PD V22 PMIS SaaS_RFI .pdf

PRODUCT DESCRIPTION (PD)

DEPARTMENT OF VETERANS AFFAIRS

VISN 22 Office of Capital Asset Management (V22-CAM)

Cloud Based Project Management Information System (PMIS)

Date: May 18, 2026

VA-26-00059514

PD Version Number: 1.0

Contents

1.0 PRODUCT REQUIREMENTS

2.0 NOTICE OF THE FEDERAL ACCESSIBILITY LAW AFFECTING ALL

INFORMATION AND COMMUNICATION TECHNOLOGY (ICT)

PROCUREMENTS (SECTION 508)

2.1 SECTION 508 – INFORMATION AND COMMUNICATION TECHNOLOGY

(ICT) STANDARDS

2.2 COMPATABILITY WITH ASSISTIVE TECHNOLOGY

2.3 ACCEPTANCE AND ACCEPTANCE TESTING

3.0 INFORMATION TECHNOLOGY USING SUSTAINABLE PRODUCTS

4.0 SHIPMENT OF SOFTWARE OR RELATED ITEMS

5.0 GENERAL REQUIREMENTS

5.1 VA TECHNICAL REFERENCE MODEL

5.2 ZERO TRUST – VA CRITICAL SECURITY CONTROLS

5.3 SOCIAL SECURITY NUMBER (SSN) REDUCTION

5.4 INTERNET PROTOCOL VERSION 6 (IPV6)

5.5 SOFTWARE AND LICENSING REQUIREMENTS

5.6 TRUSTED INTERNET CONNECTION (TIC)

5.7 GENERATIVE ARTIFICIAL INTELLIGENCE REQUIREMENTS

5.7.1 AI SYSTEM/LLM DEVELOPMENT AND OPERATION

DOCUMENTATION REQUIREMENTS

5.7.2 MONITORING, REPORTING, AND CORRECTIVE ACTION

5.7.3 AI MODEL UPDATES AND CHANGE DISCLOSURES

6.0 SECURITY AND PRIVACY REQUIREMENTS

6.1 POSITION/TASK RISK DESIGNATION LEVEL(S)

6.2 ADDENDUM B – VA INFORMATION AND INFORMATION SYSTEM

SECURITY/ PRIVACY LANGUAGE

1.0 PRODUCT REQUIREMENTS

The mission of the Department of Veterans Affairs (VA), Veterans Integrated Service Network (VISN 22), Office of Capital Asset Management (CAM) is to provide support for all VA Medical Centers in relation to their capital improvement programs which include design, construction, and lease project management, operations and maintenance, and planning. This allows each healthcare system to deliver high-quality, cost-effective facilities in support of our nation's Veterans. VISN customers are VA employees in medical centers, and community-based clinics across Southern California, Arizona and New Mexico who proudly work at the front lines of service delivery to our nation’s Veterans.

Daily Project Management (PM) decisions require distribution and review of documentation for analysis, justification, and approval. Decisions in PM workflows require collaboration amongst a variety of stakeholders to provide information necessary to support decisions. Project Management Information Systems (PMIS) provide engineers with the opportunity to improve accountability and collaboration while capturing a digital record of all PM decisions and supporting information.

This procurement requires a Commercial-off-the-Shelf (COTS), Software as a Service (SaaS) brand name Kahua or equal solution to replace its current project management process. The solution shall be Federal Risk and Authorization Management Program (FedRAMP) authorized at a Moderate or higher impact level. The Contractor shall provide licenses to PMIS software along with comprehensive support services to ensure successful deployment of the PMIS for 400 users (150 VA staffs and 250 support contractors). The system shall be a collaborative cloud-based communication and project management information system for the architect/engineering and construction (AEC) community.

