PWS-QASP Teleradiology - ATL.docx

Performance Work Statement for Tele-Radiology Physician Services

SCHEDULE OF SERVICES

The Contractor shall furnish all personnel to provide services necessary to perform Tele- Radiology Physician Services to eligible beneficiaries of the Department of Veterans Affairs Medical Center, Joseph M. McCleland – Atlanta VA Health Care System (hereinafter referred to as VAMC).

The VA Radiology Services follow the standards & guidelines set forth by American College of Radiology (ACR). A contractor providing Tele-radiology services shall provide services that meet or exceed the American College of Radiology Guidelines http://www.acr.org/Quality-Safety/Standards-Guidelines/Practice-Guidelines-by-Modality Place of Performance: Services shall be provided at 1670 Clairmont Road, Decatur GA 30033

Period of Performance: BASE AND OPTION YEARS: Base year and four (4) option year

Period of Performance: BASE: 11/01/2024 to 10/31/2025

Qty.

Total for base year: $____________

Period of Performance: OPTION 1: 11/01/2025 to 10/31/2026

Qty.

Total for option 1 year: $__________

Period of Performance: OPTION 2: 11/01/2026 to 10/31/2027

Qty.

Total for option 2 year: $__________

Period of Performance: OPTION 3: 11/01/2027 to 10/31/2028

Qty.

Total for option 3 year: $___________

Period of Performance: OPTION 4: 11/01/2028 to 10/31/2029

Qty.

Total for option 4 year: $____________

Performance Work Statement for Tele-Radiology Physician Services

1. GENERAL:

1.1. Services Provided: The Contractor shall provide Board Certified Radiology Physician Services in accordance with the specifications contained herein to beneficiaries of the Department of Veterans Affairs (VA) and the Joseph M. McCleland Atlanta VA Health Care System. The VA Radiology Services follow the standards & guidelines set forth by American College of Radiology (ACR). A contractor providing tele-radiology services shall provide services consistent with TJC and that meet or exceed VA and the American College of Radiology Guidelines as defined in this document.

1.2. Place of Performance: Contractor shall furnish services at the Atlanta VAHCS 1670 Clairmont Road, Decatur GA 30033 / TeleRadiology Services

1.3. Authority: Title 38 USC 8153, Health Care Resources (HCR) sharing Authority.

1.4. Policy/Handbooks: the contractor shall be subject to the following policies, including any subsequent updates during the period of performance:

1.4.1. VHA Handbook 1100.17: National Practitioner Data Bank Reports: https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=2135

1.4.2. VHA Handbook 1100.18: Reporting And Responding To State Licensing Boards:

https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=9174

1.4.3. VHA Handbook 1100.19: Credentialing and Privileging: http://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=2910

1.4.4. VHA Directive 1003.04: VHA Patient Advocacy: https://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=5970

1.4.5. VHA Directive 1088: Communicating Test Results to Providers and Patients: https://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=3148

1.4.6. VHA Directive 1192.01: Seasonal Influenza Prevention Program: https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=8948

1.4.7. VHA Directive 1220(1): Facility Procedure Complexity Designation Requirements to Perform Invasive Procedures In Any Clinical Setting: https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=8365

1.4.8. VHA Directive 1400.01: Supervision of Physician, Dental, Optometry, Chiropractic, and Podiatry Residents: https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=8579

1.4.9. VHA Directive 1907.01: VHA Health Information Management and Health Records: https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=9235

1.4.10. VHA Directive 1100.20 Credentialing of Health Care Providers: https://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=9444

1.4.11. VA Directive 1663: Health Care Resources Contracting – Buying: https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=969&FType=2

1.4.12. Privacy Act of 1974 (5 U.S.C. 552a) as amended: http://www.justice.gov/oip/foia_updates/Vol_XVII_4/page2.htm

1.4.13. 42 Code of Federal Regulations (CFR) Part 482 Conditions of Participation Hospitals:

https://www.ecfr.gov/cgi-bin/text-idx?node=pt42.5.482&rgn=div5

1.5. Definitions/Acronyms: Terms used in this contract shall be interpreted as follows unless the context expressly requires a different construction and/or interpretation. In case of a conflict in language between the Definitions and other sections of this contract, the language in this section shall govern.

1.5.1. ACEP: American College of Emergency Physicians

1.5.2. ACGME: Accreditation Council for Graduate Medical Education

1.5.3. AOD: Admitting Officer of the Day

1.5.4. CDC: Centers for Disease Control and Prevention

1.5.5. CDR: Contract Discrepancy Report

1.5.6. CEU: Certified Education Unit

1.5.7. CME: Continuing Medical Education

1.5.8. CMS: Centers for Medicare and Medicaid Services

1.5.9. Contracting Officer (CO): The person executing this contract on behalf of the Government with the authority to enter into and administer contracts and make related determinations and findings.

1.5.10. Contracting Officer’s Representative (COR): A person appointed by the CO to take necessary action to ensure the Contractor performs in accordance with and adheres to the specifications contained in the contract and to protect the interest of the Government. The COR shall report to the CO promptly any indication of non-compliance in order that appropriate action can be taken.

