P02 -DRAFT PWS _HIG25-30 NDS HIA Services_Rev 12_06_24.docx
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- R408--National Data Systems (NDS) Health Information Access (HIA) support (VA-25-00032565)
- Solicitation number
- 36C77625Q0078
About this file
This is a draft Performance Work Statement (PWS) for the VA's National Data Systems (NDS) Health Information Access (HIA) Services program, accompanied by a Sources Sought Notice seeking industry feedback by January 20, 2025. The requirement seeks contractor support to manage regional and national access to VHA health information resources, including data access requests, help desk support, data sharing agreements, and business associate agreement support. The period of performance is a 12-month base period with four 12-month options.
Key requirements include reviewing and processing data access requests within 3 business days, providing Tier 2 help desk support (optional task), managing approximately 467 active Business Associate Agreements, and ensuring compliance with VA security and privacy requirements. The work will primarily be performed at contractor facilities with limited government site access at VACO in Washington, DC. The contractor must provide trained personnel with appropriate background investigations and security clearances. Historical workload data indicates processing of approximately 8,000 healthcare operations requests, 4,000 CAPRI/Joint Longitudinal Viewer requests, 5,000 Power of Attorney requests, and 3,300 research requests annually. The NAICS code is 541611 with a $24.5M size standard, and the notice indicates potential set-aside considerations based on market research responses.
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NDS HIA Services
HIG20-25
PERFORMANCE WORK STATEMENT (PWS)
DEPARTMENT OF VETERANS AFFAIRS
Digital Health Office (DHO), Office of Health Informatics (OHI)
Health Information Governance (HIG) National Data Systems (NDS)
National Data Systems (NDS) Health Information Access (HIA) Services
HIG20-25
Date: 12/06/2024 PWS Version Number: 2.1
Contents
| 1.0 | BACKGROUND | 3 |
| 2.0 | APPLICABLE DOCUMENTS | 3 |
| 3.0 | SCOPE OF WORK | 7 |
| 4.0 | PERFORMANCE DETAILS | 7 |
| 4.1 | PERFORMANCE PERIOD | 7 |
| 4.2 | PLACE OF PERFORMANCE | 8 |
| 5.0 | SPECIFIC TASKS AND DELIVERABLES | 9 |
| 5.1 | VHA User Access Management and Support | 10 |
| 5.1.1 | Data Access Requests | 10 |
| 5.1.2 | Help Desk Support (OPTIONAL TASK) | 11 |
| 5.1.3 | Data Sharing Agreements (OPTIONAL TASK) | 11 |
| 5.1.4 | Historical/Projected Workload Data: | 12 |
| 5.2 | Business Associate Agreement (BAA) Support | 14 |
| 5.3 | Reporting Requirements | 15 |
| 6.0 | GENERAL REQUIREMENTS | 16 |
| 6.1 | KEY PERSONNEL | 16 |
| 6.2 | ENTERPRISE AND IT FRAMEWORK | 17 |
| 6.2.1 | ONE-VA TECHNICAL REFERENCE MODEL | 17 |
| 6.2.2 | FEDERAL IDENTITY, CREDENTIAL, AND ACCESS MANAGEMENT (FICAM) | 17 |
| 6.2.3 | INTERNET PROTOCOL VERSION 6 (IPV6) | 18 |
| 6.2.4 | TRUSTED INTERNET CONNECTION (TIC) | 19 |
| 6.2.5 | STANDARD COMPUTER CONFIGURATION | 19 |
| 6.2.6 | VETERAN FOCUSED INTEGRATION PROCESS (VIP) | 20 |
| 6.2.7 | PROCESS ASSETT LIBRARY (PAL) | 20 |
| 6.3 | SECURITY AND PRIVACY REQUIREMENTS | 20 |
| 6.3.1 | POSITION/TASK RISK DESIGNATION LEVEL(S) | 20 |
| 6.3.2 | CONTRACTOR PERSONNEL SECURITY REQUIREMENTS | 21 |
| 6.4 | METHOD AND DISTRIBUTION OF DELIVERABLES | 23 |
| 6.5 | PERFORMANCE METRICS | 23 |
| 6.6 | FACILITY/RESOURCE PROVISIONS | 24 |
| 6.7 | GOVERNMENT FURNISHED PROPERTY | 25 |
| ADDENDUM A – ADDITIONAL VA REQUIREMENTS, CONSOLIDATED | 27 | |
| ADDENDUM B – VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE | 34 |
BACKGROUND
National Data Systems (NDS) is responsible for ensuring that access to health information is managed in accordance with VA policy and Federal law, including the Privacy Act of 1974, http://www.justice.gov/opcl/privstat.htm and the Health Insurance Portability and Accountability Act (HIPAA) http://www.hhs.gov/ocr/privacy/. NDS is located within Veterans Health Administration (VHA) Office of Health Informatics (OHI) Health Information Governance (HIG). NDS manages the development and implementation of policy, regulation, and training around individuals accessing health information.
NDS manages all national health information data access requests as well as data queries and supports the reporting of VHA health information access, file extracts, Data Use Agreements (DUAs), and other related data access agreements. NDS responds to multiple requests for access to many of VHA’s health information systems, including Electronic Health Records (EHRs), national databases, and extracted datasets. The goal of NDS is to provide those who serve Veterans, proper access to the informational resources they need, while always maintaining the privacy and security of Veterans’ health information. Access may be required on a temporary or long-term basis.
