Draft_PWS.docx

Statement Of Work (PWS) Dry Cleaning for Privacy Curtain/Window Drapes Performance Work Statement (PWS) Dry Cleaning for Privacy Curtain/Window Drapes Performance Work Statement (PWS) Sterile Processing Services with Logistics for Blanchfield Army Community Hospital (BACH) / Sterile Processing Department (SPD)

1.0 INTRODUCTION/OVERVIEW

This contract is for stand-by sterile processing services for Blanchfield Army Community Hospital (BACH). The contractor of this performance work statement (PWS) has full authority to transport government property both on and off the “post” of Fort Campbell, Kentucky. Transport will be required between the contractor’s Offsite location and BACH whose principal place of business is 650 Joel Dr, Fort Campbell, KY 42223. Sterile Processing Division will transport instruments to the BACH Loading Dock, Hospital section 1DD02.

1.1 BACKGROUND

BACH requires sterile processing services for the Department of Surgery in support of patient care. BACH’s fixed facility SPD is unable to provide the sterile processing required. This contract will support the full sterile processing required to support BACH’s healthcare mission. It is the intent of the Contracting Office, on behalf of BACH to solicit, negotiate, and award a contract for a performance period not to exceed 18 months inclusive of option periods. This contract will serve to support the hospital for a temporary period until BACH’s fixed facility SPD can complete the actions required to ensure sterile processing meet all regulatory and patient safety requirements.

1.2 SCOPE

The Contractor shall provide all personnel, vehicles, equipment, tools, materials, supervision and other items necessary to perform the sterile processing of surgical medical instrumentation as described in this PWS. The Contractor shall have the tools and expertise to provide sterile processing services.

1.3 OBJECTIVES

The primary objective is to provide sterile processing services to the operating room and sterile processing department (SPD) within BACH when internal services are not available.

2.0 REQUIREMENTS

2.1 TASKS

2.1.1 The Contractor shall provide the Government’s sterilization, tracking, pick-up and delivery required for their medical surgical instrumentation trays, peel packs, sets, and Da Vinci Arms as provided, (collectively referred to as “Trays” in this Performance Work Statement (PWS)). The Contractor will provide the Government with the sterile processing services (tracking, cleaning, decontamination, assembly, and sterilization) for the Government owned, leased or consigned Trays, at their ORC in accordance with the terms and conditions set forth in this PWS. The Contractor will collect Trays from and deliver Trays processed to locations specified in paragraph 1.0 of this PWS, the collection and delivery points mutually agreed upon in by both parties.

· The following equivalency will be utilized in determine final quantities:

· DaVinci Arms: One (1) DaVinci Arm equates to one (1) Tray.

· Peel Packs: Ten (10) peel packs equate to one (1) Tray.

· HLD: Each cycle of HLD processing equates to one (1) Tray.

· Instrument Tray Wash Only Processing: Each wash only cycle equates to 0.5 Tray Sterilize Only Processing: Each sterilize only cycle equates to 0.5 Tray

2.1.2 The Contractor shall pick up all Trays at BACH’s SPD receiving area, and transport to the contractor’s facility to process and sterilize all medical surgical instrumentation trays provided and return to BACH SPD receiving area once sterilized. Once trays are picked up, the surgical instruments shall be returned to BACH SPD within 24 hours Monday-Thursday, and no greater than 72 hours for Friday pick-up and Monday delivery. Pickups and deliveries will be coordinated with the SPD department personnel and/or the Contract COR.

The Government will be responsible for purchasing new Trays and for maintaining, repairing, and replacing Trays unless otherwise contracted to do so with Contract Repair Services.