1.5.11. COS: Chief of Staff

1.5.12. COVID-19: Coronavirus Disease 2019

1.5.13. CPARS: Contractor Performance Assessment Reporting System

1.5.14. Credentialing: Credentialing is the systematic process of screening and evaluating qualification and other credentials, including licensure, required education, relevant training and experience and current competence and health status.

1.5.15. DEA: Drug Enforcement Agency

1.5.16. EHR: Electronic Health Record - electronic health record system used by the VA

1.5.17. FSMB: Federation of State Medical Boards

1.5.18. HHS: Department of Health and Human Services

1.5.19. HIPAA: Health Insurance Portability and Accountability Act

1.5.20. HR: Human Resources

1.5.21. ISO: Information Security Officer

1.5.22. MOD: Medical Officer of the Day

1.5.23. National Provider Identifier (NPI): NPI is a standard, unique 10-digit numeric identifier required by HIPAA. The Veterans Health Administration must use NPIs in all HIPAA-standard electronic transactions for individual (health care practitioners) and organizational entities (medical centers).

1.5.24. NPPES: National Plan and Provider Enumeration System

1.5.25. POP: Period of Performance

1.5.26. PPD: Purified Protein Derivative

1.5.27. PWS: Performance Work Statement

1.5.28. Privileging (Clinical Privileging): Privileging is the process by which a practitioner, licensed for independent practice; e.g., without supervision, direction, required sponsor, preceptor, mandatory collaboration, etc.; is permitted by law and the facility to practice independently, to provide specific medical or other patient care services within the scope of the individual’s license, based upon the individual’s clinical competence as determined by peer references, professional experience, health status, education, training and licensure. Clinical privileges must be facility-specific and provider-specific.

1.5.29. QA/QI: Quality Assurance/Quality Improvement

1.5.30. QM/PI: Quality Management/Performance Improvement

1.5.31. QASP: Quality Assurance Surveillance Plan

1.5.32. Veterans Health Administration (VHA): The central office for administration of the VA medical centers through throughout the United States. The VHA is located in Washington, D.C.

1.5.33. Veterans Integrated Services Network (VISN): The regional oversight for the VA medical centers.

1.5.34. VISTA (Veterans Integrated Systems Technology Architecture): A PC based system that will capture and store clinical imagery, scanned documents and other non-textual data files and integrates them into patient’s medical record and with the hospital information system.

1.5.35. VetPro: a federal web-based credentialing program for healthcare providers.

1.5.36. Veterans Affairs Medical Center (VAMC): Unless identified with the name of a different VA medical Center, for purposes of this contract, this term shall mean the Atlanta Medical Center.

2. QUALIFICATIONS:

2.1. Staff/Facility

2.1.1. License: Contract physician(s) assigned by the Contractor to perform the services covered by this contract shall have a current license to practice medicine in State, Territory, or Commonwealth of the United States for services that are being performed.

All licenses held by the personnel working on this contract shall be full and unrestricted licenses. Information on state licensing in tele-radiology may be found at this site: https://www.acr.org/Advocacy-and-Economics/State-Issues/Licensure-Requirements. Contract physician(s) who have current, full and unrestricted licenses in one or more states, but who have, or ever had, a license restricted, suspended, revoked, voluntarily revoked, voluntarily surrendered pending action or denied upon application will not be considered for the purposes of this contract.

2.1.2. Board Certification: All contract physician(s) shall be board certified . All continuing education courses required for maintaining certification must be kept up to date at all times. Documentation verifying current certification shall be provided by the Contractor to the VA COR on an annual basis for each year of contract performance.

2.1.3. Credentialing and Privileging: Credentialing and privileging is to be done in accordance with the provisions of VHA Handbook 1100.19 and VHA Directive 1100.20 referenced above. The Contractor is responsible to ensure that proposed physician(s) possesses the requisite credentials enabling the granting of privileges. No services shall be provided by any contract physician(s) prior to obtaining approval by the Atlanta VA Professional Standards Board, Medical Executive Board and Medical Center Director.

2.1.3.1. If a contract physician(s) is not credentialed and privileged or has credentials/privileges suspended or revoked, the Contractor shall furnish an acceptable substitute without any additional cost to the government.

2.1.3.2. When telemedicine services are being provided by contract physician(s) who direct, diagnose or otherwise provide clinical treatment to a patient via a telemedicine link, the contract physician(s) must be appointed, credentialed, and privileged at the VA facility (facilities) which receive the telemedicine services (patient site), as well as at the site providing the services. The following requirements apply:

2.1.3.3. Contract licensed independent practitioners must be credentialed and privileged through the VA facility’s Medical Staff Office in accordance with VHA Handbook 1100.19, Credentialing and Privileging and VHA Directive 1100.20.

2.1.3.4. Separately delineated privileges for telemedicine services must be requested and assigned in this process.

2.1.3.5. In general, the credentialing process should be started at least 60-90 days in advance of estimated entry on duty. The time required for this process may be expedited when patient care needs are urgent.

