DRAFT - Product Description - SharePoint Online Integration.docx
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- 7A21--(New Action): VA Procurement Policy Documentation Control Software (VA-27-00008195)
- Solicitation number
- 36C10B26Q0830
About this file
This is a Product Description (PD) for a Document Control Management System - SharePoint Online Integration acquisition by the Department of Veterans Affairs, Office of Acquisition, Logistics, and Construction. The solicitation number is 36C10B26Q0830 with TAC number VA-27-00008195, issued as a Pre-Solicitation/RFI.
The VA seeks an enterprise-ready, cloud-based Software as a Service (SaaS) platform or Microsoft 365/SharePoint Online-native application to manage the lifecycle of Standard Operating Procedures (SOPs), forms, and reference materials for approximately 400,000 VA personnel. The solution must support content display with formatted, readable pages; active procedure access via catalog/table of contents view; complete version control and archival; role-based access control (end users, content administrators, system administrators); draft isolation; scheduled publication with automatic archival; search and filter capabilities by title, document number, effective date, category, and keyword; automated notifications; Section 508/WCAG 2.1 AA accessibility compliance; and Azure Active Directory/Microsoft Entra ID single sign-on. The system must render correctly on Windows desktops, tablets, and mobile devices, support IPv6-Only and dual-stack connectivity, and comply with FedRAMP Moderate authorization or operate within VA's existing Microsoft 365 tenant. The Period of Performance is December 1, 2026, to November 30, 2027, with one optional 12-month extension. The PD includes extensive security and compliance requirements including Zero Trust architecture, VA Critical Security Controls, generative AI governance if applicable, FISMA compliance, continuous monitoring, data residency requirements, contractor personnel security vetting (Tier 1/Low Risk and Tier 2/Moderate Risk designations), Section 508 accessibility standards, IPv6 support, SSN reduction compliance, and comprehensive information security and privacy requirements per VA directives and OMB memoranda.
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Other files
| File | Type | Posted |
|---|---|---|
| 36C10B26Q0830 0002.docx | DOCX document | |
| RFI 36C10B26Q0830 - QandA - Part 2.xlsx | XLSX spreadsheet | |
| RFI 36C10B26Q0830 - QandA.xlsx | XLSX spreadsheet | |
| 36C10B26Q0830 0001.docx | DOCX document | |
| 36C10B26Q0830.docx | DOCX document |
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Document Control Management System – SharePoint Online Integration TAC Number: VA-27-00008195
PRODUCT DESCRIPTION (PD)
DEPARTMENT OF VETERANS AFFAIRS
Office of Acquisition, Logistics, and Construction (OALC) Office of Procurement Policy
Document Control Management System – SharePoint Online Integration
Date: September 17, 2026
VA-27-00008195
PD Version Number: 1.0
Contents
| 1.0 | PRODUCT REQUIREMENTS | 3 |
| 1.1 | SALIENT CHARACTERISTIC(S) | 3 |
| 2.0 | NOTICE OF THE FEDERAL ACCESSIBILITY LAW AFFECTING ALL INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) PROCUREMENTS (SECTION 508) | 4 |
| 2.1 | SECTION 508 – INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) STANDARDS | 5 |
| 2.2 | COMPATABILITY WITH ASSISTIVE TECHNOLOGY | 5 |
| 2.3 | ACCEPTANCE AND ACCEPTANCE TESTING | 5 |
| 3.0 | INFORMATION TECHNOLOGY USING SUSTAINABLE PRODUCTS | 5 |
| 4.0 | ELECTRONIC SHIPMENT | 6 |
| 5.0 | GENERAL REQUIREMENTS | 6 |
| 5.1 | VA TECHNICAL REFERENCE MODEL | 6 |
| 5.2 | ZERO TRUST – VA CRITICAL SECURITY CONTROLS | 6 |
| 5.3 | SOCIAL SECURITY NUMBER (SSN) REDUCTION | 7 |
| 5.4 | INTERNET PROTOCOL VERSION 6 (IPV6) | 7 |
| 5.5 | SOFTWARE AND LICENSING REQUIREMENTS | 8 |
| 5.6 | TRUSTED INTERNET CONNECTION (TIC) | 8 |
| 5.7 | GENERATIVE ARTIFICIAL INTELLIGENCE REQUIREMENTS | 8 |
| 5.7.1 | AI SYSTEM/LLM DEVELOPMENT AND OPERATION DOCUMENTATION REQUIREMENTS | 10 |
| 5.7.1.1 | MONITORING, REPORTING, AND CORRECTIVE ACTION | 11 |
| 5.7.1.2 | AI MODEL UPDATES AND CHANGE DISCLOSURES | 12 |
| 5.8 | SOURCE CODE HARMONIZATION AND REUSE IN INFORMATION TECHNOLOGY (SHARE IT Act) | 12 |
| 6.0 | SaaS FEDRAMP ASSESSMENT AND AUTHORIZATION AND CONTINUOUS MONITORING REQUIREMENTS | 12 |
| 6.1 | IF THE SOLUTION IS FedRAMP AUTHORIZED BUT NOT VA AUTHORIZED: | 15 |
| 6.2 | IF THE SOLUTION IS FedRAMP AUTHORIZED AND VA AUTHORIZED: | 16 |
| 7.0 | SECURITY AND PRIVACY REQUIREMENTS | 18 |
| 7.1 | POSITION/TASK RISK DESIGNATION LEVEL(S) | 18 |
| 8.0 | CONTRACTOR PERSONNEL SECURITY REQUIREMENTS | 18 |
| ADDENDUM B – VA INFORMATION AND INFORMATION SYSTEM SECURITY/ PRIVACY LANGUAGE | 20 | |
| 9.0 | POINTS OF CONTACT | 38 |
| 10.0 | INFORMATION SECURITY CONSIDERATIONS | 38 |
PRODUCT REQUIREMENTS
The Department of Veterans Affairs (VA), Office of Acquisition, Logistics, and Construction (OALC), Office of Procurement Policy, is seeking an enterprise-ready document control management solution designed to streamline the lifecycle of Standard Operating Procedures (SOPs), forms, and related reference materials.