The Government will, within six (6) hours of delivery, (i) inspect all delivered Trays to ensure that they are in accordance with the delivery receipt and that they are visually acceptable (e.g. dry, packaging intact, wraps not torn or damaged, labels not missing or incomplete, and seals not broken) and (ii) check the external sterilization indicators. Any visual indicators identified as unacceptable by the Government during this inspection will be returned to Contractor. The Government will complete a Service Report, providing full details of the issue. When Trays are opened for use, and before the start of all procedures, the Government will conduct an inspection to confirm that Trays processed by Contractor are complete and fit for use and the Government will check all internal and external sterility indicators and labels. Any discrepancies will be reported immediately to Contractor by the Government by completing an electronic Service Report using the Software.

Contractor will not charge for Trays that are verified Contractor errors and are deemed unusable for surgery or cause a delay or cancellation of a scheduled surgery. Non-chargeable errors include the following and require mutual agreement of the Parties:

· Bioburden: Shall be reported to Contractor through a Service Report within two (2) hours of the finding. The Government will not spray the Tray with enzymatic solution or clean the bioburden prior to returning the Tray to the ORC for inspection and root cause analysis.

· Patient impacting case delay or cancellation: Shall be reported to Contractor through a Service Report within four (4) hours of the finding.

· Unusable Tray due to lack of sterility: Shall be reported to Contractor through a Service Report within four (4) hours of the finding.

Unserviceable items that are not deemed repairable must be brought to the attention of BACH and the SPD Department Chief and COR. Unserviceable items due to sterilizer machine malfunction, or any other damage or loss done at the sterile processing facility shall be replaced at Contractor's expense.

2.1.3 The Contractor shall ensure each Trays are sterile and meets all the American National Standards Institute/Association for the Advancement of Medical Instrumentation (ANSI/AAMI) guidelines and standards as well as Occupational Safety and Health Administration (OSHA) and The Joint Commission (TJC) guidelines and standards.

2.1.4 The contractor shall ensure that the trailer or truck used to transport soiled or clean instruments meets requirements outlined in ANSI/AAMI, OSHA and TJC guidelines with respective to keeping sterilized instrumentation separate from contaminated instrumentation.

2.1.5 The Contractor shall maintain a system of records as to work performed sufficient to respond to request by the Government.

2.1.6 The contractor shall monitor the temperature and humidity in the transport vehicle when transporting sterile instrumentation in accordance with ANSI/AAMI standards.

2.1.8 The contractor shall package and sterilize all instrumentation. Many instruments may be identified for clinic use outside of BACH. Contractor will Coordinate and maintain live inventory of all materials and instruments through existing and suitable electronic Software tracking systems currently in use by or acceptable to the Government.

2.1.9 The contractor shall peel pack and sterilize any excess instrumentation discovered during the Quality Assurance/Quality Control (QA/QC) process.

2.1.10 The contractor shall allow all instrumentation to cool as recommended by ANSI/AAMI standards before being bagged and placed into transport carts.

2.1.11 Data requirements for Sterile Processing Services: Prior to the Commencement Date, the Government and Contractor shall establish the protocol to be followed by each Party regarding inventory data to be uploaded to Contractor’s software system, brand name or equal to SynergyTrak (“Software”). The format of the inventory data will be consistent with the content and format detailed required by the Contractor’s software to track all Trays. After the Parties have confirmed and validated that this data is complete and correct, the Contractor will upload the agreed upon Product inventory data into their software.

· After entry into the Contractor’s software, the Government shall verify and confirm that the data uploaded into the software is complete and correct.

· If Government has instrument Tray barcodes are compatible with the Contractor’s software, no additional barcoding will be required. Otherwise, the Government will attach identification barcode tags to Trays to be processed by the Contractor. The Parties agree that if additional barcoding is required, the barcodes shall be attached completed prior to the effective start date of the contract. The Contractor shall assist Government with the attachment of identification barcode tags.