2.1.3.6. The VA’s Medical Staff Office or Human Resources Management Service will provide an instruction packet containing forms and a detailed listing of required documentation, including curriculum vitae, current references, signed release of information from the candidate, and statement that the candidate does not have any physical or mental health condition that would adversely affect his/her ability to carry out the assigned duties, and additional credentialing forms. The candidate will also be required to make application through the VetPro internet-based process. The candidate will need to be enrolled in VetPro by the Credentialing Coordinator at the VA or by the Human Resources Management Service designee. The website address is: http://fep.vetpro.org/ It is the Contractor’s responsibility to contact the facility to request a package and instructions.

2.1.3.7. When contract physician(s) provide only teleconsultation by offering advice that supports care provided by VA’s on site licensed independent providers, the Contractor must furnish VA with a copy of the contract physician(s) credentials, verification of credentials, and current clinical privileges. The contract physician(s) providing teleconsultation services do not have to be separately privileged at the VA facility.

2.1.3.8. The Contractor must furnish a copy of its policy and procedures for credentialing and privileging to the Contracting Officer and COR for review to ensure these meet the VA’s requirements for establishment of competence through these mechanisms.

2.1.4. Technical Proficiency - Contract physician(s) shall be technically proficient in the skills necessary to fulfill the government’s requirements, including the ability to speak, understand, read and write English fluently. Contractor shall provide documents upon request of the CO/COR to verify current and ongoing competency, skills, certification and/or licensure related to the provision of care, treatment and/or services performed. Contractor shall provide verifiable evidence of all educational and training experiences including any gaps in educational history for all contract physician(s) and contract physician(s) shall be responsible for abiding by the Facility's Medical Staff By-Laws, rules, and regulations (referenced herein) that govern medical staff behavior.

2.1.5. Continuing Medical Education (CME)/ Certified Education Unit (CEU) Requirements: Contractor shall provide the COR copies of current CMEs as required or requested by the VAMC. Contract physician(s) registered or certified by national/medical associations shall continue to meet the minimum standards for CME to remain current. Contractor shall report CME hours to the credentials office for tracking. These documents are required for both privileging and re-privileging. Failure to provide shall result in loss of privileges for contract physician(s).

2.1.6. Training (ACLS, BLS, EHR and VA MANDATORY): Contractor shall meet all VA educational requirements and mandatory course requirements defined herein; all training must be completed by the contract physician(s) as required by the VA.

List all training required, frequency and associated time

2.1.7. Standard Personnel Testing/Infection Control: Contractor shall provide statement that all required infection control testing is current and that the contractor is compliant with OSHA regulations concerning occupational exposure to blood borne pathogens. The Contractor shall also notify the VA of any significant communicable disease exposures and the VA will also notify the contractor of the same, as appropriate. Contractor shall adhere to current CDC/HICPAC Guideline for Infection Control in health care personnel ( as published in American Journal for Infection Control- AJIC 1998; 26:289-354 http://www.cdc.gov/hicpac/pdf/InfectControl98.pdf) for disease control. Contractor shall provide follow up documentation of clearance to return to the workplace prior to their return. Tests shall be current within the past year.

2.1.8. National Provider Identifier (NPI): NPI is a standard, unique 10-digit numeric identifier required by HIPAA. The Veterans Health Administration must use NPIs in all HIPAA-standard electronic transactions for individual (health care practitioners) and organizational entities (medical centers). The Contractor shall have or obtain appropriate NPI and if pertinent the Taxonomy Code confirmation notice issued by the Centers for Medicare and Medicaid Services (CMS) National Plan and Provider Enumeration System (NPPES) be provided to the Contracting Officer with the proposal.

2.1.9. Conflict of Interest: The Contractor and all contract physician(s) are responsible for identifying and communicating to the CO and COR conflicts of interest at the time of proposal and during the entirety of contract performance. At the time of proposal, the Contractor shall provide a statement which describes, in a concise manner, all relevant facts concerning any past, present, or currently planned interest (financial, contractual, organizational, or otherwise) or actual or potential organizational conflicts of interest relating to the services to be provided. The Contractor shall also provide statements containing the same information for any identified consultants or subcontractors who shall provide services. The Contractor must also provide relevant facts that show how it’s organizational and/or management system or other actions would avoid or mitigate any actual or potential organizational conflicts of interest. These statements shall be in response to the VAAR provision 852.209-70 Organizational Conflicts of Interest and fully outlined in response to the subject attachment in Section D of the solicitation document.

2.1.10. Citizenship related Requirements:

2.1.10.1. The Contractor certifies that the Contractor shall comply with any and all legal provisions contained in the Immigration and Nationality Act of 1952, As Amended; its related laws and regulations that are enforced by Homeland Security, Immigration and Customs Enforcement and the U.S Department of Labor as these may relate to non-immigrant foreign nationals working under contract or subcontract for the Contractor while providing services to Department of Veterans Affairs patient referrals;

2.1.10.2. While performing services for the Department of Veterans Affairs, the Contractor shall not knowingly employ, contract or subcontract with an illegal alien; foreign national non-immigrant who is in violation their status, as a result of their failure to maintain or comply with the terms and conditions of their admission into the United States. Additionally, the Contractor is required to comply with all “E-Verify” requirements consistent with “Executive Order 12989” and any related pertinent Amendments, as well as applicable Federal Acquisition Regulations.