Available as Software as a Service (SaaS) platform or a Microsoft 365/SharePoint Online-native application, the solution will provide a centralized, secure environment for publishing, displaying, versioning, and achieving critical operational documents. Built to support an enterprise user base of approximately 400,000 VA personnel, the platform will help ensure employees can access current, approved documentation while preserving historical records for governance, compliance, and audit purposes.
The solution shall support management of the following content types:
· Standard Operating Procedures (SOPs)
· Associated fillable or static forms
· Reference documents and hyperlinks (internal and external)
· Supporting job aids and quick reference guides This acquisition is limited to cloud-based software or an M365-native application. No physical hardware is included.
The Period of Performance (PoP) shall be December 1, 2026, to November 30, 2027, with one (1) 12-month Option Period to be exercised at the Government’s discretion.
The Contractor shall provide the following:
BASE PERIOD
The Period of Performance shall be December 1, 2026, to November 30, 2027.
| Description |
| Part no. |
| Quantity |
| SharePoint Online-Native application |
| <Part Number> |
| <Qty> |
SALIENT CHARACTERISTIC(S)
| Parameter |
| Required Attribute |
| Deployment Model |
| Native SharePoint Online integration OR SharePoint-embedded SaaS application |
| User Base Scale |
| Must support approximately 400,000 concurrent read-access users |
| Content Display |
| Approved SOP content must render as a formatted, readable page within the application — not as a file requiring a separate application to open |
| Table of Contents |
| Active procedures must be accessible via a catalog/TOC view displaying title, version number, synopsis of version changes, and effective date, with direct hyperlinks to each procedure's display page |
| Version Archival |
| Complete revision history must be maintained for each procedure throughout its lifecycle, with all attachments and reference materials associated with each specific version preserved at the time of publication |
| Archived Version Access |
| Archived versions must be read-only and accessible to authorized personnel for audit, reference, and historical review |
| Scheduled Publication |
| Future-dated publication scheduling must be supported, with automatic archival of the previously active version upon publication of a new version |
| Role-Based Access Control |
| At minimum: end users (read-only), content administrators (create/edit/publish), and system administrators |
| Draft Isolation |
| Draft and pending versions must be isolated from end-user view until published or scheduled for publication |
| Document Library Avoidance |
| End users must never be required to navigate a SharePoint Document Library |
| Search and Filter |
| Catalog/TOC view must support search and filter by title, document number, effective date, category, and keyword |
| Notifications |
| Automated notifications to designated personnel for upcoming scheduled publications, expiring procedures, or configurable review cycle reminders |
| Device Compatibility |
| Must render correctly on Windows desktops, tablets, and mobile devices |
| Authentication |
| Azure Active Directory / Microsoft Entra ID Single Sign-On |
| Accessibility |
| Section 508 / WCAG 2.1 AA compliant |
| Data Residency |
| FedRAMP Moderate authorization OR operation entirely within the existing VA Microsoft 365 tenant |
| Network Protocol |
| IPv6-Only and dual-stack (IPv6/IPv4) support required |
| Sustainable Products |
| Not Applicable — this acquisition does not involve physical IT products subject to Energy Star or FEMP Low Standby Power requirements |
NOTICE OF THE FEDERAL ACCESSIBILITY LAW AFFECTING ALL INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) PROCUREMENTS (SECTION 508) On January 18, 2017, the Access Board issued a final rule that updated accessibility requirements covered by Section 508 and refreshed guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The final rule went into effect on January 18, 2018. The revisions and updates to the Section 508-based standards and Section 255-based guidelines are intended to ensure that information and communication technology (ICT) covered by the respective statutes is accessible to and usable by individuals with disabilities.
SECTION 508 – INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) STANDARDS
The Section 508 standards established by the Access Board are incorporated into, and made part of all VA orders, solicitations and purchase orders developed to procure ICT. These standards are found in their entirety at: Revised 508 Standards and 255 Guidelines (access-board.gov). A single PDF file version of the Revised Section 508 Standards and 255 Guidelines will be supplied upon request, or can be obtained from the Access Board website. Federal agencies must comply with the Rehabilitation Act of 1973, as amended.
The Contractor shall comply with “508 Chapter 2: Scoping Requirements” for all electronic ICT and content delivered under this contract. Specifically, as appropriate for the technology and its functionality, the Contractor shall comply with the technical standards marked here:
| ☒ | E205 Electronic Content – (Accessibility Standard -WCAG 2.0 Level A and AA Guidelines) |
| ☒ | E204 Functional Performance Criteria |
| ☐ | E206 Hardware Requirements |
| ☒ | E207 Software Requirements |
| ☒ | E208 Support Documentation and Services Requirements |
COMPATABILITY WITH ASSISTIVE TECHNOLOGY
The standards do not require installation of specific accessibility-related software or attachment of an assistive technology device. Section 508 requires that ICT be compatible with such software and devices so that ICT can be accessible to and usable by individuals using assistive technology, including but not limited to screen readers, screen magnifiers, and speech recognition software.
ACCEPTANCE AND ACCEPTANCE TESTING
Deliverables resulting from this solicitation will be accepted based in part on satisfaction of the Section 508 Chapter 2: Scoping Requirements standards identified above.
The Government reserves the right to test for Section 508 Compliance before delivery. The Contractor shall be able to demonstrate Section 508 Compliance upon delivery.
