10 - 518-22-700.Bedford.EHRM.IFC.B01.20250604.pdf PDF
Attachment 17 - 518-22-700.Bedford.EHRM.IFC.B08.20250604.pdf PDF
Attachment 18 - 518-22-700.Bedford.EHRM.IFC.B09.20250604.pdf PDF
Attachment 24 - 518-22-700.Bedford.EHRM.IFC.B16.20250604.pdf PDF
Attachment 29 - 518-22-700.Bedford.EHRM.IFC.B22.20250604.pdf PDF
Attachment 35 - 518-22-700.Bedford.EHRM.IFC.B80.20250604.pdf PDF
Attachment 36 - 518-22-700.Bedford.EHRM.IFC.B81.20250604.pdf PDF
Attachment 38 - 518-22-700.Bedford.EHRM.IFC.BCH.20250604.pdf PDF
36C77626R0003.pdf PDF
Attachment 06 - Brand Name Justification - Bedford 110525_Redacted.pdf PDF
Attachment 22 - 518-22-700.Bedford.EHRM.IFC.B14.20250604.pdf PDF
Attachment 26 - 518-22-700.Bedford.EHRM.IFC.B18.20250604.pdf PDF
Attachment 27 - 518-22-700.Bedford.EHRM.IFC.B20.20250604.pdf PDF
Attachment 03 - Bedford Campus Map.pdf PDF
Attachment 04 - PPQ.docx DOCX document
Attachment 09 - Bedford MA EHRM Specifications IFC 20250604 Part3of3.pdf PDF
Attachment 11 - 518-22-700.Bedford.EHRM.IFC.B02.20250604.pdf PDF
Attachment 12 - 518-22-700.Bedford.EHRM.IFC.B03.20250604.pdf PDF
Attachment 14 - 518-22-700.Bedford.EHRM.IFC.B05.20250604.pdf PDF
Attachment 19 - 518-22-700.Bedford.EHRM.IFC.B10.20250604.pdf PDF
Attachment 21 - 518-22-700.Bedford.EHRM.IFC.B13.20250604.pdf PDF
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?.## VAAR 852.204-72 PERSONNEL VETTING AND CREDENTIALING (MAR 2026)

(a) Definitions. As used in this clause –

VA Information system is the same as information system and means, pursuant to 38 U.S.C.

5727, a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information whether automated or manual.

VA sensitive information means all VA data, on any storage media or in any form or format, which requires protection due to the risk of harm that could result from inadvertent or deliberate disclosure, alteration, or destruction of the information and includes sensitive personal information.

The term includes information where improper use or disclosure could adversely affect the ability of VA to accomplish its mission, proprietary information, records about individuals requiring protection under various confidentiality provisions such as the Privacy Act and the HIPAA Privacy Rule, and information that can be withheld under the Freedom of Information Act. Examples of VA sensitive information include the following: individually-identifiable medical, benefits, and personnel information; financial, budgetary, research, quality assurance, confidential commercial, critical infrastructure, investigatory, and law enforcement information; information that is confidential and privileged in litigation such as information protected by the deliberative process privilege, attorney work-product privilege, and the attorney-client privilege; and other information which, if released, could result in violation of law or harm or unfairness to any individual or group, or could adversely affect the national interest or the conduct of Federal programs.

(b) General. Contractor personnel assigned to work for or on behalf of VA must undergo a background investigation commensurate with the risk and sensitivity level designation associated with the work to be performed at the level indicated in the contract. The Contractor and subcontractors shall comply with VA Directive/Handbook 0710, Personnel Security and Suitability Program, which can be accessed at:

https://vaww.va.gov/vapubs/index.cfm

(c) Risk and Sensitivity Levels. The following table identifies the risk and sensitivity levels that apply to any personnel providing services under this contract.

*VA Administrations, organizations and staff offices will use the OPM Position Designation Tool.