2.1.10.3. If the Contractor fails to comply with any requirements outlined in the preceding paragraphs or its Agency regulations, the Department of Veterans Affairs may, at its discretion, require that the foreign national who failed to maintain their legal status in the United States or otherwise failed to comply with the requirements of the laws administered by Homeland Security, Immigration and Customs Enforcement and the U.S Department of Labor, shall be prohibited from working at the Contractor’s place of business that services Department of Veterans Affairs patient referrals; or other place where the Contractor provides services to veterans who have been referred by the Department of Veterans Affairs; and shall form the basis for termination of this contract for breach.

2.1.10.4. This certification concerns a matter within the jurisdiction of an agency of the United States and the making of a false, fictitious, or fraudulent certification may render the maker subject to prosecution under 18 U.S.C. 1001.

2.1.10.5. The Contractor agrees to obtain a similar certification from its subcontractors. The certification shall be made as part of the offerors response to the RFP using the subject attachment in Section D of the solicitation document.

2.1.11. Annual Office of Inspector General (OIG) Statement: In accordance with HIPAA and the Balanced Budget Act (BBA) of 1977, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) has established a list of parties and entities excluded from Federal health care programs. Specifically, the listed parties and entities may not receive Federal Health Care program payments due to fraud and/or abuse of the Medicare and Medicaid programs.

2.1.11.1. Therefore, Contractor shall review the HHS OIG List of Excluded Individuals/Entities on the HHS OIG web site at http://oig.hhs.gov/exclusions/index.asp to ensure that the proposed contract physician(s) are not listed. Contractor should note that any excluded individual or entity that submits a claim for reimbursement to a Federal health care program, or causes such a claim to be submitted, may be subject to a Civil Monetary Penalty (CMP) for each item or service furnished during a period that the person was excluded and may also be subject to treble damages for the amount claimed for each item or service. CMP’s may also be imposed against the Contractor that employ or enter into contracts with excluded individuals to provide items or services to Federal program beneficiaries.

2.1.11.2. By submitting their proposal, the Contractor certifies that the HHS OIG List of Excluded Individuals/Entities has been reviewed and that the Contractors are and/or firm is not listed as of the date the offer/bid was signed.

2.2. Clinical/Professional Direction: The qualifications of Contractor personnel are subject to review by VA Medical Center COS or his/her clinical designee and approval by the Medical Center Director as provided in VHA Handbook 1100.19 and VHA Directive 1100.20. Clinical/Professional direction of all clinical personnel covered by this contract for quality purposes will be provided by the VAMC COS and/or the Chief of the Service or his designee. A clinical COR may be appointed, however, only the CO is authorized to consider any contract modification request and/or make changes to the contract during the administration of the resultant contract.

2.3. Non Personal Healthcare Services: The parties agree that the Contractor and all contract physician(s) shall not be considered VA employees for any purpose.

2.4. Inherent Government Functions: Contractor and Contract physician(s) shall not perform inherently governmental functions. This includes, but is not limited to, determination of agency policy, determination of Federal program priorities for budget requests, direction and control of government employees (outside a clinical context), selection or non-selection of individuals for Federal Government employment including the interviewing of individuals for employment, approval of position descriptions and performance standards for Federal employees, approving any contractual documents, approval of Federal licensing actions and inspections, and/or determination of budget policy, guidance, and strategy.

2.5. No Employee status: The Contractor shall be responsible for protecting Contract physician(s) furnishing services. To carry out this responsibility, the Contractor shall provide or certify that the following is provided for all their staff providing services under the resultant contract:

2.5.1. Workers’ compensation

2.5.2. Professional liability insurance

2.5.3. Health examinations

2.5.4. Income tax withholding, and

2.5.5. Social security payments.

2.6. Tort Liability: The Federal Tort Claims Act does not cover Contractor or contract physician(s). When a Contractor or contract physician(s) has been identified as a provider in a tort claim, the Contractor shall be responsible for notifying their legal counsel and/or insurance carrier. Any settlement or judgment arising from a Contractor’s (or contract physician(s)) action or non-action shall be the responsibility of the Contractor and/or insurance carrier.

2.7. Contingency Plan: Because continuity of care is an essential part of VAMC’s medical services, The Contractor shall have a contingency plan in place to be utilized if the contract physician(s) leaves Contractor’s employment or is unable to continue performance in accordance with the terms and conditions of the resulting contract.

2.7.1. Contractor shall submit a listing of proposed key personnel performing technical delivery of services in the following format:

Provider Name: ___________________ Title/Rank: __________________.

Curriculum Vitae and qualification documents of each key personnel shall be submitted with the proposal.