INFORMATION TECHNOLOGY USING SUSTAINABLE PRODUCTS
The Contractor shall comply with Sections 524 and Sections 525 of the Energy Independence and Security Act of 2007; Section 104 of the Energy Policy Act of 2005; Executive Order 14148, “Initial Rescissions of Harmful Executive Orders and Actions,” dated January 20, 2025; Executive Order 13221, “Energy-Efficient Standby Power Devices,” dated August 2, 2001; and the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) to provide ENERGY STAR® certified and Federal Energy Management Program (FEMP) Designated Low Standby Power information technology products, see https://www.energy.gov/femp/search-energy-efficient-products. See http://www.energystar.gov for complete product specifications and updated lists of Energy Star certified products. FEMP low standby power product listing can be found at https://www.energy.gov/femp/low-standby-power-product-list.
The Contractor shall provide products that meet the definition of sustainable products if the products are delivered to the Government; furnished by the Contractor for use by the Government, incorporated into the construction of a public building or public work, or acquired by the Contractor for use in performing services under a Government contract where the cost of the products is a direct cost to a Government contract (versus costs which are normally applied to a contractor's general and administrative expenses or indirect costs).
Specifically, the Contractor shall provide sustainable products under this contract in accordance with RFO 52.223-23 (NOV 2025). The applicable products with their associated certification and/or designation required (e.g. Energy Star, FEMP Low Standby Power) are identified within the product requirements specifications in this PD. The Contractor shall self-certify that its proposed products meet the certification(s) and/or designation(s) specified.
ELECTRONIC SHIPMENT
Inspection: Destination Acceptance: Destination Free on Board (FOB): Destination
Ship To and Mark For:
Primary
Alternate
| Name: |
| TBD |
| Name: |
| TBD |
| Address: |
| TBD |
| Address: |
| TBD |
| Voice: |
| TBD |
| Voice: |
| TBD |
| Email: |
| TBD |
| Email: |
| TBD |
GENERAL REQUIREMENTS
VA TECHNICAL REFERENCE MODEL
The Contractor shall comply with the VA OIT Technical Reference Model (VA TRM). Compliance with the VA TRM is achieved by using only technologies and standards that are listed as approved for use in the VA TRM. The Contractor shall provide all necessary information requested by VA to ensure TRM approval is obtained prior to use on VA’s network.
ZERO TRUST – VA CRITICAL SECURITY CONTROLS
VA has established minimum mandatory security requirements and requires that any network connected software system or service must meet the VA Critical Security Controls as outlined in the VA Memorandum, “VA Security Controls”, https://www.voa.va.gov/DocumentView.aspx?DocumentID=5010. VA Critical Security Controls identify the minimum mandatory requirements that must be implemented across all VA enterprise infrastructure, cloud computing environments, information systems, networks, and specialized devices (medical devices/systems, special-purpose systems, and research scientific computing devices) that process, store, and/or transmit VA data. Effective July 1, 2025, the Contractor shall implement these VA Critical Security Controls, within any network connected software system or service prior to being authorized for use in the VA. This functional requirement is not negotiable, and Plan of Action & Milestones (POAM) will not be accepted in the event these controls cannot be implemented for new systems. Critical Security Controls are intended to increase VA’s security posture and provide security and privacy risk visibility into the VA network and is not a new requirement. The Contractor’s failure to maintain these VA Critical Controls after implementation will result in VA discontinuing the use of the system.
SOCIAL SECURITY NUMBER (SSN) REDUCTION
The Contractor solution shall support the Social Security Number (SSN) Fraud Prevention Act (FPA) of 2017 which prohibits the inclusion of SSNs on any document sent by mail. The Contractor support shall also be performed in accordance with Section 240 of the Consolidated Appropriations Act (CAA) 2018, enacted March 23, 2018, which mandates VA to discontinue using SSNs to identify individuals in all VA information systems as the Primary Identifier. The Contractor shall ensure that any new IT solution discontinues the use of SSN as the Primary Identifier to replace the SSN with the Integrated Control Number (ICN) in all VA information systems for all individuals. The Contractor shall ensure that all Contractor delivered applications and systems integrate with the VA Master Person Index (MPI) for identity traits to include the use of the ICN as the Primary Identifier. The Contractor solution may only use a Social Security Number to identify an individual in an information system if and only if the use of such number is required to obtain information VA requires from an information system that is not under the jurisdiction of VA.
INTERNET PROTOCOL VERSION 6 (IPV6)
The Contractor solution shall support IPv6-Only based upon the memo issued by the Office of Management and Budget (OMB) on November 19, 2020 (https://www.whitehouse.gov/wp-content/uploads/2020/11/M-21-07.pdf). Which defines IPv6-only as the state of an operational system or service when IPv4 protocol functions (addressing, packet forwarding) are not in use. The NIST USGv6 profile defines technical requirements for a product to be capable of operating in IPv6-Only environments. IPv6-Only technology, in accordance with the USGv6 Program (https://www.nist.gov/programs-projects/usgv6-program/usgv6-revision-1), NIST Special Publication (SP) 500-267B Revision 1 “USGv6 Profile” (https://doi.org/10.6028/NIST.SP.500-267Br1), and NIST SP 800-119 “Guidelines for the Secure Deployment of IPv6” (https://doi.org/10.6028/NIST.SP.800-119), compliance shall be included in all IT infrastructures, application designs, application development, operational systems and sub-systems, and their integration. In addition to the above requirements, all devices, applications, and systems shall support all applicable functionality on native IPv6-Only as well as dual stack (IPv6 / IPv4) connectivity without additional memory or other resources being provided by the Government, so that they can function in a mixed environment. All public/external facing servers and services (e.g., web, email, DNS, ISP services, etc.) shall support native IPv6-Only and dual stack (IPv6 / IPv4) users and all internal infrastructure and applications shall support using native IPv6-Only and dual stack (IPv6 / IPv4) for all functionality and operations.