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 1/Low Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 1/Low Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 1/Low Risk]

Positions/Tasks Designated as Non-Sensitive Positions - Tier 1/Low Risk

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 1/Low Risk] https://vaww.va.gov/vapubs/index.cfm https://pdt.nbis.mil/consent

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 1/Low Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 1/Low Risk]

Positions/Tasks Designated as Non-Sensitive Positions - Tier 2/Mod Risk

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 2/Mod Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 2/Mod Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 2/Mod Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 2/Mod Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 2/Mod Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 2/Mod Risk]

Positions/Tasks Designated as Non-Sensitive Positions - Tier 4/High Risk

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 4/High Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 4/High Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 4/High Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 4/High Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 4/High Risk]

[Contracting Officer to enter position or task number, if all positions fulfilling a task are Tier 4/High Risk]

Security clearances are granted to individuals with a specific requirement for access to classified material (for example, Confidential, Secret and Top Secret). Contractor personnel that are required to obtain a security clearance will be subject to a Tier 3 or Tier 5 investigation. The following sensitivity designations have been assigned for the identified Tier 3 and Tier 5 required by this contract:

Tier 3: [Contracting Officer to enter “Non-Critical” or “Not Applicable” if no positions are identified as Tier 3]

Tier 5: [Contracting Officer to enter either Critical Sensitive and/or Special Sensitive, or “Not Applicable” if no positions are identified as Tier 5]

(d) Fitness. The results from a background investigation are used to determine if an individual’s fitness is sufficient for that individual to perform work for or on behalf of VA in the position identified in this contract. Contractor fitness determinations are made in accordance with 5 CFR Part 731.202.

Fitness requirements for employment are separate and distinct from job qualifications. If a Contractor or subcontractor employee is found to be unsuitable or unfit to provide services under this contract, the Contractor shall immediately remove the employee from working on this contract and take those necessary steps that restrict the employee’s logical access to VA data, information, VA sensitive information, or information technology or VA information systems containing such data or information.

The Contractor shall advise the employee that they are not permitted to access any VA controlled building or real property in relation to this contract.

The removal of an unfit Contractor or subcontractor employee does not alleviate the Contractor from satisfying the requirements of this contract. The Government will not reimburse the Contractor for any costs associated with the recruitment/replacement of an employee or subcontractor employee who is found to be unfit.

(e) Identification Cards. The Government will provide a Personal Identification Verification (PIV) card or other identification card, as necessary, to fit Contractor personnel who require physical access to VA facilities and/or logical access to VA data, information, VA sensitive information, or information technology or VA information systems containing such data or information. Contractor and subcontractor personnel shall prominently display their PIV/identification card on their persons while working at a VA facility and shall present their PIV/identification card for inspection upon request by a VA official. The Contractor must surrender the employee or subcontractor employee’s PIV/identification card in accordance with the requirements set forth in Directive/Handbook 0735 when any of the following events occur:

1. When no longer needed for contract performance.

2. Upon completion of the Contractor/subcontractor employee’s employment.

3. Upon contract completion or termination.

(f) Lost/stolen. Immediately upon detection, the Contractor shall report a lost or stolen PIV/identification card to the Government authorities as identified in Directive/Handbook 0735.

Within 48 hours of reporting the lost/stolen PIV/identification card, the Contractor shall submit to the Program Manager an incident report that describes the relevant facts and circumstances regarding the loss/theft. If the loss/theft was reported by the Contractor to the local police, the Contractor shall further submit a copy of the final police report to the Program Manager within 48 hours of the report being made available by the local police department. The Government will not reimburse the Contractor for any costs that result from lost/stolen PIV/identification card(s).

(g) Regular Reporting. The Contractor shall submit a status report to PIV Sponsor within 5 working days after the end of each calendar quarter and as requested by the

Government in order to initiate contract closeout procedures. The report must provide the status of each contractor/subcontractor employee who is required to have a PIV/identification card during the performance of the contract. The report shall identify the Contractor and the contract number, and list the following status for each contractor/subcontractor employee who holds a PIV/identification card under this contract:

1. Contractor/subcontractor employee name..

2. Name of VA facility where Contractor/subcontractor employee works, if applicable.

3. Date background check submitted for Contractor/subcontractor employee.

4. Date PIV/identification card issued to Contractor/subcontractor employee.

5. Contractor/subcontractor employee’s PIV/identification card number, as applicable.

6. Date Contractor/subcontractor employee no longer has need for

PIV/identification card.

7. Date Contractor notified VA that PIV/identification card is no longer required.

8. Date Contractor returned PIV/identification card was returned to VA.

(h) Flow down of clause. The Contractor shall include the substance of this clause in subcontracts, third-party agreements, and BAA’s, in which subcontractors, third-party servicers/employees, and business associates will perform functions where they will have physical access to a VA facility or logical access to VA data, information, VA sensitive information, or information technology or VA information system containing such data or information.

(End of Clause)

?.## VAAR 852.204-72 PERSONNEL VETTING AND CREDENTIALING (MAR 2026)

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