2.8. Emergency Substitutions: During the first ninety (90) calendar days of performance, the Contractor shall make NO substitutions of key personnel unless the substitution is necessitated by illness, death or termination of employment. The Contractor shall notify the CO, in writing, within _10__ calendar day (s) after the occurrence of any of these events and provide the information required below. After 90 days, the Contractor shall submit the information required below to the CO at least _10__ calendar days prior to making any permanent substitutions

2.8.1. The Contractor shall provide a detailed explanation of the circumstances necessitating the proposed substitutions, complete resumes for the proposed substitutes, and any additional information requested by the CO. Proposed substitutes shall have comparable qualifications to those of the persons being replaced. The CO will notify the Contractor within _5__ calendar days after receipt of all required information of the decision on the proposed substitutes. The contract will be modified to reflect any approved changes of key personnel

2.8.2. For temporary substitutions where the key person shall not be reporting to work for three _3__ consecutive work days or more, the Contractor shall provide a qualified replacement for the key person. The substitute shall have comparable qualifications to the key person. Any period exceeding two weeks will require the procedure as stated above

3. HOURS OF OPERATION

3.1. Business Hours: Monday – Friday 0700 - 1730

3.2. Contractor shall be available to the VAMCs for consultation and interpretation 24 hours a day, 7 days a week, 52 weeks a year for stat, urgent, and routine exams.

3.3. Federal Holidays: The following holidays are observed by the Department of Veterans Affairs:

· New Year’s Day

· President’s Day

· Martin Luther King’s Birthday

· Memorial Day

· Juneteenth

· Independence Day

· Labor Day

· Columbus Day

· Veterans Day

· Thanksgiving

· Christmas

· Any day specifically declared to be a national holiday.

3.4. Continuity of services under contact:

3.4.1. Contractor is responsible for providing qualified personnel to read films. The VA must be informed at least 48 hours in advance if there will be a significant change in contractor’s ability to perform to allow for planning of service coverage and workload distribution. Requirements as noted in attachment B will be provided to all VAMCs and maintained by the contractor.

3.4.2. The contractor shall maintain open and professional communication with members of the VISN and Facility Diagnostic Imaging staff. The contractor shall provide up-to-date points of contact to facilitate communication on clinical, technical and administrative issues. Clinical staff will be available by phone and pager 24/7. The Contractor will provide a schedule of radiologists with telephone numbers for consultation by VA technologists and referring physicians. The contractor will provide a FAX number for the transmission of radiographic orders.

3.4.3. The Contractor shall provide a single phone number with a list of individuals who could be contacted to immediately resolve any difficulties experienced during the hours of teleradiology services and STAT studies after hours. The COR will assure up-to-date rosters of staff are provided to the Contractor.

3.4.4. Tele-Communications

3.4.4.1. The contractor will secure and maintain the communications link between the contractor’s facility and the VAMCs’ facilities at the contractor’s expense. These expenses may be included in contractor’s proposal as a separate item. The cost to establish and maintain this communication link may be provided if the Government deems it is more cost effective to the Government.

3.4.4.2. In the event of telecommunications failure, the Government shall package, hard copy film or alternative media in Government-provided shipping containers, and ship to the contractor’s facility; using Government provided pre-paid shipping documentation. The contractor’s place of business must be within the confines of the continental United States.

3.4.4.3. The contractor shall make provisions for the proper maintenance and functioning of all imaging, teleradiology and associated equipment, facilities and fixtures as may reasonably be required by Contract Physicians to perform services hereunder.

4. CONTRACTOR RESPONSIBILITIES

4.1. Clinical Personnel Required: The Contractor shall provide contract physician(s) who are competent, qualified per this performance work statement and adequately trained to perform assigned duties. .

4.2. Management and Supervision:

4.2.1. The Contractor shall be responsible for supervising the daily services provided under this contract by the Contractor’s staff.

4.2.2. The Contractor shall have written policies and procedures regarding staff credentials and privileging.

4.2.3. The VAMC will provide to the Contractor policies, procedures and processes necessary to allow cooperative functioning between the agency and VAMC. Updates and refreshers will be provided to the Contractor upon request and when policy procedures or process changes.

4.2.4. The Contractor shall complete background investigations to insure that employees do not have a record of criminal offenses or substantiated incidents of patient abuse; and, if required to perform their duties, employees are properly licensed and insured to operate motor vehicles.

4.3. Standards of Care: The contract physician(s)’ care shall cover the range of Radiology services as would be provided in a state-of-the-art civilian medical treatment facility and the standard of care shall be of a quality, meeting or exceeding currently recognized national standards as established by:

4.3.1. The American College of Radiology Guidelines: http://www.acr.org/~/media/ACR/Documents/PGTS/toc.pdf

4.3.2. ACR Practice Parameter for Communication of Diagnostic Imaging Findings: http://www.acr.org/~/media/C5D1443C9EA4424AA12477D1AD1D927D.pdf

4.3.3. VA Standards: MCM-113 Reporting of Critical Tests and Results

GUIDELINES FOR COMMUNICATION OF DIAGNOSTIC IMAGING RESULTS

Radiology Service

COMMUNICATION TIMEFRAMES:

Critical Result: 1 hour Critical Test: Head CT w/o contrast to rule out intracerebral hemorrhage Ordered ‘STAT’; clinical history must include ordering provider contact information.

Results within 2 hours, in-patient order.

Results within 3 hours, emergency ‘call-back’ order.

Critical Result – A test result that is interpreted as being severe and/or life threatening will be communicated to the ordering provider within 1 hour from exam completion. The dictated Radiology report will include a statement that notates the time and name of the provider notified of the critical findings.