· The Contractor shall provide and maintain access to live inventory tracking of items via existing government assets, to support the tracking of all sterilization Trays to be completed and agreed upon by both parties prior to effective date. In order to effectively process and return Trays in their correct condition it is essential that tray build sheets accurately reflect the contents, tray set up and include any appropriate details and/or processing instructions relevant to that tray, thereby removing any misunderstanding and/or ambiguity regarding the actual contents and processing requirements of the Trays during the decontamination, inspection and packing process. Contractor provided layouts are necessary in order to accurately load instrument and other relevant information into the Software At a minimum the Contractor shall provide a completed and verified inventory management acknowledgement of items received and delivered.

· The Contractor with Government concurrence shall perform count sheet audits and rectify tray inventory count sheets prior to completing data transfer to the ORC SynergyTrak or brand name equivalent software system.

· The Contractor shall provide Training & Education as required in the use of the Hospitals inventory management system to all the identified Government employees on how to use the SynergyTrak, name brand or equivalent system and ensure the Government’s SPD Team have been trained on the identification and preparation of tray process

2.1.12 The Contractor will provide sterilization services offsite at its ORC for Trays used by the Government at the Government’s facilities.

2.1.13 The Contractor will schedule meetings as needed, to be held virtually or in-person at the Government’s facilities, prior to the effective date to evaluate various processes and provide guidance to the Government for best practices for the transition from onsite processing to offsite processing.

2.1.14 The Contractor will be responsible for the transportation of used Trays between the Collection and Delivery Points to the ORC and transportation of processed Trays from the ORC to the Collection and Delivery Points specified in paragraph 1.0 of this PWS.

2.1.15 If applicable, the Contractor will assist the Government with developing a process for creating barcodes, printing barcodes, and placing barcode tags on trays.

2.1.16 The Contractor will provide transfer carts needed for transferring Trays to and from the ORC.

2.1.17 The Contractor will not transfer any clinical waste on behalf of the Government.

2.1.18 The Contractor will scan the transfer carts at the Collection and Delivery Points using their software to record collection and delivery of the transported Trays.

2.1.19 The Contractor will clean, decontaminate, assemble, and sterilize Trays in accordance with AAMI guidelines and Instrument manufacturers’ instructions for use. Trays will be wrapped or containerized (where compliant containers are provided by the Government) and individual or small supplementary instrument packs will be sealed in peel packs or similar materials in accordance with manufacturers’ instructions for use.

2.1.20 The Contractor will perform instrument return quality audits to validate that the Government adheres to the Instrument Return Protocol and other requirements of this PWS. In the event there are any deviations, the Contractor will create a Government Service Report in the Software for identifying and recording the Government’s Service Reports for attention and corrective actions by the Government.

2.2 DELIVERABLES

2.2.1 Pick-Up/ Delivery Procedures. The Contractor shall perform a joint inventory of medical surgical instrument trays and peel packs prior to taking custody of items to be sterilized. The Contractor shall annotate the number of medical surgical instrument trays and peel packs received for sterilizing with concurrence from the requiring activities representative. All medical surgical instrument trays and peel packs processed under this contract shall be picked up/dropped off every daily or as coordinated with the SPD Department. There will be only one pick up site, BACH, Exact Address add Attachment with Map (Sterile Processing Department – Receiving Area) located in paragraph 1.0 and Exhibit ##.. The Contractor may coordinate with the COR to determine the best times to pick up and deliver.

Daily Pick-up and Drop-off times shall be an afternoon pick-up no earlier than 1400 EST and latest 2200 EST. If there is a cancellation of any pick-up, the Government must notify the Contractor 12 hours before the pick-up that is to be cancelled. Communication for cancellation must be emailed to a provided list of Contractor contacts. The Contractor and the Government will review, discuss, and agree upon the pick-up and delivery times for routine pick-up and deliveries scheduled on a Federal Holiday (para 2.3.4).

2.3 SCHEDULE

2.3.1 Period of Performance: Is for Not to Exceed (NTE) 18 months from the date of award.

2.3.2 Pick-up and Delivery Schedule: Services for BACH to be provided within 48 hours of notification and agreement all tracking requirements are completed and accurate by both parties in accordance with paragraph 2.2. Services will continue until the end of the contract term, extend if optional terms are required, or otherwise discontinued through required contractual notification and processes.