NDS is the central program for managing, tracking and approving all VHA data access requests to many of VHA’s health information resources. NDS approves user access to national data which contains Personal Health Information (PHI) to include the Veteran’s social security number. NDS fulfills requests from VHA health information resources to various Government customers including, but not limited to, clinicians, program offices, researchers, government oversight organizations. Non-Government customers include but are not limited to Veteran Service Organizations (VSO) access in order to advocate for Veterans with their claims for benefits. NDS is involved in data access activities and initiatives which manage the development and implementation of policy, regulation, training and the evaluation and monitoring of trending, and reporting on data access performance.
APPLICABLE DOCUMENTS
In the performance of the tasks associated with this Performance Work Statement, the Contractor shall comply with the following:
1. “Federal Information Security Modernization Act of 2014”
2. Federal Information Processing Standards (FIPS) Publication 140-2, “Security Requirements for Cryptographic Modules”
3. FIPS Pub 199. Standards for Security Categorization of Federal Information and Information Systems, February 2004
4. FIPS Pub 200, Minimum Security Requirements for Federal Information and Information Systems, March 2016
5. FIPS Pub 201-2, “Personal Identity Verification of Federal Employees and Contractors,” August 2013
6. 10 U.S.C. § 2224, "Defense Information Assurance Program"
7. Carnegie Mellon Software Engineering Institute, Capability Maturity Model® Integration for Development (CMMI-DEV), Version 1.3 November 2010; and Carnegie Mellon Software Engineering Institute, Capability Maturity Model® Integration for Acquisition (CMMI-ACQ), Version 1.3 November 2010
8. 5 U.S.C. § 552a, as amended, “The Privacy Act of 1974”
9. Public Law 109-461, Veterans Benefits, Health Care, and Information Technology Act of 2006, Title IX, Information Security Matters
10. 42 U.S.C. § 2000d “Title VI of the Civil Rights Act of 1964”
11. VA Directive 0710, “Personnel Security and Suitability Program,” June 4, 2010, https://www.va.gov/vapubs/
12. VA Handbook 0710, Personnel Security and Suitability Security Program, May 2, 2016, https://www.va.gov/vapubs/
13. VA Directive and Handbook 6102, “Internet/Intranet Services,” July 15, 2008
14. 36 C.F.R. Part 1194 “Electronic and Information Technology Accessibility Standards,” July 1, 2003
15. Office of Management and Budget (OMB) Circular A-130, “Managing Federal Information as a Strategic Resource,” July 28, 2016
16. 32 C.F.R. Part 199, “Civilian Health and Medical Program of the Uniformed Services (CHAMPUS)”
17. An Introductory Resource Guide for Implementing the Health Insurance Portability and Accountability Act (HIPAA) Security Rule, October 2008
18. Sections 504 and 508 of the Rehabilitation Act (29 U.S.C. § 794d), as amended by the Workforce Investment Act of 1998 (P.L. 105-220), August 7, 1998
19. Homeland Security Presidential Directive (12) (HSPD-12), August 27, 2004
20. VA Directive 6500, “VA CYBER SECURITY PROGRAM,” February 24, 2021
21. VA Handbook 6500, “Risk Management Framework for VA Information Systems VA Information Security Program,” February 24, 2021
22. VA Handbook 6500.1, “Electronic Media Sanitization,” November 03, 2008
23. VA Handbook 6500.2, “Management of Breaches Involving Sensitive Personal Information (SPI)”, June 30, 2023
24. VA Handbook 6500.3, “Assessment, Authorization, And Continuous Monitoring of VA Information Systems,” February 3, 2014
25. VA Handbook 6500.5, “Incorporating Security and Privacy in System Development Lifecycle”, March 22, 2010
26. VA Handbook 6500.6, “Contract Security,” March 12, 2010
27. VA Handbook 6500.8, “Information System Contingency Planning”, April 6, 2011
28. OI&T Process Asset Library (PAL), https://www.va.gov/process/ . Reference Process Maps at https://www.va.gov/process/maps.asp and Artifact templates at https://www.va.gov/process/artifacts.asp
29. One-VA Technical Reference Model (TRM) (reference at https://www.va.gov/trm/TRMHomePage.aspx)
30. VA Directive 6508, “Implementation of Privacy Threshold Analysis and Privacy Impact Assessment,” October 15, 2014
31. VA Handbook 6508.1, “Procedures for Privacy Threshold Analysis and Privacy Impact Assessment,” July 30, 2015
32. VA Handbook 6510, “VA Identity and Access Management”, January 15, 2016
33. VA Directive 6300, Records and Information Management, September 21, 2018
34. VA Handbook, 6300.1, Records Management Procedures, March 24, 2010
35. NIST SP 800-37, Guide for Applying the Risk Management Framework to Federal Information Systems: A Security Life Cycle Approach, June 10, 2014
36. NIST SP 800-53 Rev. 4, Security and Privacy Controls for Federal Information Systems and Organizations, January 22, 2015
37. OMB Memorandum, “Transition to IPv6”, September 28, 2010
38. VA Directive 0735, Homeland Security Presidential Directive 12 (HSPD-12) Program, October 26, 2015
39. VA Handbook 0735, Homeland Security Presidential Directive 12 (HSPD-12) Program, March 24, 2014
40. OMB Memorandum M-06-18, Acquisition of Products and Services for Implementation of HSPD-12, June 30, 2006