The following diagnostic findings include, but are not limited to:

1. Cerebral hemorrhage

2. Cerebral hematoma

3. Brain tumor with mass effect

4. Depressed skull fracture

5. Spinal cord compression

6. Carotid artery dissection

7. Tension pneumothorax

8. Aortic dissection

9. Pulmonary embolism

10. Ruptured aneurysm

11. Impending aneurysm rupture

12. Free air

13. Appendicitis

14. Portal venous gas

15. Volvulus

16. Mediastinal emphysema

17. Acute traumatic visceral injury

18. Retroperitoneal hemorrhage

19. Stress induced ischemia

20. Ectopic pregnancy

21. Testicular torsion

22. Ovarian torsion

23. Acute DVT

24. Significant line misplacement

25. Significant tube misplacement

4.3.4. The professional standards of the Joint Commission (TJC): http://www.jointcommission.org/standards_information/hap_requirements.aspx

4.3.5. The standards of the American Hospital Association (AHA): http://www.hpoe.org/resources?show=100&type=8 and;

4.4. MEDICAL RECORDS

4.4.1. Authorities: Contractor’s physician(s) providing healthcare services to VA patients shall be considered as part of the Department Healthcare Activity and shall comply with the 5 U.S.C.552a (Privacy Act), 38 U.S.C. 5701 (Confidentiality of claimants records), 5 U.S.C. 552 (FOIA), 38 U.S.C. 5705 (Confidentiality of Medical Quality Assurance Records) 38 U.S.C. 7332 (Confidentiality of certain medical records), Title 5 U.S.C. § 522a (Records Maintained on Individuals) as well as 45 C.F.R. Parts 160, 162, and 164 (HIPAA).

4.4.2. HIPAA: This contract and its requirements meet exception in 45 CFR 164.502(e), and do not require a BAA in order for Covered Entity to disclose Protected Health Information to: a health care provider for treatment of VA patients. Based on this exception, a BAA is not required for this contract. Health records generated by this contract or provided to the Contractors by the VA are covered by the VA Privacy Act system of records entitled ‘Patient Medical Records-VA’ (24VA10A7). Contractor generated VA Patient records are the property of the VA and shall not be accessed, released, transferred, or destroyed except in accordance with applicable laws and regulations. Contractor shall ensure that all records pertaining to medical care and services provided to VA patients are captured in the VA electronic health record system as required by VA policy as discussed in 4.4.4.

4.4.3. Disclosure: Contractor’s physician(s) may have access to patient medical records for the purpose of providing medical care and services to VA patients and performing services under the contract. VA authorizes the Contractor to discuss patient health information for coordination of care with community health care providers in compliance with VA regulations, HIPAA and VHA Directive 1605.01, Privacy and Release of Information. The VA will provide the Contractor with a copy of VHA Handbook 1907.01, Health Information Management and Health Records and VHA Directive 1605.1, Privacy and Release of Information. The penalties and liabilities for the unauthorized disclosure of VA patient information mandated by the statutes and regulations mentioned above, apply to the Contractor.

4.4.4. Professional Standards for Documenting Care: Care shall be appropriately documented in medical records in accordance with standard commercial practice and guidelines established by VHA Handbook 1907.01 Health Information Management and Health Records: https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=9235 and all guidelines provided by the VAMC.

4.4.4.1. All film interpretations will either meet or exceed established VISN standards of timeliness, accuracy, content and signature. Only VAMC approved abbreviations will be used for documentation of the patient health record. All imaging exam interpretations shall either meet or exceed established standards of timeliness, accuracy, content, and signature. Only medical abbreviations from The Joint Commission’s National Patient Safety Goals, current edition, will be used for documentation of the patient health record. Those abbreviations not acceptable to conform with the JCAHO directives.

4.4.4.2. Interpretations shall include the following information:

Patient’s full name, SSN, date of birth, clinical history, exam case number (accession number), date of interpretation, requesting physician, exam type, interpretation, and signature of contract radiologist providing interpretation.

4.4.4.2.1. Each VAMC will provide necessary procedures for reports to be reviewed, edited (if required), and for electronic signature approval by the Contractor. Contractor will provide interpretation per routine exam to the respective VAMC within 24 hours after receipt of images. Contractor will not be held responsible for late reports caused by delays in the respective transcription service system. All exam study interpretation reports shall be dictated into the designated VAMC system and verified in the VISN Vista dictation system. Non-routine and emergency exams will be handled on a case-by-case basis, but all emergency exams will take precedence over all routine exams.

4.4.4.2.2. Supervision of residents for any services provided by such residents must meet all applicable Medicare documentation requirements for teaching physicians. The teaching physician must document that he/she personally reviewed the image and resident's interpretation and either agree with it or edit the findings. A countersignature by an attending of the resident's interpretation is not sufficient.

4.4.5. Release of Information: The VA shall maintain control of releasing any copies of patient health information or health records and will follow policies and standards as defined, but not limited to Privacy Act requirements. Contractor will not release or disclose copies of records and will refer all such requests to the Release of Information Department at the VA facility were assigned.