2.3.3 SPD’s Hours of Operations: 24 hours a day – 7 days a week.

2.3.4 The following Government Holidays are observed:

New Year’s Day, January 1.

Note: Any of the above holidays falling on a Saturday will be observed on the preceding Friday; holidays falling on a Sunday will be observed on the following Monday. Any holidays that are declared by Presidential Executive Order shall be observed in the same manner as the holidays listed above. If SPD is closed on any day other than the holidays noted above, SPD shall notify the Contractor at least a two-day notice of the closure date. Closures of the installation due to inclement weather or other such acts of God, shall be handled in the same manner.

2.4 QUALITY CONTROL PROGRAM

2.4.1 Quality Control Program (QCP). The Contractor shall establish and maintain a complete QCP to verify the requirements of the contract are provided as specified. The plan shall include procedures to implement all requirements of the contract, which shall include the in-processing of the medical surgical instrument sterilizing processes and the following:

2.4.2 The Contractor shall have an inspection system covering all the services required by this contract which must specify the areas to be inspected on either a scheduled or unscheduled basis, how often inspection will be accomplished and documented, and the name and title of the individual who will perform the inspection.

2.4.3 The Contractor shall establish methods of identifying and preventing defects in the quality of service performed before the level of performance becomes unacceptable. This will include procedures for a method of inspection to assure proper temperatures, chemical rinse, detergents and other additives are adhered to.

2.4.4 The Contractor shall maintain records of all quality control inspections conducted by the Contractor and corrective action taken to prevent continued reoccurrence of deficiencies. This documentation shall be made available to the COR or Contracting Officer during the term of the contract. The Contractor shall provide its Quality Control Reports and Infection Control Reports on the last working day of each month to the COR throughout the duration of this contract.

2.4.5 The Contractor shall have a plan to keep Trays segregated and returned to BACH in accordance with their inspection status, such as accepted, rejected, set aside for re-cleaning, and awaiting decision by the COR, to prevent intermixing and unauthorized use.

Contractor Key Performance Indicators

1. Production Based. All Trays to be returned to the Government as outlined in paragraph 2. Services of this PWS

2. Quality Based. Service Reports (SR) to be created by the Government in real time using the Government portal of the Software. These reports will be addressed once received at the ORC. All Service Reports, and comments, are visible in the Government Portal for leadership to review. Classification examples are outlined below:

a) Collection Error

b) Communication

c) Damaged Wrap/ Pack

d) Delivery Error

e) Dirty Item

f) Extra item

g) Incorrect assembly

h) Incorrect labelling

i) Incorrect packing specification

j) Item requiring repair/ worn item

k) Missing consumable

l) Missing item

m) Wet pack

n) Wrong item Upon return to the ORC, the SR will be checked against the Tray and remedial actions will be taken and documented by Contractor to address the SR. The total number of confirmed defects will be divided by the total Tray volume to establish the percentage of defects attributable to Contractor. The goal is a defect rate of 1% or below.

The Government Key Performance Indicators

1. Production Based. Contractor and The Government will review volume of Trays processed weekly to adhere to capacity or total sterilization Trays agreed upon in the contract. Provide identification of any overages and pay any associated and proposed prices for volumes above contractual agreed weekly capacity.