The PMIS solution shall support VISN-level portfolio management and oversight across all VA Medical Centers, outpatient facilities, and leased assets within VISN 22. VISN CAM users shall have portfolio-wide visibility, reporting, and governance authority while preserving facility-level execution control. The PMIS shall support high-volume, Non- Recurring Maintenance (NRM) and Minor Construction projects, including template-based project creation, lightweight workflows, and rapid project setup and closeout to meet fiscal year execution demands.

The consumption model for this PMIS shall be License based where the total cost is based on total users with access to the system.

The required Brand Name or Equal to Kahua shall meet all of the salient characteristics identified in this PD.

The period of performance shall be one 12-month base period with four 12-month option period.

TABLE 1 – SALIENT CHARACTERISTICS

Item No. Description

1.

The PMIS solution shall be a cloud-hosted Software-as-a-Service (SaaS) platform accessible through standard web browsers and mobile devices provided by the Department of Veterans Affairs without requiring installation of software on VA computers. The only application requirement is for Government issues mobile devices already available through the VA market place. The solution shall be vendor or third-party hosted and shall not require VA to manage or control the underlying cloud infrastructure, including network, servers, operating systems, storage, or application capabilities. No VA-hosted servers shall be required.

2.

The PMIS solution shall maintain FedRAMP Moderate authorization and an active VA Authority to Operate (ATO) throughout the Period of Performance. Any software components requiring installation on VA issued mobile devices shall be VA Technical Reference Model (TRM) approved and listed on the VA Product Marketplace at time of award.

3.

The solution shall provide a centralized enterprise Project Management Information System (PMIS) for electronically exchanging, reviewing, logging, routing, tracking, archiving, and managing design and construction documentation including, design drawings, RFIs, submittals, schedules, meeting minutes, change orders, daily reports, field observations, punch lists, compliance records, photos, financial records, supplemental instructions, test reports, contracts, invoices, and project correspondence.

4.

The system shall provide industry-standard workflows and configurable business process automation tools supporting Architect-Engineering- Construction (AEC) and healthcare project management processes including RFIs, Submittals, Design Reviews, Change Orders, Punch Lists, Meeting Minutes, Field Observations, Daily Reports, Cost Management, Utility Shutdowns, Infection Control, Interim Life Safety Measures, Hot Work Permits, Fire Watch Logs, Vendor Performance, Compliance Documents, Checklists and Inspections.

5.

The PMIS shall include a native Business Process Management (BPM) engine capable of modeling, automating, routing, enforcing, and tracking complex workflows across modules and projects. Workflows shall support configurable routing, multiple approvals, notifications, escalation, auditability, ball-in-court ownership, workflow status tracking, auto-population of data, list selections, formatted entries, and business rule enforcement.

6.

The system shall provide comprehensive configuration capabilities without requiring custom software development or vendor programming services.

Authorized users shall be able to create, modify, and manage forms, templates, portals, workflows, reports, dashboards, queries, user interfaces, fields, labels, workflows, and navigation through low-code/no-code visual configuration tools and wizards.

7.

The system shall support hierarchical enterprise configuration and administration across portfolios, programs, projects, facilities, user groups, and individual users. Configuration settings, workflows, forms, reports, permissions, and user interfaces shall support inherited, overridden, or enforced configurations at any level of the enterprise.

8.

The system shall support granular Role-Based Access Control (RBAC) with configurable permissions controlling create, read, update, delete, archive, workflow participation, field visibility, navigation, and administrative functions. Administrative users shall be able to assign permissions to users and groups and manage hierarchical security configurations.

9.

The PMIS shall support SAML 2.0, Single Sign-On (SSO), and Multi-Factor Authentication (MFA) integration for enterprise identity management. All data at rest shall be encrypted using AES-256 or higher, and all data in transit shall use TLS 1.2 or higher with HTTPS protocols.

10.

The system shall maintain immutable, discoverable audit trails capturing all user actions, transactions, workflow activities, document revisions, email history, approvals, timestamps, and user identification information in accordance with VA security and records management requirements.

11.