SOFTWARE AND LICENSING REQUIREMENTS
The Contractor shall be responsible for the provision of all software licenses and any associated licensing maintenance required for any development, delivery, integration, operation, and/or maintenance associated with its proposed application(s), software products, software solution, and/or system including, but not limited to, any and all application(s), software and/or software products that comprise, are a part of, or integrate with the Contractor’s proposed application(s), software products, software solution, and/or system for the life of any resulting contract.
TRUSTED INTERNET CONNECTION (TIC)
The Contractor solution shall meet the requirements outlined in Office of Management and Budget Memorandum M-19-26, “Update to the Trusted Internet Connections (TIC) Initiative“ (https://www.whitehouse.gov/wp-content/uploads/2019/09/M-19-26.pdf), VA Directive 6513 “Secure External Connections”, and shall comply with the TIC 3.0 Core Guidance Documents, including all Volumes and TIC Use Cases, found at the Cybersecurity & Infrastructure Security Agency (CISA) (https://www.cisa.gov/publication/tic-30-core-guidance-documents.)
GENERATIVE ARTIFICIAL INTELLIGENCE REQUIREMENTS
If Artificial Intelligence (AI) is part of the Contractor system/solution, the Contractor shall be in compliance with E.O. 13960 and 14319, OMB Memorandums M-25-21, M-25-22, and M-26-04, and VA Directive and Handbook 6500 to support VA in trustworthy, secure, responsible, accountable, Truth Seeking, and Ideologically Neutral AI innovation.
The Contractor shall protect VA Sensitive data from unauthorized disclosure or use, and from being used to train or improve the functionality of the vendor's commercial AI offerings without express permission from VA. Current guidance and approved AI tools are available here: https://department.va.gov/ai/guidance-for-generative-ai-use-at-va/. The entire definition of VA Sensitive Data can be found at 38 U.S.C. § 5727 (23).
The Contractor shall deliver the services, technical data, configurations, models, weights, documentation or other information, including source code, developed during contract performance. The Contractor, in collaboration with VA, must evaluate the output of any AI tool for accuracy prior to using the output in VA efforts. All data, including models, weights, algorithms, and outputs generated using either Government-furnished data or data first developed under this contract shall be the property of the Government with unlimited rights as defined by FAR 52.227-14. The Contractor shall also deliver any custom-developed code developed with AI methodologies in accordance with the SHARE IT Act, if applicable. VA shall also retain unlimited rights to any improvements to that data, including the continued design, development, testing, and operation of AI systems and/or systems utilizing AI.
The Contractor shall ensure that all AI Systems, including Large Language Models (LLM), whether standalone LLMs or integrated into broader software platforms, procured under this effort and/or used in performance of this contract complies with the Unbiased AI Principles as defined in Executive Order 14319 and OMB Memorandum M-26-04, e.g. Truth Seeking and Ideologically Neutral, as applicable to the intended use of the system.
The Contractor shall ensure that AI System/LLM generated outputs are truthful in responding to user prompts seeking factual information or analysis, prioritize historical accuracy, scientific inquiry, and objectivity, as well as acknowledge uncertainty where reliable information is incomplete or contradictory and do not fabricate, hallucinate, or present unverifiable information as fact.
The Contractor shall ensure that LLMs and AI outputs are neutral, nonpartisan tools that do not manipulate responses in favor of ideological dogmas such as Diversity, Equity, and Inclusion (DEI). The Contractor shall ensure that the LLMs, including the AI System, are not intentionally encoded with partisan or ideological judgments within an AI System’s/LLM’s outputs unless those judgments are prompted by or otherwise readily accessible to the end user.
Compliance with the AI requirements of this contract, including adherence to the Unbiased AI Principles, Truth-Seeking and Ideological Neutrality requirements, disclosure obligations, monitoring and reporting requirements, and corrective action responsibilities, is a material condition of eligibility for payment and continued performance. In accordance with OMB Memorandum M-26-04, failure to comply with these requirements, or refusal to take timely and appropriate corrective action to remedy identified noncompliance, may constitute a material breach of contract and may result in remedies consistent with the terms of the contract and applicable law including but not limited to withholding of payment, termination for cause/default, or other appropriate contractual remedies, as determined by the Contracting Officer.
All AI for delivery and/or use in performance of the contract shall adhere to the VA Trustworthy AI Framework, available at https://department.va.gov/ai/trustworthy/. Once the Contractor has obtained CO authorization to use specific AI in contract performance, the Contractor shall provide the COR a signed Statement of Attestation prior to AI implementation as identified in the Artificial Intelligence in VA Contracts clause, to include its associated list of AI being used in contract performance.
Deliverable:
A. Statement of Attestation
AI SYSTEM/LLM DEVELOPMENT AND OPERATION DOCUMENTATION REQUIREMENTS
To enable Government continued assessment of compliance with Trustworthy AI requirements and both Unbiased AI Principles, Truth-seeking and Ideological Neutrality, in accordance with OMB M-26-04, the Contractor shall provide AI System/LLM Development and Operation Documentation Package to include, at a minimum:
1. Acceptable Use Policy The Contractor shall provide an Acceptable Use Policy document governing its AI operation that characterizes and differentiates appropriate and inappropriate use of their product offering
2. Model Cards, System Cards and/or Data Cards The Contractor shall provide documentation describing essential information about the model, system, and or data as it relates to the AI/LLM product offering. The documentation shall address summaries of training process, identified risks and mitigations, and model evaluation scores on LLM benchmarks at a minimum, where appropriate
3. End User Resources The Contractor shall provide documentation to include product tutorials, developer guides, and/or other tools to assist VA in ensuring proper use of the AI/LLM to maximize utility
4. Mechanism for End User Feedback The Contractor shall provide documentation describing the mechanism employed to provide feedback to the Offeror on outputs identified that violate the Unbiased AI Principles. This may be satisfied by a general inbox, specific Point of Contact, or similar feedback mechanism.