2. Quality Based. The Government Service Reports (CSRs) will be created by Contractor in real time using the Software. The filing of the CSR will automatically send an email to the Government Leadership identified within Software. Each report will be addressed by the Government to include responses to questions posted by Contractor. All CSRs created and comments are visible in the Government Portal for leadership to review. Example classifications are outlined below:

a) Bar code missing

b) Cart overload

c) Damaged item requiring repair

d) Extra item in Tray

e) Gross debris present

f) Incorrect instrument code on count sheet

g) Items not scanned to cart

h) Missing items

i) Scanned items missing from cart

j) Sharps returned to Tray

k) Tray list missing or not checked

l) Unacceptable condition

m) Wrong item in Tray

3. The number of CSRs created will be divided by the total Product volume to establish the percentage of defects attributable to the Government. The goal is a defect rate of 1% or below. Contractor will adhere to established pickup and delivery times of twenty-four hours, with deviation >5%. Contractor will monitor contaminated sets for bioburden, detergent and water stains, and foreign materials, with deviation of >5%. Contractor will check for perforations in peel packs and blue wraps with 0 deviations. Contractor will adhere to class 1-5 indicators, both internal and external, for surgical sets, wraps, and peel pack items with 0 deviations. Contractor will verify that sets are properly assembled, including stringer instruments, protective devices on sharp instruments, no dropped filters in pans and secure instrument wraps with 0 deviation.

2.5 EMPLOYEES AND EXPERIENCE.

2.5.1 Contractor personnel shall present a neat appearance and must be easily recognizable as an employee of the Contractor. This may be accomplished by wearing distinctive clothing bearing the name of the company, or by wearing appropriate badges or identification tags which contain the company name. This applies to any individual that enters the military installation under this contract.

2.5.2 The Contractor will ensure that employees have the following current and valid professional certifications before starting work. For all trucks exceeding 26,001 lbs. Maximum capacity, a certified Commercial Driver’s License will be necessary for each driver.

2.5.3 The Contractor shall adhere to Army Regulation (AR) 40-1 regarding the employment of Government personnel.

2.5.4 The contractor will ensure it meets all Department of Transportation (DOT) requirements for transporting infectious waste.

2.6 CONTINGENCY PLAN

2.6.1 The Contractor shall have the responsibility of notifying the COR if at any time the plan is changed. The Contractor shall notify the COR of any event that jeopardizes performance under this contract. The plan shall include contingency operations for:

2.6.2 Mobilization. If mobilization and services are required beyond the Contractor’s capability to provide services, the Contractor shall advise the COR of the capability and additional volume, which the Contractor can obtain from the local civilian community. Mobilizations that extend beyond the normal contract purview may be subject to a claim by the Contractor for the additional cost incurred as agreed upon by the Contracting Officer.

2.6.3 Labor Disputes. In the event of a labor dispute, the Contractor’s responsibility to provide the service will not be terminated. The Contractor shall provide the COR his/her strike or other employee job action contingency plan to continue performance of service without interruption or degradation in the quality of service. In the event of a strike or other labor dispute interference with timely contract performance, the Contractor shall immediately notify the COR and initiate action under the contingency plan.

2.6.4 Disaster. In the event of a disaster, to include but not limited to destruction of the facility, sabotage, or an act of God or nature that renders the Contractor’s facility unsafe, the Contractor shall determine feasible alternative method of providing services and make recommendations to the COR.

2.6.5 Severe Weather Plan. The Contractor shall establish a severe weather plan with procedures of providing the services to BACH.

3.0 GOVERNMENT FURNISHED PROPERTY

The Government will provide the property and the services listed herein:

3.1.1 Forms and Publications. The Government will provide authorized Army (Military) forms, Department of Defense (DOD) Defense Health Agency (DHA) publications, and services specifically identified in this contract. All commercial, industry publications related to the performance of medical surgical instrumentation sterilizing process / service shall be provided by the Contractor.

3.1.2 The Government will provide instruments to be sterilized either by trays or peel packs, including the bags that the contaminated items will be stored in during the transport process.

3.1.3 The Government will provide medical surgical instrument trays that are commercially acceptable and serviceable. Contractor shall return clean sterilized medical surgical instrument trays to BACH.