4.4.6. Management for Medical Records: National Archives and Records Administration record disposition requirements are found in RCS 10-1 Chapter 6, 6000 series.

4.4.7. MEDICAL RECORDS/COMPUTERIZED RECORD SYSTEMS/ DISCLOSURE/ RECORD RETENTION All records created from these actions shall be managed per Record Control Schedule (RCS) 10-1. Close attention shall be given to disposition schedule found in RCS 10-1 Chapter 4, 4000 series (General Record Schedule 1.1) . Other records included but not limited too Chapter 1, 1180.15 and 1180.23 (GRS 1.1) , Chapter 5, 5020.5 (GRS 5.4). There are some specific special contracting record schedule in RCS 10-1 for individual groups of records.

4.4.8. MEDICAL RECORDS REQUIREMENTS: Authorities: Contractor providing treatment and healthcare services to VHA patients in the community shall comply with 45 C.F.R. Parts 160, 162, and 164 (Health Insurance Portability and Accountability Act’s Privacy Rule) and any other applicable law regarding health information, including contractual obligations as outlined in the Community Care Network (CCN) contract.

4.4.9. Health records provided to the Contractor by the VA for the medical care and services to VA patients are covered by VHA Privacy Act system of records entitled ‘Patient Medical Records-VA’ 24VA10A7 at http://vaww.oprm.va.gov/docs/Current_SORN_List_11_13_2020.pdf. Address and authority exists to disclosure these records to the Contractor for treatment purposes.

4.4.10. Contractor generated patient medical records are the property of the contractor and shall not be accessed, released, transferred, or destroyed except in accordance with applicable laws and regulations. Contractor shall ensure that copies of all health records pertaining to medical care and services provided to VHA patients are available for transmission and release when requested by VHA in accordance with the CCN contract, for treatment or payment purposes. As part of reimbursing the contractor for medical care and services provided to VHA patients, copies of health records may be required for payment and quality reviews.

4.4.11. Direct Patient Care: estimated _0__% of the time involved in direct patient care. Contractor shall be responsible for no direct patient care.

4.4.11.1. Scope of Care: Contract physician(s) shall be responsible for providing : including, but not limited to:

4.4.11.1.1. Physicians provided in satisfaction of this contract shall be required to perform their assigned duties with regards to all admitted patients, outpatients, and eligible beneficiaries regardless of underlying disease process or physical condition of such patients or beneficiaries. The contract shall provide physicians who shall:

4.4.11.1.2. Contractor shall provide board certified Radiologists to perform final teleradiology Interpretation services. Examination images captured by VISN medical centers will be transmitted to the contractor using the DICOM protocol and the Federal Information Processing Standard (FIPS) compliant encryption. Upon receipt of captured image and patient information from a VISN facility, the contractor shall provide an interpretation for studies. VISN personnel will inform the contractor once images are ready for viewing once the images are sent using the PACS electronic system. These procedures will be rendered in writing once the contract is awarded.

4.4.11.1.3. The Contract physician(s) shall dictate all interpreted studies into the VAMCs indentified transcription service company or into the VAMCs Radiology voice recognition system, whichever is more advantageous to the Government, to ensure report entry into the VA electronic medical record (Vista/EHR). At the discretion of the VISN, the PowerScribe 360, speech recognition dictation system, can be used for report dictation and e-signature. Training on the VAMC facility dictation system will be provided by the VISN prior to contract physicians beginning work on this contract, if applicable. Contract Radiologists will have control of the reporting process from dictation to report sign-off/electronic signature/approval. The contract Radiologist dictates self edits and approves their reports within the application. No transcription services will be provided. Report quality/content will follow ACR standards of report structure and communication of results. Contract Radiologist(s) will notify clinicians of critical findings in accordance with American College of Radiology (ACR) standards, VHA and the VISN "alert notification" policies and in a manner appropriate to the clinical urgency of the case. When required by policy, contract Radiologists will supplement critical finding reporting methods by use of the diagnostic code function. If the Contractor prefers to use alternate voice recognition software programs, the product must be integrated into the VA VistA/EHR and function as outlined above. The VAMCs will provide necessary procedures for reports to be reviewed, edited (if required), and electronic signature approval by the contractor.

4.4.11.1.4. If a serious medical condition is identified during the interpretation; the report shall be immediately called in telephonically or faxed to the attention of VISN16 medical facilty’s designated POC for their information and action. Procedures outlined in Attachment G “Guideline for Communication of Significant Imaging Results” will be followed.

4.4.11.1.5. All STAT exams, when properly identified, will be performed and the results communicated within one (1) hour of receipt of images and appropriate paperwork. STAT exams shall be identified by a telephone call to contractor or by a stamp or other indication on the paperwork provided by contractor. All STAT exams must be identified at or prior to receipt of the images and paperwork by contractor. For STAT exams, a preliminary reading will be provided by a radiologist or experienced radiology resident within 1 hour of the image being transmitted to the reading site. The level of experience of the preliminary reader must be, at a minimum, the same level the Contractor provides for its own patients. A preliminary reading will be transmitted back to the referral site within 1 hour of the image being transmitted to the reading site. This can occur by fax, email, or by direct entry into the VA electronic medical record. (Note: “Preliminary” is defined as abbreviated results. The actual substance of the interpretation is NOT to change in any significant way from “preliminary” to “final” interpretation). All stat exams require the contractor to call the requesting physician within one business day from the time the images were transmitted providing a verbal interpretation. The signed dictated report will be completed within 48 hours of receipt. VA will not need to guarantee any minimum image volume.