5. Pre-Training and Post-Training Activities of the AI System/LLM The Contractor shall provide documentation of Pre-Training and Post Training Activity that provides details on:
a. Actions taken that impact the factuality and grounding of AI System/LLM outputs
b. System-level prompts that provide natural language instructions to the model specifying guidelines on responding to user-generated queries, to include how a model responds when reliable information is incomplete, contradictory, or subject to individual interpretation
c. The type of outputs restricted via content moderation and safety filters
d. The use of red teaming as a means of continuously assessing the model to protect against incidents of bias in generated output.
e. Training or development, if any, that occurred outside the United States, to include the type of activity and the country in which it occurred.
f. Any modifications or configurations undertaken to comply with any regulation from a government other than the U.S. Federal Government.
6. Model Evaluation Results and Methodologies The Contractor shall provide documentation describing the Evaluation Results of bias evaluations conducted by the Vendor to include the methodology for performing such tests (e.g., testing prompt pairs for politically oriented topics).
The documentation shall also include Benchmark scoring results measuring the model’s bias, helpfulness, honesty, or accuracy when provided with ambiguous versus straightforward questions. (Including any benchmarks comparing performance across multiple languages, where applicable).
7. Description of Enterprise-Level Controls The Contractor shall provide documentation describing the Enterprise Governance tools and controls, such as:
a. Customizable system instructions that are additive to a base model’s system prompts or content generation filters.
b. Product features that require a model to cite sources of its outputs or otherwise provide visibility into the provenance of the model’s outputs.
c. AI System/LLM model evaluation tools that enable comparisons either between a model’s outputs, or across various models.
8. Third Party Modification Disclosure The Contractor shall disclose of any additional controls to modify an AI Model’s/LLM’s output applied by the Contractor if the Contractor is not a direct developer of the LLM (e.g., classifiers, system prompts, fine-tuning, content moderation and filters, etc.)
Deliverable:
A. AI System/LLM Development and Operation Documentation Package
MONITORING, REPORTING, AND CORRECTIVE ACTION
The Contractor shall develop and implement a Compliance Monitoring and Reporting Plan supporting ongoing monitoring processes to evaluate AI outputs for compliance with Trustworthy AI and Unbiased AI principles. This plan shall include the mechanism for authorized users to provide end user feedback to report suspected violations of Truth-Seeking or Ideological Neutrality requirements.
The Contractor shall notify the COR within 10 business days of identifying any material deviation from these principles and shall submit a written Corrective Action Plan describing mitigation steps, responsible parties, and timelines. Any material deviation, corrective action taken, and results shall be detailed in the <Weekly or Monthly> Progress Reports.
Deliverable:
A. Compliance Monitoring and Reporting Plan B. Corrective Action Plan
AI MODEL UPDATES AND CHANGE DISCLOSURES
The Contractor, in an AI Model/LLM Change Disclosure, shall notify the Government throughout the PoP in advance of any material changes to AI models, including new AI enhancements, features and/or components, controls, retraining, classifiers, system prompts, fine-tuning, content moderation, filters, version replacement, or architectural changes, that could reasonably affect compliance with Trustworthy AI or Unbiased AI principles. Updated documentation shall be provided to VA for VA approval prior to implementation of such changes.
Deliverable:
A. AI Model/LLM Change Disclosure SOURCE CODE HARMONIZATION AND REUSE IN INFORMATION TECHNOLOGY (SHARE IT Act) The Contractor shall comply with the Source Code Harmonization and Reuse in Information Technology (SHARE IT) Act when developing custom software source code first produced for the VA in the performance of this Contract/Order. The Contractor shall deliver to the Government all data first produced under this Contract/Order with unlimited rights as defined by FAR 52.227-14, to include without limitation, all custom developed software source code and other key technical components of the code (including documentation, data models, schemas, metadata, architecture designs, configuration scripts, and artifacts required to develop, build, test, and deploy the code). Custom-developed software source code includes source code, or segregable portions of source code and all documentation created in support thereof to include source code written for a software project, product, module, plugin, script, middleware, or application programming interface.
SaaS FEDRAMP ASSESSMENT AND AUTHORIZATION AND CONTINUOUS MONITORING REQUIREMENTS IF THE SOLUTION IS NOT FedRAMP AUTHORIZED:
The information system solution selected by the Contractor shall comply with the Federal Information Security Management Act (FISMA).
The Contractor shall comply with FedRAMP requirements at the <<Insert Impact Level from the Data Security Categorization. This should be done by DTC>> Impact Level, as mandated by Federal laws and policies, including making available any documentation, physical access, and logical access needed to support this requirement.
The Contractor shall provide a SaaS product as defined by the following criteria: Software as a Service (SaaS) is an application delivery model in which the application is hosted on a cloud infrastructure outside the security boundary of VA and is provided to the Cloud Service Customer (CSC) over the internet. The CSC uses the SaaS offering via a thin-client interface, such as a web-browser or a program interface. The CSC subscribes to the SaaS offering and is only responsible for minor in-app customizations. The Cloud Service Provider (CSP) offering the application is responsible for management of the application, safeguarding of data stored or processed by the application, and all elements of the underlying infrastructure. Additionally, the CSP is responsible for all on-going compliance. In order to qualify as SaaS for use at VA, and to align with Federal Risk and Authorization Management Program (FedRAMP) requirements, the hosting for the offering must conform to the NIST 800-145 definition of Cloud Computing and thus contain following key characteristics:
On-Demand Self-Service: The CSP fully automates the provisioning of both the customer interface and the underlying cloud components of the SaaS offering. In some cases, to the CSP may provision internal resources manually, while providing the CSC an automated interface to request and track the service.
Broad Network Access: The SaaS capabilities are available over the internet or over a network that is available from all access points the CSC requires. The SaaS offering is accessible through common platforms (e.g., mobile phones, tablets, laptops, and workstations).