41. OMB Memorandum 04-04, E-Authentication Guidance for Federal Agencies, December 16, 2003
42. OMB Memorandum 05-24, Implementation of Homeland Security Presidential Directive (HSPD) 12 – Policy for a Common Identification Standard for Federal Employees and Contractors, August 5, 2005
43. OMB memorandum M-11-11, “Continued Implementation of Homeland Security Presidential Directive (HSPD) 12 – Policy for a Common Identification Standard for Federal Employees and Contractors, February 3, 2011
44. OMB Memorandum, Guidance for Homeland Security Presidential Directive (HSPD) 12 Implementation, May 23, 2008
45. Federal Identity, Credential, and Access Management (FICAM) Roadmap and Implementation Guidance, December 2, 2011
46. NIST SP 800-116, A Recommendation for the Use of Personal Identity Verification (PIV) Credentials in Physical Access Control Systems, November 20, 2008
47. OMB Memorandum M-07-16, Safeguarding Against and Responding to the Breach of Personally Identifiable Information, May 22, 2007
48. NIST SP 800-63-3, 800-63A, 800-63B, 800-63C, Digital Identity Guidelines, June 2017
49. NIST SP 800-157, Guidelines for Derived PIV Credentials, December 2014
50. NIST SP 800-164, Guidelines on Hardware-Rooted Security in Mobile Devices (Draft), October 2012
51. Draft National Institute of Standards and Technology Interagency Report (NISTIR) 7981 Mobile, PIV, and Authentication, March 2014
52. VA Memorandum, VAIQ #7100147, Continued Implementation of Homeland Security Presidential Directive 12 (HSPD-12), April 29, 2011 (reference https://www.voa.va.gov/documentlistpublic.aspx?NodeID=514)
53. IAM Identity Management Business Requirements Guidance document, May 2013, (reference Enterprise Architecture Section, PIV/IAM (reference https://www.voa.va.gov/documentlistpublic.aspx?NodeID=514)
54. VA Memorandum “Mandate to meet PIV Requirements for New and Existing Systems” (VAIQ# 7712300), June 30, 2015, https://www.voa.va.gov/DocumentView.aspx?DocumentID=4846
55. Trusted Internet Connections (TIC) Reference Architecture Document, Version 2.0, Federal Interagency Technical Reference Architectures, Department of Homeland Security, October 1, 2013, https://s3.amazonaws.com/sitesusa/wp-content/uploads/sites/482/2015/04/TIC_Ref_Arch_v2-0_2013.pdf
56. OMB Memorandum M-08-05, “Implementation of Trusted Internet Connections (TIC), November 20, 2007
57. OMB Memorandum M-08-23, Securing the Federal Government’s Domain Name System Infrastructure, August 22, 2008
58. VA Memorandum, VAIQ #7497987, Compliance – Electronic Product Environmental Assessment Tool (EPEAT) – IT Electronic Equipment, August 11, 2014 (reference Document Libraries, EPEAT/Green Purchasing Section, https://www.voa.va.gov/documentlistpublic.aspx?NodeID=552)
59. Sections 524 and 525 of the Energy Independence and Security Act of 2007, (Public Law 110–140), December 19, 2007
60. Section 104 of the Energy Policy Act of 2005, (Public Law 109–58), August 8, 2005
61. Executive Order 13693, “Planning for Federal Sustainability in the Next Decade”, dated March 19, 2015
62. Executive Order 13221, “Energy-Efficient Standby Power Devices,” August 2, 2001
63. VA Directive 0058, “VA Green Purchasing Program”, July 19, 2013
64. VA Handbook 0058, “VA Green Purchasing Program”, July 19, 2013
65. Office of Information Security (OIS) VAIQ #7424808 Memorandum, “Remote Access”, January 15, 2014, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28
66. Clinger-Cohen Act of 1996, 40 U.S.C. §11101 and §11103
67. VA Memorandum, “Implementation of Federal Personal Identity Verification (PIV) Credentials for Federal and Contractor Access to VA IT Systems”, (VAIQ# 7614373) July 9, 2015, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28
68. VA Memorandum “Mandatory Use of PIV Multifactor Authentication to VA Information System” (VAIQ# 7613595), June 30, 2015, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28
69. VA Memorandum “Mandatory Use of PIV Multifactor Authentication for Users with Elevated Privileges” (VAIQ# 7613597), June 30, 2015; https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28
70. “Veteran Focused Integration Process (VIP) Guide 2.0”, May 2017, https://www.voa.va.gov/DocumentView.aspx?DocumentID=4371
71. “VIP Release Process Guide”, Version 1.4, May 2016, https://www.voa.va.gov/DocumentView.aspx?DocumentID=4411
72. “POLARIS User Guide”, Version 1.2, February 2016, https://www.voa.va.gov/DocumentView.aspx?DocumentID=4412
73. VA Memorandum “Use of Personal Email (VAIQ #7581492)”, April 24, 2015, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28
74. VA Memorandum “Updated VA Information Security Rules of Behavior (VAIQ #7823189)”, September, 15, 2017, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28
SCOPE OF WORK
The Contractor shall provide all labor, supervision and other resources required to deliver professional and technical services, to the NDS Program Office. These services include support for VHA health information user access management, and support for the Business Associate Agreement program.
PERFORMANCE DETAILS
PERFORMANCE PERIOD
The period of performance shall be a twelve (12) month base period, with four (4) twelve (12) month option periods.
Any work at the Government site shall not take place on Federal holidays or weekends unless directed by the Contracting Officer (CO).