3.1.4 The Government will provide inventory data for information purposes only.

3.1.5 Any damaged equipment identified during reprocessing will be tagged, bagged, and transported back to BACH along with the original set. BACH will provide peel-packed items to accompany the surgical case carts to offset the count sheets. Items not included in the surgical sets due to damage or maintenance will be labeled with an identifiable tag, allowing BACH’s SPD to send accompanying peel packs to reconcile the count sheet. This will simplify the accountability of individual items and enable BACH to maintain positive control of its durable instrumentation. Before resending the set, BACH personnel will replace the broken item to correctly update the count sheet.

3.1.6 The Government will adhere to the Tray Protocol outlined and provided by the Contractor to ensure proper handling and transporting of the Trays. In the event the Government cannot performance a specified requirement the parties will meet with the Contracting Officer (KO) to determine mutual agreed upon changes to the contract.

3.2 CONTRACTOR FURNISHED ITEMS.

In addition to items specified elsewhere in the contract, the Contractor shall furnish:

3.2.1 The Contractor shall provide all property or services necessary for the performance of this contract that is not specifically identified as furnished by the Government. Such property or services shall include, but is not limited to facilities, tools, materials, equipment.

3.2.2 The Contractor shall provide their employees all appropriate protective clothing as required by OSHA.

3.2.3 Pick-up and Delivery Vehicles. Pick-up and delivery vehicles with proper temperature and humidity to maintain sterility of instruments in accordance with ANSI/AAMI standards. Contaminated instruments will be kept separate from sterile instruments. If sterile instruments will occupy a once previously occupied contaminated instruments, it will be properly disinfected in accordance with recommended standards and guidelines.

3.2.4 Storage space for Government provided medical surgical instrument trays, necessary for performance of this contract. The Contractor shall provide adequate storage for all Government materials and equipment in such a manner as to maintain proper identification, prevent damage to items, protect items from soiling and other unsanitary conditions, and maintain segregation of items as required by the contract.

3.2.5 The Contractor shall provide tracking methods that will be by written or electronic means for each medical surgical instrument tray and peel pack delivered to BACH. This document shall identify the contents in the medical surgical instrument tray or peel pack by item count for each type of item in the medical surgical instrument tray.

3.2.6 A facility equipped and ventilated to prevent dissemination of contaminants. The ventilation system shall include adequate intake filtration, exchange rate, and exhaust in accordance with local, state, and federal requirements (Joint Commission). The Contractor's facility shall be subject to inspection of sanitary conditions at any time by an authorized representative of the Government.

4.0 SECURITY REQUIREMENTS

4.1.1 The Contractor shall furnish a list of all employees entering the military facilities at least five (5) calendar days prior to the start of contract performance. The list shall include the full name and work assignment of each employee. The Contractor shall notify the respective COR of all additions, deletions, or changes at least five (5) days in advance of such changes whenever practicable, or as soon thereafter as is reasonably practicable.

4.1.2 Contractor Employee Compliance. The Contractor shall ensure that Contractor’s employees entering the military installation observe and comply with all Army policies, regulations, and procedures concerning fire, safety, environmental protection, sanitation, security, traffic, parking, flag courtesy, “off limits” areas, and possession of firearms or other lethal weapons.

4.1.3

4.1.4 GATE CONTROL. The award of this contract does not bestow a right to have access to any military installation. Unscheduled gate closures by the Security Police may occur at any time and personnel entering or leaving the installation may experience delays. All vehicles are subject to search while on federal installations pursuant to current directives. Although delays due to the Government cannot be held against the Contractor, the Contractor shall ensure delivery is scheduled in time to allow for these inspections. Any violation of installation regulation, state or federal statue may result in the termination of the privilege to enter one or more military installations.