Resource Pooling: The computing infrastructure supporting the SaaS offering is shared among more than one CSC using a multi-tenant model, and resources are dynamically assigned depending on customer demand.
Rapid Elasticity: Computing capabilities are automatically provisioned and released in a manner that scales with customer demand. In some cases, the scaling of resources may not be fully automated, but it should be fast enough to support the needs of the CSC, which the CSC would have to define.
Measured Service: Resource usage, such as storage, processing, bandwidth, and user activity are measured and reported on in a manner that is relevant to the SaaS offering.
Following guidance from the Federal CIO, VA will utilize existing JAB ATO or agency ATO issued by another agency as a starting point for FedRAMP requirements. If neither of those exist, VA will sponsor The Cloud Service Provider for a FedRAMP Authorization. VA will be using the FedRAMP baselines as a starting point, since they are specifically tailored for cloud services.
The Contractor shall, where applicable, assist with the VA ATO Process to help achieve agency authorization of the cloud service or migrated application at the impact level required by VA to utilize the product. For this solution the required impact level is: <<Insert Impact Level from the Data Security Categorization. This should be done by DTC>>.
The Contractor shall comply with FedRAMP requirements surrounding data location within the Continental United States. FedRAMP specifies data location requirements in the High Baseline as part of control SA-9 (5); however, FedRAMP does not provide or specify data location requirements for other baselines.
The Contractor shall complete a FedRAMP System Security Plan (SSP) and supporting documentation including required attachments.
The Contractor shall work with a VA DTC Subject Matter Expert to develop and provide a VA system boundary diagram including any integration and connectivity components for VA use. This will be known as the VA Implementation Diagram (VAID) and will demonstrate the proposed implementation of this system at VA.
The Contractor shall complete a Third-Party Assessment Organization (3PAO) Security Assessment Plan (SAP).
The Contractor shall complete a 3PAO Security Assessment Report (SAR).
If new or unanticipated vulnerabilities are discovered by either VA or the Contractor, or if existing safeguards have ceased to function, the discoverer shall bring the situation to the attention of the other party within one hour in accordance with Addendum B, VA Information and Information System Security/Privacy Language.
The Contractor shall comply with FedRAMP data management requirements.
Successful issuance of a VA ATO will be required before live VA data can be used in the system.
The Contractor shall participate in FedRAMP Continuous Monitoring activities as outlined by FedRAMP’s Continuous Monitoring Strategy Guide found on the FedRAMP website.
The Contractor shall participate in monthly Agency and FedRAMP Sustainment meetings following the granting of a VA ATO.
The Contractor shall provide continuous monitoring activities including, but not limited to, scans, security artifacts, and provide Continuous Monitoring Monthly Scans and monthly Plan of Action and Milestones (POAM) reports as outlined by VA and FedRAMP requirements.
The Contractor shall provide a Monthly VA License Report of VA sites currently utilizing the cloud product post ATO award. The license report shall include the number of subscription licenses being utilized and the specific VA site where they’re in use.
Deliverables:
A. FedRAMP System Security Plan (SSP) and required Attachments B. VA Implementation Diagram C. 3PAO Security Assessment Plan (SAP) D. 3PAO Security Assessment Report (SAR) E. Plan of Action and Milestones Reports.
F. Monthly VA License Report IF THE SOLUTION IS FedRAMP AUTHORIZED BUT NOT VA AUTHORIZED:
The information system solution selected by the Contractor shall comply with the Federal Information Security Management Act (FISMA)
The Contractor shall remain in compliance with FedRAMP requirements as mandated by Federal laws and policies, including making available any documentation, physical access, and logical access needed to support this requirement.
The system must be FedRAMP Authorized at no less than the <<Insert Impact Level from the Data Security Categorization. This should be done by DTC>>
The Contractor shall, where applicable, assist with the VA ATO Process to help achieve agency authorization of the cloud service or migrated application.
The Contractor shall provide confirmation of the completion of its FedRAMP System Security Plan (SSP) and supporting documentation by providing, to the VA PM, COR, and DTC, its repository ID number and associated link for VA to download the SSP and all required artifacts within five calendar days of contract award.
The Contractor shall work with a VA DTC Subject Matter Expert to develop and provide a VA specific system boundary diagram including any integration and connectivity components for VA use. This will be known as the VA Implementation Diagram (VAID) and will demonstrate the proposed implementation of this system at VA.
The Contractor shall provide the results of their most recent Third-Party Assessment Organization (3PAO) Security Assessment Plan (SAP).
The Contractor shall complete a 3PAO Security Assessment Report (SAR).
The Contractor shall provide VA with the most recent monthly scans for the production environment within the authorization boundary and their scan upload schedule for FedRAMP within 30 calendar days of contract award.
The Contractor shall provide their availability to participate in monthly continuous monitoring meetings to be scheduled following successful VA ATO within 30 calendar days of contract award.
If new or unanticipated vulnerabilities are discovered by either VA or the Contractor, or if existing safeguards have ceased to function, the discoverer shall bring the situation to the attention of the other party within one hour in accordance with Addendum B, VA Information and Information System Security/Privacy Language.
The Contractor shall comply with FedRAMP data management requirements.
Successful issuance of a VA ATO will be required before live VA data can be used in the system.
The Contractor shall participate in FedRAMP Continuous Monitoring activities as outlined by FedRAMP’s Continuous Monitoring Strategy.
The Contractor shall participate in monthly Agency and FedRAMP Sustainment meetings following the granting of a VA ATO.
The Contractor shall provide continuous monitoring activities including, but not limited to scans, security artifacts, and provide Continuous Monitoring Monthly Scans and monthly Plan of Action and Milestones (POAM) reports as outlined by VA and FedRAMP requirements.