There are eleven (11) Federal holidays set by law (USC Title 5 Section 6103) that VA follows:
Under current definitions, five are set by date:
| New Year's Day | January 1 | |
| Juneteenth | June 19 | |
| Independence Day | July 4 | |
| Veterans Day | November 11 | |
| Christmas Day | December 25 |
If any of the above falls on a Saturday, then Friday shall be observed as a holiday. Similarly, if one falls on a Sunday, then Monday shall be observed as a holiday.
The other six are set by a day of the week and month:
| Martin Luther King's Birthday | Third Monday in January |
| Washington's Birthday | Third Monday in February |
| Memorial Day | Last Monday in May |
| Labor Day | First Monday in September |
| Columbus Day | Second Monday in October |
| Thanksgiving | Fourth Thursday in November |
PLACE OF PERFORMANCE
Tasks under this PWS shall be performed at Contractor facilities.
Work may be performed at government site with prior approval of the Program Manager and Contracting Officer. Government onsite space is limited to one space at VACO in Washington, DC.
a) Hours of service - Contractor shall provide service during normal business hours from 8:00 A.M. to 4:30 P.M. local time, Monday through Friday.
In addition, TDY to a Government facility within the effort doesn’t change the Place of Performance to the Government Site.
SPECIFIC TASKS AND DELIVERABLES
The Contractor shall perform the mandatory tasks and provide the specific deliverables described below within the performance period stated in this Performance Work Statement. If for any reason, any deliverable cannot be delivered on time according to the below schedule, the Contractor shall provide a written explanation to the Program Manager, Contracting Officer Representative and Contracting Officer as soon as discovered, but not later than three days prior to deliverable due date. This written transmittal shall include a firm commitment of when the work shall be completed. This transmittal shall cite the reasons for the delay, and the impact on the overall project.
VHA User Access Management and Support The Contractor shall manage regional (Veteran Integrated Service Networks – VISNs) and national access to VHA health information resources. These services include: data access requests, help desk support, data access process support, and business associate agreement support.
NDS customers include, but are not limited to, clinicians, researchers, peer reviewers, legal reviewers, and Veteran Service Organizations (VSO).
The Contractor shall be involved in information gathering and documentation development related to VHA data access. The Contractor shall assist with continuous improvement of existing processes and tools for VHA data access on a quarterly basis. The Contractor shall assist NDS in managing new initiatives or innovations that improve how VA processes VHA Data Access requests, which is driven by customer need. At a minimum, supervisory and/or lead Contractor staff shall regularly participate in all designated weekly, monthly, and ad hoc staff, workgroup, and access-related meetings and/or conference calls.
Data Access Requests (An option CLIN with additional quantities will be included in the schedule).
The contractor shall review all data access requests to ensure all required paperwork has been submitted and meets VHA policy requirements for data access approval. The Contractor shall be responsible for all processes in the provisioning of access to VHA data based on the data sources requested and enter the requests into a VA developed tracking system. All data access requests shall involve customer service-based interaction, with timely feedback to end users about status of request, missing documentation, and when the requestor may expect data after request is approved. Contractor must complete all requests within three business days from the date of receipt and comply with the standard operating procedures (SOP).
Refer to the associated standard operating procedures for additional detail. Please note the referenced SOP attachments may not be reflective of the actual level of effort involved.
Reference Attachments:
Attachment B - SOP BAA Management 2018 Attachment C – BAA Management Checklist
Attachment H - SOP Healthcare Operations Access (HOA) Requests 7.2018 Attachment I - SOP Power of Attorney (POA) 3.2015 Attachment J - SOP Research Requests DART 7.24.15
In support of ensuring adherence to NDS User Access Management processes, the Contractor shall conduct a quality assurance review daily to ensure appropriate access administration was completed accurately and in accordance with standard operating procedures.
The contractor shall be required to compile monthly, quarterly, and annual statistics of user demographics and frequency of requests seeking special access to VA health information resources. The Contractor shall track all open, closed, and pending actions taken in existing VA system or platform under this task.
Help Desk Support (OPTIONAL TASK) This task is identified as an optional task and contingent upon the availability of funding. The contractor shall provide second-tier help desk support assistance to the established Enterprise Service Desk (ESD) for managed access. The contractor shall do the following immediately upon receipt but not to exceed one business day:
- Log help-desk tickets into the appropriate existing workload management tracking system.
- Respond to email and phone inquiries from the ESD Helpdesk or customer.
- Provide user training associated with access applications (Training is typically regarding how to complete the request form and/or step-by-step instructions for logging in to use requested access, once granted. This is typically adhoc and PowerPoint driven.)
Second Tier Support includes software troubleshooting Examples of Support Tickets:
Tier Two Support Tickets:
• CAPRI Mailbox inquiries
• CAPRI upgrade
• Connectivity Issues
• Modify Menus in CLAIMS (CAPRI)
• Modify Security Key(s) in CLAIMS (CAPRI)
• Invalid Pointer Operation (via CAPRI)
Historical/Projected Workload Data:
Provided below is a chart identifying projected data of volume of requests for each task 1 workload category. This information is based on reporting matrix within the organization.
This information is provided as data to be utilized for information purpose only. Some contract staff below are cross utilized within multiple workload categories.