4.4.11.1.6. Final interpretation and official signature will be electronically uploaded into the VA VISTA Radiology package and electronically signed in VISTA by an attending radiologist within 24 hours of the image being transmitted to the reading site.

4.4.11.1.7. Availability to consult with a radiologist to determine the most appropriate study for the clinical scenario involved; although for the most part, pre-defined protocols would be used. Fees may be charged for such consults if the consult does not result in an imaging study being performed.

4.4.11.1.8. Mechanisms must be in-place to provide notification of test results for patients receiving care in accordance with VHA Directive 1088, Communicating Test Results to Providers and Patients.

4.4.12. ADMINISTRATIVE: estimated 0% of time not involved in direct patient care.

4.4.12.1. Must take part in medical staff functions as required to meet the standards of the Joint Commission on Accreditation of Health Care Organizations.

4.4.12.2. QA/QI documentation: The contract physician(s) shall complete the appropriate QM/PI documentation pertaining to all procedures, complications and outcome of examinations.

4.4.13. SYSTEM REQUIREMENTS: If Applicable

4.4.13.1. If VISN chooses to use the contractor’s teleradiology system and PACS in lieu of supplying its own teleradiology system and PACS, then the contractor must maintain a teleradiology system that is reliable and functional to prevent any disruption in the delivery of services. Data transmission security must be maintained at all times. VAMC personnel must be notified immediately of any equipment malfunctions that would hinder the transmission of images.

4.4.13.2. Contractor warrants that any data containing patient-specific identifiers will be handled in such a way as to prevent disclosure to unauthorized parties. This includes transmission of the data (from the point at which the data leaves the VA network to the point at which the images are interpreted) as well as storage of the data by the Contractor. Contractor agrees to comply with all applicable data security laws and guidelines, as well as HIPAA and various JCAHO provisions. The contractor will provide utmost care and attention to patient data. All patients will be assured of their privacy and personal dignity in accordance with applicable laws, rules and regulations. Refer to Attachment A for specific guidelines regarding protected health information. All patient information remains the sole property of the US Government and may not be used for any purpose other than those stipulated in this agreement.

4.4.13.3. VA will act as primary custodian of the patient information (including both the image data and the report) for all purposes related to VA and Government records retention requirements.

4.4.13.4. Patient information, including images, will be retained by the Contractor only for the minimum period of time required to comply with any applicable laws, and should then be purged.

4.4.13.5. Upon request, Contractor will provide VA with access to information pertaining to the way in which the Contractor maintains VA patient data and thesteps taken on an ongoing basis to assure the privacy and security thereof. This includes, but is not limited to, information regarding computer network architecture, configuration of firewall(s), routers, and other pieces of networking equipment, information about installed security software, and audits of patches of known security vulnerabilities. All relevant security-related patches and anti-virus updates must be installed within 30 days of initial release.

4.4.13.6. Patient medical data transfer and storage complies with the American College of Radiology ( ACR) and Digital Imaging and Communication of Medicine (DICOM) standards and meets and anticipates all current, known CONFIDENTIALITY requirements and regulations.

4.4.13.7. Contractor radiologists shall be available to receive phone calls from the VAMCs’ physicians (e.g. Emergency Room STAT requests after normal operating hours) in reference to the most appropriate study to perform in the given clinical situation. If an additional study is needed, the local VAMC referring provider will be contacted by the respective Contractor’s staff to communicate the need for the study.

4.4.13.8. Contractor will provide a transcribed final report, which will be uploaded to the respective VAMC's hospital information system(s) and electronically signed by the interpreting radiologists within twenty-four (24) hours.

4.4.13.9. Contractor will have ability to interpret images from commercial PACS or VA’s VISTA RAD PACS system. Contractor shall maintain its teleradiology equipment in good working order and in accordance with the specifications of the manufacturer. Equipment quality control shall be performed in accordance with manufacturer's specifications. Records of equipment quality control activities shall be made available to VA for review upon request.

4.5. PERFORMANCE STANDARDS, QUALITY ASSURANCE (QA) AND QUALITY IMPROVEMENT(QI)

4.5.1. Quality Management/Quality Assurance Surveillance: Contract personnel shall be subject to Quality Management measures, such as patient satisfaction surveys, timely completion of medical records, and Peer Reviews. Methods of Surveillance: Focused Provider Practice Evaluation (FPPE) and Ongoing Provider Practice Evaluation (OPPE). Contractor performance will be monitored by the government using the standards as outlined in this Performance Work Statement (PWS) and methods of surveillance detailed in the Quality Assurance Surveillance Plan (QASP). The QASP shall be attached to the resultant contract and shall define the methods and frequency of surveillance conducted.

4.5.2. Patient Complaints: The CO will resolve complaints concerning Contractor relations with the Government…