The PMIS shall provide automated document management and document control capabilities including version tracking, revision history, searchable indexing, metadata management, document routing, configurable notifications, PDF markup tools, annotation flattening, simultaneous review collaboration, and secure archival. Users shall be able to search documents and document contents without requiring knowledge of folder structures.

12.

The system shall provide collaborative review tools allowing multiple users to simultaneously review and comment on PDF drawings and documents within active workflows. Review comments shall automatically populate structured tracking tables and support routing, evaluation, back-checking, and closure tracking across future document revisions.

13.

The system shall provide real-time collaboration capabilities for owners, contractors, subcontractors, consultants, and stakeholders within a unified workspace. The system shall include live communication tools and maintain all communications within associated project records and workflows.

14.

The PMIS shall support automated daily reporting processes that generate and manage official project site records using workflow-driven shared documents with configurable security rights, routing, dashboards, and approval processes.

15.

The system shall support meeting management processes including meeting agendas, meeting minutes, assignment of action items, workflow notifications, and tracking of task completion across meetings.

16.

The PMIS shall support automated RFI, Submittal, and Change Order workflows using construction industry best practices. Workflows shall include configurable business rules, automated routing, structured data entry, notifications, tracking, approvals, and integrated cost management functions.

17.

The system shall support integrated project cost management capabilities including budgets, contracts, invoices, schedules, change orders, and financial tracking within a unified real-time environment.

18.

The PMIS shall support project milestone and schedule management, including import and synchronization of Primavera P6, Microsoft Project, and similar industry-standard scheduling platforms. Imported scheduling data shall integrate with milestone tracking dashboards and automated project status reporting.

19.

The system shall support bulk import and export of project data using industry-standard formats including .xlsx, .csv, .zip, PDF, and other non-proprietary formats. VA shall be able to export active and archived projects, records, and documents for transfer to successor PMIS solutions without additional vendor processing.

20.

The PMIS shall provide comprehensive search, reporting, analytics, and dashboard capabilities including configurable reports, historical reporting, workflow status reporting, project tracking, and Power BI analytics integration without requiring additional customer licensing.

21.

The system shall support mobile device functionality with offline operation and automatic synchronization upon reconnection to the network.

22.

The system shall include REST APIs, middleware, ETL capabilities, and low-code/no-code integration frameworks supporting secure data exchange and interoperability with VA systems and common AEC technologies and tools.

23.

The system shall support separate development, testing, training, and production environments with controlled migration and promotion of configurations and data between environments. Only VA-approved changes shall be promoted to production. The contractor shall maintain environment sufficient to support user acceptance testing and training activities.

24.

The system shall support automated configuration-driven deployment of applications and enterprise functions through centralized governance and managed application distribution mechanisms.

25.

The PMIS shall include configurable forms, templates, print layouts, PDF mail merge functionality, dashboards, portals, reports, and user interfaces supporting VA-specific operational and documentation requirements.

26.

The system shall support automated notifications, reminders, queues, escalations, workflow ownership identification, and project transparency functions enabling stakeholders to monitor project activities and status in real time.

27.

The PMIS shall support project asset tagging and linkage of asset data to workflows, documents, maintenance records, and project delivery records to facilitate transition to operations and maintenance activities.

28.

The system shall retain project data in both native application format and non-proprietary exportable formats accessible through commercially available software. Administrators shall be able to configure records retention schedules, automated deletion rules, and archive management policies in accordance with agency requirements.

29.

The PMIS shall provide configurable deployment and workflow assistance services to support implementation, configuration management, and ongoing operational optimization for VA-specific business processes and project delivery requirements.

30.

The system shall support easy upload, organization, routing, and management of design, construction, compliance, and project documentation with transparent access controls, complete version history, and project lifecycle traceability.

31.

The system shall provide a sealed bid management portal including vendor Q&A, leveling tools, bid workflows, and award management capabilities.

32.