NDS Workload Projections
| PoP Contract Resource |
| Workload Category |
| PoP May 2023– Apr 2024 |
| Base Year Projections |
| Option Year 1 Projections |
| .5 |
| HealthCare Ops |
| 8167 |
| 8050 |
| 8300 |
| .5 |
| CAPRI/Joint LongitudinalViewer |
| 4035 |
| 3825 |
| .5 |
| Power of Attorney |
| 5957 |
| 5007 |
| 1 |
| Research |
| 3248 |
| 3300 |
| .5 |
| Helpdesk Support |
(designated as an Optional Task)
| 448 |
| 400 |
| 400 |
Deliverables 5.1:
Contractor shall provide a monthly status report of VHA User Access Management tasks and documentation support to include the quantities for each workload category. This report shall contain:
· NDS User Access Management Status of open, closed, and pending requests for each workload type
· All open, closed, and pending actions taken during the Quality Assurance Review
· All open, closed, and pending actions on Help Desk Support items
· Log of attended meetings/conference calls Deliverable 5.1.1 (Quantities for each):
A. Healthcare Ops Access requests B. CAPRI/Joint Longitudinal Viewer C. Power of Attorney D. Research Deliverable 5.1.2 Optional (Quantities):
A. Helpdesk Support (Tier 2 tickets only)
Due Date: Monthly for twelve (12) months from date of award Business Associate Agreement (BAA) Support (An option CLIN with additional quantities will be included in the schedule).
The Contractor shall provide administrative support to the VHA Business Associate PM. The Contractor shall provide the updated status in response to email and telephone inquiries regarding the progression of each Business Associate Agreements (BAA) action. These actions include but are not limited to the initial profile application step, scoring the risk analysis worksheet, preparing draft BAA documents for PM review, acquiring appropriate signatures (Business Associate and VHA), scanning completed agreements and archiving (upload into database), setting meetings with vendors, follow up with non-responsive vendors (email and phone calls), and other BAA administrative tasks that result from the above duties. The Contractor shall assist with managing and updating the BAA databases and trackers. Reference Section D, Attachment B, SOP BAA Management. NDS currently has approximately 467 active BAAs in the database. The contractor shall attend weekly BAA status meetings via phone with the VHA Business Associate Agreement PM.
Task 5.2 Historical/Projected Data:
Based on historical data, the Government estimates that one (1) FTE can support the following BAA transactions. Note: During the Period of Performance (PoP) May 2023 through April 2024 the following transactions were completed. This historical data is based on available PoP data with the understanding that transactions can fluctuate.
| BAA Transaction Description |
| PoP |
May 2023 – Apr 2024
| Base Year Projection Totals |
| Option Year 1 Projection Totals |
| BAAs Reviewed |
| 104 |
| 154 |
| 210 |
| BAAs Executed |
| 32 |
| 19 |
| 20 |
Deliverables 5.2:
Contractor shall provide a monthly status report of BAA Support to include the quantities for each BAA action. The Business Associate PM will review and validate data input against information contained in the BAA Tracker. This report shall contain:
A. BAAs Reviewed (quantities) B. BAAs Executed (quantities)
Support for each BAA transaction includes the following administrative tasks and are consistent for each BAA transaction:
· Emailing clients with attachments to include Business Associate Profile Questionnaires, draft BAAs, final BAAs, partially executed Business Associate Agreement Termination Letters and fully executed Business Associate Termination Letters
· Follow up status emails to clients
· Emailing Business Associate Agreement PM with attachments to include Business Associate Profile Questionnaires, draft BAAs, final BAAs, partially executed Business Associate Agreement Termination Letters and fully executed Business Associate Termination Letters
· Phone calls to clients for status updates
· Scoring the Business Associate Risk Analysis Worksheet
· Updating the BAA Tracker
· Updating the network drive BAA folders
Due Date: Monthly for twelve (12) months from date of award.
Reporting Requirements The Contractor shall provide the PM and COR with Monthly Progress Reports in electronic form in Microsoft Word. The report shall include detailed instructions/explanations for each required data element, to ensure that data is accurate and consistent. These reports shall reflect data as of the last day of the preceding Month.
The Monthly Progress Reports shall cover all work completed during the reporting period and work planned for the subsequent reporting period. The report shall also identify any problems that arose and a description of how the problems were resolved. If problems have not been completely resolved, the Contractor shall provide an explanation including their plan and timeframe for resolving the issue. The Contractor shall monitor performance against the PWS and report any deviations. It is expected that the Contractor will keep in communication with VA accordingly so that issues that arise are transparent to both parties to prevent escalation of outstanding issues. The contractor shall notify the PM, COR, and CO in writing if problems arise that could adversely impact the performance of the task order.
The contractor shall take minutes of all formal conference calls and/or meetings held with the PM. Copies of these minutes shall be attached to the monthly progress report.
Monthly progress reports shall contain, but are not limited to, the following:
· Status summary
· Change request status (new, open, closed since last report)
· Issue status (new, open, closed since last report)
· Schedule status
· Minutes of status meetings
· Contractor staff roster (providing updates as they occur, including personnel and security requirements)
· Status of required background investigations
Deliverables 5.3:
Monthly Progress Report. Due the fifth (5th) business day of each month
GENERAL REQUIREMENTS
KEY PERSONNEL
The following minimum standards shall apply for personnel performing under this contract and shall be maintained throughout the life of the contract.
A. Program Assistant Functional Responsibilities:
Provide administrative support to the VHA Business Associate Program Manager. Provide the updated status in response to email and telephone inquiries regarding the progression of each Business Associate Agreements (BAA) action. These actions include sending and receiving profile applications, scoring the risk analysis worksheet, drafting BAAs, acquiring appropriate signatures (Business Associate and VHA), annotating communications between VHA and business associate, scanning completed agreements and archiving (upload into database), setting meetings with vendors, non-responsive vendor follow up, and other BAA administrative tasks that result from the above duties. The contractor shall assist with managing and updating the BAA databases and trackers.