The Contractor shall provide a Monthly VA License Report of VA sites currently utilizing the cloud product post ATO award. The license report shall include the number of subscription licenses being utilized and the specific VA site where they’re in use.
Deliverables:
A. VA Implementation Diagram B. 3PAO Security Assessment Plan (SAP) C. 3PAO Security Assessment Report (SAR) D. Plan of Action and Milestones Reports E. Monthly VA License Report IF THE SOLUTION IS FedRAMP AUTHORIZED AND VA AUTHORIZED:
The information system solution selected by the Contractor shall comply with the Federal Information Security Management Act (FISMA) and have a current VA authorization.
The Contractor shall remain in compliance with FedRAMP requirements as mandated by Federal laws and policies, including making available any documentation, physical access, and logical access needed to support this requirement.
The FedRAMP Authorization level and existing VA ATO should be no less than the level required for this use case which has been defined as <<Insert Impact Level from the Data Security Categorization. This should be done by DTC>>.
The Contractor shall, where applicable, assist with the VA ATO Sustainment Process to help maintain health and quality of agency authorization of the cloud service or migrated application.
The Contractor shall exclusively provide subscription licenses to FedRAMP authorized and VA authorized environments.
If new or unanticipated vulnerabilities are discovered by either VA or the Contractor, or if existing safeguards have ceased to function, the discoverer shall bring the situation to the attention of the other party within one hour in accordance with Addendum B, VA Information and Information System Security/Privacy Language. VA Privacy and Security deliverables as directed by the VA System owner.
The Contractor shall comply with FedRAMP data management requirements.
Successful issuance of a VA ATO will be required before live VA data can be used in the system.
The Contractor shall participate in FedRAMP Continuous Monitoring activities as outlined by FedRAMP’s Continuous Monitoring Strategy Guide found on the FedRAMP Website.
The Contractor shall provide continuous monitoring activities including, but not limited to, scans, security artifacts, and provide Continuous Monitoring Monthly Scans and monthly Plan of Action and Milestones (POAM) reports as outlined by FedRAMP requirements.
The Contractor shall participate in monthly Agency and FedRAMP Sustainment meetings following the granting of a VA ATO.
The Contractor shall provide a Monthly VA License report of VA sites currently utilizing the cloud product post ATO award. The license report shall include the number of subscription licenses being utilized and the specific VA site where they’re in use.
Deliverables:
A. Continuous Monitoring Monthly Scans B. Plan of Action and Milestones Reports.
C. Monthly VA License Report
SECURITY AND PRIVACY REQUIREMENTS
POSITION/TASK RISK DESIGNATION LEVEL(S)
In accordance with VA Handbook 0710, Personnel Vetting Program, the position sensitivity and the level of background investigation commensurate with the required level of access for the following tasks within the PD are:
Position Sensitivity and Background Investigation Requirements by Service Task/Item Number Service Task / Item Number
| Tier 1 / Low Risk |
| Tier 2 / Moderate Risk |
| Tier 3 / High Risk |
| 1.1: Solution Implementation | ||
| ☒ | ||
| ☐ | ☐ | |
| 1.2: Ongoing Technical Support | ||
| ☒ | ☐ | ☐ |
The Tasks identified above and the resulting Position Sensitivity and Background Investigation requirements identify, in effect, the Background Investigation requirements for Contractor individuals, based upon the tasks the particular Contractor individual will be working. The submitted Contractor Staff Roster must indicate the required Background Investigation Level for each Contractor individual based upon the tasks the Contractor individual will be working, in accordance with their submitted proposal.
CONTRACTOR PERSONNEL SECURITY REQUIREMENTS
Contractor Responsibilities:
a. The Contractor shall prescreen all personnel requiring access to the computer systems to ensure they maintain the appropriate Background Investigation, and are able to read, write, speak, and understand the English language.
b. Within 3 business days after award, the Contractor shall provide a roster of Contractor and Subcontractor employees to the COR to begin their background investigations in accordance with the PAL template artifact. The Contractor Staff Roster shall contain the Contractor’s Full Name, Date of Birth, Place of Birth, individual background investigation level requirement (based upon Section 6.2.1 Tasks), as well as the following information IAW VAAR 852.204-72 Personnel Vetting and Credentialing:
i. Name of VA facility where Contractor/subcontractor employee works, if applicable.
ii. Date background check submitted for Contractor/subcontractor employee.
iii. Date PIV/identification card issued to Contractor/subcontractor employee.
iv. Contractor/subcontractor employee’s PIV/identification card number, as applicable.
v. Date Contractor/subcontractor employee no longer has need for PIV/identification card.
vi. Date Contractor notified VA that PIV/identification card is no longer required.
vii. Date Contractor returned PIV/identification card was returned to VA.
c. The Contractor shall submit associated full Social Security Numbers either within the Contractor Staff Roster or under separate cover to the COR. The Contractor Staff Roster shall be updated and provided to VA within 5 working days after the end of each calendar quarter, and within 1 day of any changes in employee status, training certification completion status, Background Investigation level status, additions/removal of employees, etc. throughout the Period of Performance. The Contractor Staff Roster shall remain a historical document indicating all past information and the Contractor shall indicate in the Comment field, employees no longer supporting this contract. The preferred method to send the Contractor Staff Roster or Social Security Number is by encrypted e-mail. If unable to send encrypted e-mail, other methods which comply with FIPS 140-2 (or its successor) are to encrypt the file, use a secure fax, or use a traceable mail service. (Note that by September 22, 2026, all FIPS 140-2 certificate validations will be placed on the Historical List. See FIPS Transition Effort Timeline for more details: https://csrc.nist.gov/projects/fips-140-3-transition-effort#schedule)
d. The Contractor should coordinate with the location of the nearest VA fingerprinting office through the COR. Only electronic fingerprints are authorized. The Contractor shall bring their completed Personnel Security Adjudication Center (PSAC) Fingerprint request form with them (see paragraph d.4. below) when getting fingerprints taken.