The system shall support configurable user-installed training videos, help content, quick guides, and contextual training materials directly accessible within the application interface.

33.

The Contractor shall provide full system maintenance, technical support, onboarding support, troubleshooting assistance, escalation management, and operational support throughout the Period of Performance.

34.

The Contractor shall provide a designated Client Success Manager responsible for implementation coordination, configuration support, onboarding, user administration, workflow optimization, enhancement planning, release management, user adoption, issue escalation, training coordination, lessons learned activities, and customer communications.

35.

The Contractor shall provide role-based virtual and online training, training presentations, quick reference guides, FAQs, user manuals, training collateral, and refresher training specific to VA-configured workflows and processes. Training materials shall be maintained and updated within one week of system changes, upgrades, or configuration modifications.

2.0 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.

2.1 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

2.2 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.

2.3 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.

3.0 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;

https://www.access-board.gov/ict/ https://www.access-board.gov/ict/

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.

4.0 SHIPMENT OF SOFTWARE OR RELATED ITEMS

Inspection: Destination Acceptance: Destination Free on Board (FOB): Destination

Ship To and Mark For:

Electronic Delivery:

Primary Alternate Name: Name:

Address: VA Desert Pacific

Healthcare Network

(VISN 22)

Address:

Voice: Voice:

Email: Email:

https://www.energy.gov/femp/search-energy-efficient-products http://www.energystar.gov/ https://www.energy.gov/femp/low-standby-power-product-list

5.0 GENERAL REQUIREMENTS

5.1 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.

5.2 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.

5.3 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.

https://www.voa.va.gov/DocumentView.aspx?DocumentID=5010

5.4 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.

5.5 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.

5.6 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.)

https://www.whitehouse.gov/wp-content/uploads/2020/11/M-21-07.pdf https://www.nist.gov/programs-projects/usgv6-program/usgv6-revision-1 https://doi.org/10.6028/NIST.SP.500-267Br1 https://doi.org/10.6028/NIST.SP.800-119 https://www.whitehouse.gov/wp-content/uploads/2019/09/M-19-26.pdf https://www.cisa.gov/publication/tic-30-core-guidance-documents

5.7 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.

No web-based, publicly available generative AI service has been approved for use with VA-sensitive data including, but not limited to OpenAI’s ChatGPT, Microsoft’s Copilot, Google’s Gemini, and Anthropic’s Claude. No PII, protected health information (PHI), or VA-sensitive data should be entered into these unapproved services. The entire definition of VA Sensitive Data can be found at 38 U.S.C. § 5727 (23). 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 offerings without express permission from VA. Only VA-hosted instances of generative AI services may be approved for use with VA-sensitive data.

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

5.7.1 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 https://department.va.gov/ai/trustworthy/

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

5.7.2 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 Monthly Progress Reports.

A. Compliance Monitoring and Reporting Plan B. Corrective Action Plan

5.7.3 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.

A. AI Model/LLM Change Disclosure

6.0 SECURITY AND PRIVACY REQUIREMENTS

6.1 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:

Service Task / Item Number/Table

Tier1 / Low Risk Tier 2 / Moderate Risk

Tier 4 / High Risk

1.1 ☐ ☒ ☐

1.2 ☐ ☒ ☐

1.3 ☐ ☒ ☐

1.4 ☐ ☒ ☐

1.5 ☐ ☒ ☐

1.6 ☐ ☒ ☐

1.7 ☐ ☒ ☐

1.8 ☐ ☒ ☐

1.9 ☐ ☒ ☐

1.10 ☐ ☒ ☐

1.11 ☐ ☒ ☐

1.12 ☐ ☒ ☐

1.13 ☐ ☒ ☐

1.14 ☐ ☒ ☐

1.15 ☒ ☐ ☐

1.16 ☐ ☒ ☐

1.17 ☐ ☒ ☐

1.18 ☐ ☒ ☐

1.19 ☐ ☒ ☐

1.20 ☐ ☒ ☐

1.21 ☐ ☒ ☐

1.22 ☐ ☒ ☐

Service Task / Item Number/Table

Tier1 / Low Risk Tier 2 / Moderate Risk

Tier 4 / High Risk

1.23 ☐ ☒ ☐

1.24 ☐ ☒ ☐

1.25 ☐ ☒ ☐

1.26 ☐ ☒ ☐

1.27 ☐ ☒ ☐

1.28 ☐ ☒ ☐

1.29 ☐ ☒ ☐

1.30 ☐ ☒ ☐

1.31 ☒ ☒ ☐

1.32 ☒ ☐ ☐

1.33 ☐ ☒ ☐

1.34 ☐ ☒ ☐

1.35 ☒ ☐ ☐

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.

6.2 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

B1. 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.

B2. 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) contract is terminated for default or cause with a business associate, the related local Business Associate Agreement (BAA) shall also be terminated and actions taken in accordance with VHA Directive 1605.05, Business Associate Agreements. If there is an executed national BAA associated with the contract, VA will determine what actions are appropriate and notify the contractor.

h. The Contractor shall store and transmit VA sensitive information in an encrypted form, using VA-approved encryption tools which are, at a minimum, Federal Information Processing Standards (FIPS) 140-2, Security Requirements for Cryptographic Modules (or its successor) validated and in conformance with VA Information Security Knowledge Service requirements. The Contractor shall transmit VA sensitive information using VA approved Transport Layer Security (TLS) configured with FIPS based cipher suites in conformance with National Institute of Standards and Technology (NIST) 800-52, Guidelines for the Selection, Configuration and Use of Transport Layer Security (TLS) Implementations.

i. The Contractor’s firewall and web services security controls, as applicable, shall meet or exceed VA’s minimum requirements.

j. Except for uses and disclosures of VA information authorized by this contract for performance of the contract, the Contractor may use and disclose VA information only in two situations: (i) in response to a qualifying order of a court of competent jurisdiction after notification to VA CO (ii) with written approval from the VA CO.

The Contractor shall refer all requests for, demands for production of or inquiries about, VA information and information systems to the VA CO for response.

k. Notwithstanding the provision above, the Contractor shall not release VA records protected by Title 38 U.S.C. § 5705, Confidentiality of medical quality-assurance records and/or Title 38 U.S.C. § 7332, Confidentiality of certain medical records pertaining to drug addiction, sickle cell anemia, alcoholism or alcohol abuse or infection with Human Immunodeficiency Virus (HIV). If the Contractor is in receipt of a court order or other requests for the above-mentioned information, the Contractor shall immediately refer such court order or other requests to the VA CO for response.

l. Information made available to the Contractor by VA for the performance or administration of this contract or information developed by the Contractor in performance or administration of the contract will be protected and secured in accordance with VA Directive 6500 and Identity and Access Management (IAM) Security processes specified in the VA Information Security Knowledge Service.

m. Any data destruction done on behalf of VA by a Contractor shall be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management, VA Handbook 6300.1, Records Management Procedures, and applicable VA Records Control Schedules.

n. The Contractor shall provide its plan for destruction of all VA data in its possession according to VA Directive 6500 and NIST 800-88, Guidelines for Media Sanitization prior to termination or completion of this contract. If directed by the COR/CO, the Contractor shall return all Federal Records to VA for disposition.

o. Any media, such as paper, magnetic tape, magnetic disks, solid state devices or optical discs that is used to store, process, or access VA information that cannot be destroyed shall be returned to VA. The Contractor shall hold the appropriate material until otherwise directed by the Contracting Officer’s Representative (COR) or CO. Items shall be returned securely via VA-approved methods. VA sensitive information must be transmitted utilizing VA-approved encryption tools which are validated under FIPS 140-2 (or its successor) and NIST 800-52. If mailed, the Contractor shall send via a trackable method (USPS, UPS, FedEx, etc.) and immediately provide the COR/CO with the tracking information. Self-certification by the Contractor that the data destruction requirements above have been met shall be sent to the COR/CO within 30 business days of termination of the contract.

p. All electronic storage media (hard drives, optical disks, CDs, back-up tapes, etc.)

used to store, process or access VA information will not be returned to the Contractor at the end of lease, loan, or trade-in. Exceptions to this paragraph will only be granted with the written approval of the VA CO.