Minimum Experience/Education:
Possess at least a 2-year degree in business, administration, office automation or healthcare related fields, with preferred background and/or training in the Health Insurance Portability and Accountability Act (HIPAA) business associate provisions.
B. Program Analyst Functional Responsibilities:
Possess and be able to apply expert level knowledge of research, the use of data for research, and research methodologies to the review and approval process for applicable VHA data access requests. Using analytical ability, provide professional and thorough written and/or verbal communications in response to email and telephone inquiries regarding the approval process and any identified deficiencies that may exist within a request. These actions include collaborating with other entities identified in the approval process; reviewing submitted documentation and applying scrutiny in accordance with applicable policy, procedures, and guidance; acquiring appropriate approvals; and annotating communications and status within identified applications. The contractor shall assist with managing, updating, and identifying business requirements for the applicable tools used in the approval process.
Minimum Experience/Education:
Possess at least a 2-year degree in business, administration, office automation or healthcare related fields, with a minimum of 2 years’ experience in the Health Insurance Portability and Accountability Act (HIPAA) and Privacy Act of 1974.
ENTERPRISE AND IT FRAMEWORK
ONE-VA TECHNICAL REFERENCE MODEL
The Contractor shall support the VA enterprise management framework. In association with the framework, the Contractor shall comply with OI&T Technical Reference Model (One-VA TRM). One-VA TRM is one component within the overall Enterprise Architecture (EA) that establishes a common vocabulary and structure for describing the information technology used to develop, operate, and maintain enterprise applications. One-VA TRM includes the Standards Profile and Product List that collectively serves as a VA technology roadmap. Architecture, Strategy, and Design (ASD) has overall responsibility for the One-VA TRM.
FEDERAL IDENTITY, CREDENTIAL, AND ACCESS MANAGEMENT (FICAM)
The Contractor shall ensure Commercial Off-The-Shelf (COTS) product(s), software configuration and customization, and/or new software are Personal Identity Verification (PIV) card-enabled by accepting HSPD-12 PIV credentials using VA Enterprise Technical Architecture (ETA), http://www.ea.oit.va.gov/VA_EA/VAEA_TechnicalArchitecture.asp, and VA Identity and Access Management (IAM) approved enterprise design and integration patterns, http://www.techstrategies.oit.va.gov/enterprise_dp.asp. The Contractor shall ensure all Contractor delivered applications and systems comply with the VA Identity, Credential, and Access Management policies and guidelines set forth in the VA Handbook 6510 and align with the Federal Identity, Credential, and Access Management Roadmap and Implementation Guidance v2.0.
The Contractor shall ensure all Contractor delivered applications and systems provide user authentication services compliant with the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-63-3, VA Handbook 6500 Appendix F, “VA System Security Controls”, and VA IAM enterprise requirements for direct, assertion based authentication, and/or trust based authentication, as determined by the design and integration patterns. Direct authentication at a minimum must include Public Key Infrastructure (PKI) based authentication supportive of PIV card and/or Common Access Card (CAC), as determined by the business need.
The Contractor shall ensure all Contractor delivered applications and systems conform to the specific Identity and Access Management PIV requirements set forth in the Office of Management and Budget (OMB) Memoranda M-04-04, M-05-24, M-11-11, and NIST Federal Information Processing Standard (FIPS) 201-2. OMB Memoranda M-04-04, M-05-24, and M-11-11 can be found at: https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/omb/memoranda/fy04/m04-04.pdf, https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/omb/memoranda/fy2005/m05-24.pdf, and https://obamawhitehouse.archives.gov/sites/default/files/omb/memoranda/2011/m11-11.pdf respectively. Contractor delivered applications and systems shall be on the FIPS 201-2 Approved Product List (APL). If the Contractor delivered application and system is not on the APL, the Contractor shall be responsible for taking the application and system through the FIPS 201 Evaluation Program.
The Contractor shall ensure all Contractor delivered applications and systems support:
1. Automated provisioning and are able to use enterprise provisioning service.
2. Interfacing with VA’s Master Veteran Index (MVI) to provision identity attributes, if the solution relies on VA user identities. MVI is the authoritative source for VA user identity data.
3. The VA defined unique identity (Secure Identifier [SEC ID] / Integrated Control Number [ICN]).
4. Multiple authenticators for a given identity and authenticators at every Authenticator Assurance Level (AAL) appropriate for the solution.
5. Identity proofing for each Identity Assurance Level (IAL) appropriate for the solution.
6. Federation for each Federation Assurance Level (FAL) appropriate for the solution, if applicable.
7. Two-factor authentication (2FA) through an applicable design pattern as outlined in VA Enterprise Design Patterns.
8. A Security Assertion Markup Language (SAML) implementation if the solution relies on assertion-based authentication. Additional assertion implementations, besides the required SAML assertion, may be provided as long as they are compliant with NIST SP 800-63-3 guidelines.
9. Authentication/account binding based on trusted Hypertext Transfer Protocol (HTTP) headers if the solution relies on Trust based authentication.
10. Role Based Access Control.
11. Auditing and reporting capabilities.
12. Compliance with VAIQ# 7712300 Mandate to meet PIV requirements for new and existing systems. https://www.voa.va.gov/DocumentView.aspx?DocumentID=4846
The required Assurance Levels for this specific effort are Identity Assurance Level 3, Authenticator Assurance Level 3, and Federation Assurance Level 3.