e. The Contractor shall ensure the following required forms are submitted to the COR within 5 days after contract award:
1. Optional Form 306
2. Self-Certification of Continuous Service
3. VA Form 0710
4. Completed PSAC Fingerprint Request Form
f. The Contractor personnel shall submit all required information related to their background investigations (completion of the investigation documents (SF85, SF85P, or SF 86) utilizing the Defense Counterintelligence and Security Agency (DCSA) National Background Investigation Services (NBIS) Electronic Application (eAPP) (formerly e-QIP) after receiving an email notification from the PSAC.
g. The Contractor employee shall certify and release the eAPP document, print, and sign the signature pages, and send them encrypted to the COR for electronic submission to the PSAC. These documents shall be submitted to the COR within 3 business days of receipt of the eAPP notification email. (Note: DCSA is moving towards a “click to sign” process. If click to sign is used, the Contractor employee should notify the COR within 3 business days that documents were signed via eAPP).
h. The Contractor shall be responsible for the actions of all personnel provided to work for VA under this contract. In the event that damages arise from work performed by Contractor provided personnel, under the auspices of this contract, the Contractor shall be responsible for all resources necessary to remedy the incident.
i. A Contractor may be granted unescorted access to VA facilities and/or access to VA Information Technology resources (network and/or protected data) with a favorably adjudicated Special Agreement Check (SAC), completed training delineated in VA Handbook 6500.6 (Appendix C, Section 4), signed “Contractor Rules of Behavior”, and with a valid, operational Personal Identity Verification (PIV) credential for PIV-only logical access to VA’s network. A PIV card credential can be issued once your SAC has been favorably adjudicated and your background investigation has been scheduled by DCSA. However, the Contractor will be responsible for the actions of the Contractor personnel they provide to perform work for VA. The investigative history for Contractor personnel working under this contract must be maintained in the database of DCSA.
j. The Contractor, when notified of an unfavorably adjudicated background investigation on a Contractor employee as determined by the Government, shall withdraw the employee from consideration in working under the contract.
k. Failure to comply with the Contractor personnel security investigative requirements may result in loss of physical and/or logical access to VA facilities and systems by Contractor and Subcontractor employees and/or termination of the contract for default.
l. PIV Credential Holders must follow all HSPD-12 policies and procedures as well as use and protect their assigned identity credentials in accordance with VA policies and procedures, displaying their badges at all times, and returning the identity credentials upon termination of their relationship with VA.
Deliverable:
A. Contractor Staff Roster
| Task |
| Deliverable ID |
| Deliverable Description |
| 6.2.2 |
| A |
| Contractor Staff Roster |
Due 3 days after contract award, updated within 5 working days after each calendar quarter, and updated throughout the PoP within 1 day of any changes to employee status.
Electronic submission to: VA PM, COR, CO.
Inspection: destination Acceptance: destination
ADDENDUM B – VA INFORMATION AND INFORMATION SYSTEM SECURITY/ PRIVACY LANGUAGE
NOTE: In the event of a conflict, VA Acquisition Regulation (VAAR) Security Clauses take precedence over the language in this Addendum B.
APPLICABLE SECTIONS TAILORED FROM: VA NOTICE 24-12, APRIL 22, 2024, UPDATE TO VA HANDBOOK 6500.6, CONTRACT SECURITY, APPENDIX C VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE, FOR INCLUSION INTO CONTRACTS, AS APPROPRIATE
GENERAL
This entire section applies to all acquisitions requiring any Information Security and Privacy language. Contractors, contractor personnel, Subcontractors and subcontractor personnel will be subject to the same federal laws, regulations, standards, VA directives and handbooks, as VA personnel regarding information and information system security and privacy.
VA INFORMATION CUSTODIAL LANGUAGE
a. The Government shall receive unlimited rights to data/intellectual property first produced and delivered in the performance of this contract or order (hereinafter “contract”) unless expressly stated otherwise in this contract. This includes all rights to source code and all documentation created in support thereof. The primary clause used to define Government and Contractor data rights is FAR 52.227-14 Rights in Data – General.
b. Information made available to the Contractor by VA for the performance or administration of this contract will be used only for the purposes specified in the service agreement, SOW, PWS, PD, and/or contract. The Contractor shall not use VA information in any other manner without prior written approval from a VA Contracting Officer (CO). The primary clause used to define Government and Contractor data rights is FAR 52.227-14 Rights in Data – General.
c. VA information will not be co-mingled with any other data on the Contractor’s information systems or media storage systems. The Contractor shall ensure compliance with Federal and VA requirements related to data protection, data encryption, physical data segregation, logical data segregation, classification requirements and media sanitization.
d. VA reserves the right to conduct scheduled or unscheduled audits, assessments, or investigations of Contractor Information Technology (IT) resources to ensure information security is compliant with Federal and VA requirements. The Contractor shall provide all necessary access to records (including electronic and documentary materials related to the contracts and subcontracts) and support (including access to Contractor and Subcontractor staff associated with the contract) to VA, VA's Office Inspector General (OIG), and/or Government Accountability Office (GAO) staff during periodic control assessments, audits, or investigations.
e. The Contractor may only use VA information within the terms of the contract and applicable Federal law, regulations, and VA policies. If new Federal information security laws, regulations or VA policies become applicable after execution of the contract, the parties agree to negotiate contract modification and adjustment necessary to implement the new laws, regulations, and/or policies.
f. The Contractor shall not make copies of VA information except as specifically authorized and necessary to perform the terms of the contract. If copies are made for restoration purposes, after the restoration is complete, the copies shall be destroyed in accordance with VA Directive 6500, VA Cybersecurity Program and VA Information Security Knowledge Service.
g. If a Veterans Health Administration (VHA)…
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