B3. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS

a. A Contractor/Subcontractor shall request logical (technical) or physical access to

VA information and VA information systems for their employees and subcontractors only to the extent necessary to perform the services specified in the solicitation or contract. This includes indirect entities, both affiliate of Contractor/Subcontractor and agent of Contractor/Subcontractor.

b. Contractors and subcontractors shall sign the VA Information Security Rule of

Behavior (ROB) before access is provided to VA information and information systems (see Section 4, Training, below). The ROB contains the minimum user compliance requirements and does not supersede any policies of VA facilities or other agency components which provide higher levels of protection to VA’s information or information systems. Users who require privileged access shall complete the VA elevated privilege access request processes before privileged access is granted.

c. All Contractors and Subcontractors working with VA information are subject to the same security investigative and clearance requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for contractors shall be in accordance with VA Directive and Handbook 0710, Personnel Vetting Program.

The Office of Human Resources and Administration/Operations, Security and Preparedness (HRA/OSP) is responsible for these policies and procedures.

Contract personnel who require access to classified information or information systems shall have an appropriate security clearance. Verification of a Security Clearance shall be processed through the Special Security Officer located in HRA/OSP. Contractors shall conform to all requirements stated in the National Industrial Security Program Operating Manual (NISPOM).

d. All Contractors and subcontractors shall comply with conditions specified in

VAAR 852.204-71(d); Contractor operations required to be in United States. All Contractors and Subcontractors working with VA information must be permanently located within a jurisdiction subject to the law of the United States or its Territories to the maximum extent feasible. If services are proposed to be performed abroad the Contractor must state where all non-U.S. services are provided. The Contractor shall deliver to VA a detailed plan specifically addressing communications, personnel control, data protection and potential legal issues. The plan shall be approved by the COR/CO in writing prior to access being granted.

e. The Contractor shall notify the COR/CO in writing immediately (no later than 24 hours) after personnel separation or occurrence of other causes. Causes may include the following:

(1) Contractor/Subcontractor personnel no longer has a need for access to VA information or VA information systems.

(2) Contractor/Subcontractor personnel are terminated, suspended, or otherwise has their work on a VA project discontinued for any reason.

(3) Contractor believes their own personnel or Subcontractor personnel may pose a threat to their company’s working environment or to any company-owned property. This includes Contractor-owned assets, buildings, confidential data, customers, employees, networks, systems, trade secrets and/or VA data.

(4) Any previously undisclosed changes to Contractor/Subcontractor background history are brought to light, including but not limited to changes to background investigation or employee record.

(5) Contractor/Subcontractor personnel have their authorization to work in the

United States revoked.

(6) Agreement by which Contractor provides products and services to VA has either been fulfilled or terminated, such that VA can cut off electronic and/or physical access for Contractor personnel.

f. In such cases of contract fulfillment, termination, or other causes; the Contractor shall take the necessary measures to immediately revoke access to VA network, property, information, and information systems (logical and physical) by Contractor/Subcontractor personnel. These measures include (but are not limited to): removing and then securing Personal Identity Verification (PIV) badges and PIV – Interoperable (PIV-I) access badges, VA-issued photo badges, credentials for VA facilities and devices, VA-issued laptops, and authentication tokens.

Contractors shall notify the appropriate VA COR/CO immediately to initiate access removal.

g. Contractors/Subcontractors who no longer require VA accesses will return VA-issued property to VA.