INTERNET PROTOCOL VERSION 6 (IPV6)
The Contractor solution shall support the latest Internet Protocol Version 6 (IPv6) based upon the directives issued by the Office of Management and Budget (OMB) on August 2, 2005 (https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/omb/memoranda/fy2005/m05-22.pdf) and September 28, 2010 (https://cio.gov/wp-content/uploads/downloads/2012/09/Transition-to-IPv6.pdf). IPv6 technology, in accordance with the USGv6 Profile, NIST Special Publication (SP) 500-267 (https://www.nist.gov/programs-projects/usgv6-technical-basis-next-generation-internet), the Technical Infrastructure for USGv6 Adoption (http://www-x.antd.nist.gov/usgv6/index.html), and the NIST SP 800 series applicable compliance (http://csrc.nist.gov/publications/PubsSPs.html) 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 shall support native IPv6 and/or 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 and/or dual stack (IPv6/ IPv4) users and all internal infrastructure and applications shall communicate using native IPv6 and/or dual stack (IPv6/ IPv4) operations. Guidance and support of improved methodologies which ensure interoperability with legacy protocol and services in dual stack solutions, in addition to OMB/VA memoranda, can be found at: https://www.voa.va.gov/documentlistpublic.aspx?NodeID=282.
TRUSTED INTERNET CONNECTION (TIC)
The Contractor solution shall meet the requirements outlined in Office of Management and Budget Memorandum M08-05 mandating Trusted Internet Connections (TIC) (https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/omb/memoranda/fy2008/m08-05.pdf), M08-23 mandating Domain Name System Security (NSSEC) (https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/omb/memoranda/fy2008/m08-23.pdf), and shall comply with the Trusted Internet Connections (TIC) Reference Architecture Document, Version 2.0 https://s3.amazonaws.com/sitesusa/wp-content/uploads/sites/482/2015/04/TIC_Ref_Arch_v2-0_2013.pdf.
STANDARD COMPUTER CONFIGURATION
The Contractor IT end user solution that is developed for use on standard VA computers shall be compatible with and be supported on the standard VA operating system, currently Windows 7 (64bit), Internet Explorer 11 and Microsoft Office 2010. In preparation for the future VA standard configuration update, end user solutions shall also be compatible with Office 365 ProPlus and Windows 10. However, Office 365 ProPlus and Windows 10 are not the VA standard yet and are currently approved for limited use during their rollout, we are in-process of this rollout and making them the standard by OI&T. Upon the release approval of Office 365 ProPlus and Windows 10 individually as the VA standard, Office 365 ProPlus and Windows 10 will supersede Office 2010 and Windows 7 respectively. Applications delivered to the VA and intended to be deployed to Windows 7 workstations shall be delivered as a signed .msi package with switches for silent and unattended installation and updates shall be delivered in signed .msp file formats for easy deployment using System Center Configuration Manager (SCCM) VA’s current desktop application deployment tool. Signing of the software code shall be through a vendor provided certificate that is trusted by the VA using a code signing authority such as Verizon/Cybertrust or Symantec/VeriSign. The Contractor shall also ensure and certify that their solution functions as expected when used from a standard VA computer, with non-admin, standard user rights that have been configured using the United States Government Configuration Baseline (USGCB) and Defense Information Systems Agency (DISA) Secure Technical Implementation Guide (STIG) specific to the particular client operating system being used.
VETERAN FOCUSED INTEGRATION PROCESS (VIP)
The Contractor shall support VA efforts IAW the Veteran Focused Integration Process (VIP). VIP is a Lean-Agile framework that services the interest of Veterans through the efficient streamlining of activities that occur within the enterprise. The VIP Guide can be found at https://www.voa.va.gov/DocumentView.aspx?DocumentID=4371. The VIP framework creates an environment delivering more frequent releases through a deeper application of Agile practices. In parallel with a single integrated release process, VIP will increase cross-organizational and business stakeholder engagement, provide greater visibility into projects, increase Agile adoption and institute a predictive delivery cadence. VIP is now the single authoritative process that IT projects must follow to ensure development and delivery of IT products
PROCESS ASSETT LIBRARY (PAL)
The Contractor shall utilize PAL, the OI&T-wide process management tool that assists in the execution of an IT project (including adherence to VIP standards). PAL serves as an authoritative and informative repository of searchable processes, activities or tasks, roles, artifacts, tools and applicable standards or guides to assist project teams in facilitating their VIP compliant work.
SECURITY AND PRIVACY REQUIREMENTS
It has been determined that protected health information may be disclosed or accessed and a signed Business Associate Agreement (BAA) shall be required. The Contractor shall adhere to the requirements set forth within the BAA, referenced in Section D of the contract, and shall comply with VA Directive 6066.
POSITION/TASK RISK DESIGNATION LEVEL(S)
In accordance with VA Handbook 0710, Personnel Security and Suitability Program, the position sensitivity and the level of background investigation commensurate with the required level of access for the following tasks within the PWS are:
Position Sensitivity and Background Investigation Requirements by Task
| Task Number |
| Tier1 / Low Risk |
| Tier 2 / Moderate Risk |
| Tier 4 / High Risk |
| 5.1 |
| |_| |
| |X| |
| |_| |
| 5.2 |
| |_| |
| |X| |
| |_| |
| 5.3 |
| |X| |
| |_| |
| |_| |
| |_| |
| |_| |
| |_| |
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:
1. 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.