4.1.5 GATE ACCESS. All commercial vehicles, vans and larger, will be required to enter BACH Main Post through Gates 4 or 7. Gates 4 and 7 hours of operation are 7 days a week 24 hours a day. Commercial vehicles are expected to complete their business and exit Fort Campbell through any Gate applicable to their direction of travel. Commercial vehicles may be searched. Upon entry of the installation drivers will be required to show photo identification. Upon award, Contractor will provide all information required to obtain an Air Assault Gate Pass for contract employees requiring post access (SEE APPENDIX ONE)

4.1.6 DOCK OPERATIONS. Upon arrival at BACH drivers will notify the warehouse personnel of their arrival. Personnel from the warehouse must be present at all times with the driver while the driver is performing loading and unloading procedures.

4.1.7 LOST ITEMS. All lost articles/hospital instruments, etc., found by the Contractor employees shall be turned over to the COR.

4.1.8 AT LEVELI TRAINING. All contractor employees, to include subcontractor employees, requiring access Army installations, facilities and controlled access areas shall complete AT Level I Awareness training within calendar days after contract start date or effective date of incorporation of this requirement into the contract, whichever is applicable. The contractor shall submit certificates of completion for each affected contractor employee And subcontractor employee, to the COR or to the contracting officer, if a COR is not assigned, within calendar days after completion of training by all employees and subcontractor personnel. AT level I Awareness training is available at the following website: http://jko.jten.mil.

4.1.9 2. ACCESS AND GENERAL PROTECTION/SECURITY POLICY AND PROCEDURES. This standard language is for contractor employees with an area of performance within Army controlled installation, facility, or area. Contractor and all associated subcontractor employees shall provide all information required for background checks to meet installation access requirements to be accomplished by installation Provost Marshal Office, Director of Emergency Services or Security Office. Contractor workforce must comply with all personal identity verification requirements (FAR clause 52.204‐9, Personal Identity Verification of Contractor Personnel) as directed by DOD, HQDA and/or local policy. In addition to the changes otherwise authorized by the changes clause of this contract, should the Force Protection.

4.1.9.3 FOR CONTRACTORS REQUIRINGCOMMAN ACCESS CARD (CAC. Before CAC issuance, the contractor employee requires, at a minimum, a favorably adjudicated National Agency Check with Inquiries (NACI) or an equivalent or higher investigation in accordance with Army Directive 2014‐05. The contractor employee will be issued a CAC only if duties involve one of the following: (1) Both physical access to a DoD facility and access, via logon, to DoD networks on‐site or remotely; (2) remote access, via logon, to a DoD network using DoD‐approved remote access procedures; or (3) physical access to multiple DoD facilities or multiple non‐DoD federally controlled facilities on behalf of the DoD on a recurring basis for a period of 6 months or more. At the discretion of the sponsoring activity, an Initial CAC may be issued based on a favorable review of the FBI fingerprint check and a successfully scheduled NACI at the Office of Personnel Management

4.9.4 FOR CONTRACTORS THAT DO NOT REQUIRE CAC, BUT REQUIRE ACCESS TO A DOD FACILITY OR INSTALLATION. Contractor and all associated sub‐contractors employees shall comply with adjudication standards and procedures using the National Crime Information Center Interstate Identification Index (NCIC‐III) and Terrorist Screening Database (Army Directive 2014‐05/AR 190‐13), applicable installation, facility and area commander installation/facility access and local security policies and procedures (provided by government representative); or, at OCONUS locations, in accordance with status of forces agreements and other theater regulations.

4.9.5. AT Awareness Training for Contractor Personnel Traveling Overseas. This standard language required US based contractor employees and associated subcontractor employees to make available and to receive Government provided area of responsibility (AOR)-specific AT awareness training.

4.9.6 iWATCH TRAINING. The contractor and all associated sub‐contractors shall brief all employees on the local iWATCH Army program (training standards provided by the requiring activity ATO). This local developed training will be used to inform employees of the types of behavior to watch for and instruct employees to reportsuspicious activity to the COR. This training shall be completed within 30 calendar days of contract award and within 7 calendar days of New employees commencing performance with the results reported to the COR NLT 7 calendar days after contract award.