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 Tasks), etc. The Contractor shall submit 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 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 are to encrypt the file, use a secure fax, or use a traceable mail service.
1. 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 Security and Investigations Center (SIC) Fingerprint request form with them (see paragraph d.4. below) when getting fingerprints taken.
b. 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 SIC Fingerprint Request Form 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 Office of Personnel Management’s (OPM) Electronic Questionnaire for Investigations Processing (e-QIP) after receiving an email notification from the Security and Investigation Center (SIC).
The Contractor employee shall certify and release the e-QIP document, print and sign the signature pages, and send them encrypted to the COR for electronic submission to the SIC. These documents shall be submitted to the COR within 3 business days of receipt of the e-QIP notification email. (Note: OPM 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 e-QIP).
1. 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.
1. 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 9), signed “Contractor Rules of Behavior”, and with a valid, operational 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 OPM. 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 OPM.
1. 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.
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.
Identity 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
METHOD AND DISTRIBUTION OF DELIVERABLES
The Contractor shall deliver documentation in electronic format, unless otherwise directed in Section B of the solicitation/contract. Acceptable electronic media include: MS Word 2000/2003/2007/2010, MS Excel 2000/2003/2007/2010, MS PowerPoint 2000/2003/2007/2010, MS Project 2000/2003/2007/2010, MS Access 2000/2003/2007/2010, MS Visio 2000/2002/2003/2007/2010, AutoCAD 2002/2004/2007/2010, and Adobe Postscript Data Format (PDF).
PERFORMANCE METRICS
The table below defines the Performance Standards and Acceptable Levels of Performance associated with this effort.
| Performance Objective |
| Performance Standard |
| Acceptable Levels of Performance |
| A. Technical / Quality of Product or Service |
| 1. Demonstrates understanding of requirements |
2. Efficient and effective in meeting requirements
3. Meets technical needs and mission requirements
4. Provides quality services/products Satisfactory or higher
| B. Project Milestones and Schedule |
| 1. Established milestones and project dates are met |
2. Products completed, reviewed, delivered in accordance with the established schedule
3. Notifies customer in advance of potential problems Satisfactory or higher
| C. Cost & Staffing |
| 1. Currency of expertise and staffing levels appropriate |
2. Personnel possess necessary knowledge, skills and abilities to perform tasks Satisfactory or higher
| D. Management |
| 1. Integration and coordination of all activities to execute effort |
| Satisfactory or higher |
The COR will utilize a Quality Assurance Surveillance Plan (QASP) throughout the life of the contract to ensure that the Contractor is performing the services required by this PWS in an acceptable level of performance. The Government reserves the right to alter or change the surveillance methods in the QASP at its own discretion.
FACILITY/RESOURCE PROVISIONS
The Government will provide office space, telephone service and system access when authorized contract staff work at a Government location as required in order to accomplish the Tasks associated with this PWS. All procedural guides, reference materials, and program documentation for the project and other Government applications will also be provided on an as-needed basis.
The Contractor shall request other Government documentation deemed pertinent to the work accomplishment directly from the Government officials with whom the Contractor has contact. The Contractor shall consider the COR as the final source for needed Government documentation when the Contractor fails to secure the documents by other means. The Contractor is expected to use common knowledge and resourcefulness in securing all other reference materials, standard industry publications, and related materials that are pertinent to the work.
VA may provide remote access to VA specific systems/network in accordance with VA Handbook 6500, which requires the use of a VA approved method to connect external equipment/systems to VA’s network. Citrix Access Gateway (CAG) is the current and only VA approved method for remote access users when using or manipulating VA information for official VA Business. VA permits CAG remote access through approved Personally Owned Equipment (POE) and Other Equipment (OE) provided the equipment meets all applicable 6500 Handbook requirements for POE/OE. All of the security controls required for Government furnished equipment (GFE) must be utilized in approved POE or OE. The Contractor shall provide proof to the COR for review and approval that their POE or OE meets the VA Handbook 6500 requirements and VA Handbook 6500.6 Appendix C, herein incorporated as Addendum B, before use. CAG authorized users shall not be permitted to copy, print or save any VA information accessed via CAG at any time. VA prohibits remote access to VA’s network from non-North Atlantic Treaty Organization (NATO) countries. The exception to this are countries where VA has approved operations established (e.g. Philippines and South Korea). Exceptions are determined by the COR in coordination with the Information Security Officer (ISO) and Privacy Officer (PO).
This remote access may provide access to VA specific software such as Veterans Health Information System and Technology Architecture (VistA), ClearQuest, PAL, Primavera, and Remedy, including appropriate seat management and user licenses, depending upon the level of access granted. The Contractor shall utilize government-provided software development and test accounts, document and requirements repositories, etc. as required for the development, storage, maintenance and delivery of products within the scope of this effort. The Contractor shall not transmit, store or otherwise maintain sensitive data or products in Contractor systems (or media) within the VA firewall IAW VA Handbook 6500.6 dated March 12, 2010. All VA sensitive information shall be protected at all times in accordance with VA Handbook 6500, local security field office System Security Plans (SSP’s) and Authority to Operate (ATO)’s for all systems/LAN’s accessed while performing the tasks detailed in this PWS. The Contractor shall ensure all work is performed in countries deemed not to pose a significant security risk. For detailed Security and Privacy Requirements (additional requirements of the contract consolidated into an addendum for easy reference) refer to ADDENDUM A – ADDITIONAL VA REQUIREMENTS, CONSOLIDATED and ADDENDUM B - VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE.
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