S02 - 36C26321R0030.pdf

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PAGE 1 OF 1. REQUISITION NO.

2. CONTRACT NO. 3. AWARD/EFFECTIVE DATE 4. ORDER NO. 5. SOLICITATION NUMBER 6. SOLICITATION ISSUE DATE

a. NAME b. TELEPHONE NO. (No Collect Calls) 8. OFFER DUE DATE/LOCAL

TIME

9. ISSUED BY CODE 10. THIS ACQUISITION IS UNRESTRICTED OR SET ASIDE: % FOR:

SMALL BUSINESS

HUBZONE SMALL

BUSINESS

SERVICE-DISABLED

VETERAN-OWNED

SMALL BUSINESS

WOMEN-OWNED SMALL BUSINESS

(WOSB) ELIGIBLE UNDER THE WOMEN-OWNED

SMALL BUSINESS PROGRAM

EDWOSB

8(A)

NAICS:

SIZE STANDARD:

11. DELIVERY FOR FOB DESTINA-

TION UNLESS BLOCK IS

MARKED

SEE SCHEDULE

12. DISCOUNT TERMS

13a. THIS CONTRACT IS A

RATED ORDER UNDER

DPAS (15 CFR 700)

13b. RATING

14. METHOD OF SOLICITATION

RFQ IFB RFP

15. DELIVER TO CODE 16. ADMINISTERED BY CODE

17a. CONTRACTOR/OFFEROR CODE FACILITY CODE 18a. PAYMENT WILL BE MADE BY CODE

TELEPHONE NO. DUNS: DUNS+4:

PHONE: FAX:

17b. CHECK IF REMITTANCE IS DIFFERENT AND PUT SUCH ADDRESS IN OFFER

18b. SUBMIT INVOICES TO ADDRESS SHOWN IN BLOCK 18a UNLESS BLOCK BELOW IS CHECKED

SEE ADDENDUM

19. 20. 21. 22. 23. 24.

ITEM NO. SCHEDULE OF SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE AMOUNT

(Use Reverse and/or Attach Additional Sheets as Necessary)

25. ACCOUNTING AND APPROPRIATION DATA 26. TOTAL AWARD AMOUNT (For Govt. Use Only)

27a. SOLICITATION INCORPORATES BY REFERENCE FAR 52.212-1, 52.212-4. FAR 52.212-3 AND 52.212-5 ARE ATTACHED. ADDENDA ARE ARE NOT ATTACHED.

27b. CONTRACT/PURCHASE ORDER INCORPORATES BY REFERENCE FAR 52.212-4. FAR 52.212-5 IS ATTACHED. ADDENDA ARE ARE NOT ATTACHED

28. CONTRACTOR IS REQUIRED TO SIGN THIS DOCUMENT AND RETURN _______________ 29. AWARD OF CONTRACT: REF. ___________________________________ OFFER

COPIES TO ISSUING OFFICE. CONTRACTOR AGREES TO FURNISH AND DATED ________________________________. YOUR OFFER ON SOLICITATION

DELIVER ALL ITEMS SET FORTH OR OTHERWISE IDENTIFIED ABOVE AND ON ANY (BLOCK 5), INCLUDING ANY ADDITIONS OR CHANGES WHICH ARE

ADDITIONAL SHEETS SUBJECT TO THE TERMS AND CONDITIONS SPECIFIED SET FORTH HEREIN IS ACCEPTED AS TO ITEMS:

30a. SIGNATURE OF OFFEROR/CONTRACTOR 31a. UNITED STATES OF AMERICA (SIGNATURE OF CONTRACTING OFFICER)

30b. NAME AND TITLE OF SIGNER (TYPE OR PRINT) 30c. DATE SIGNED 31b. NAME OF CONTRACTING OFFICER (TYPE OR PRINT) 31c. DATE SIGNED

AUTHORIZED FOR LOCAL REPRODUCTION (REV. 2/2012)

PREVIOUS EDITION IS NOT USABLE Prescribed by GSA - FAR (48 CFR) 53.212

7. FOR SOLICITATION

INFORMATION CALL:

STANDARD FORM 1449

OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24, & 30

SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL ITEMS 113

36C26321R0030 12-21-2020

Charles Morin – Contract Specialist 651-293-3035 1-20-2021 2300 Central

36C263

Department of Veterans Affairs

NETWORK 23 CONTRACTING OFFICE

Attention: Charles Morin

316 Robert Street N. STE. 506

St. Paul MN 55101

X

621111

$12 Million

N/A

N/A

X

Department of Veterans Affairs

Minneapolis VA Health Care System

1 Veterans Drive

Minneapolis MN 55417

NETWORK 23 CONTRACTING OFFICE

Attention: Charles Morin

Y

Financial Services Center

PO Box 149971

Austin TX 78714-9971

See CONTINUATION Page

On-Site Radiation Oncology Therapeutic Medical Physicists for the Minneapolis VA Healthcare System.

This requirement is for two positions. One Chief Therapeutic

Medical Physicist and one Therapeutic Medical Physicist.

See Section B.2 Schedule of Services on page 6.

See Section B.3 Performance Work Statement on page 13.

Base Period: 3-16-2021 through 3-15-2022

See CONTINUATION Page

X X

X ONE

Andrew J. Schoenecker

Contracting Officer

36C26321R0030

Table of Contents

SECTION A

A.1 SF 1449 SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL ITEMS

SECTION B - CONTINUATION OF SF 1449 BLOCKS

B.1 CONTRACT ADMINISTRATION DATA

B.2 SCHEDULE OF SERVICES

B.3 PERFORMANCE WORK STATEMENT

SECTION C - CONTRACT CLAUSES

C.1 52.212-4 CONTRACT TERMS AND CONDITIONS—COMMERCIAL ITEMS (OCT

2018)

C.2 52.204-9 PERSONAL IDENTITY VERIFICATION OF CONTRACTOR

PERSONNEL (JAN 2011)

C.3 52.204-21 BASIC SAFEGUARDING OF COVERED CONTRACTOR

INFORMATION SYSTEMS (JUN 2016)

C.4 52.216-18 ORDERING (AUG 2020)

C.5 52.216-19 ORDER LIMITATIONS (OCT 1995)

C.6 52.216-22 INDEFINITE QUANTITY (OCT 1995)

C.7 52.217-8 OPTION TO EXTEND SERVICES (NOV 1999)

C.8 52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000) ... 65

C.9 52.232-19 AVAILABILITY OF FUNDS FOR THE NEXT FISCAL YEAR (APR

1984)

C.10 SUPPLEMENTAL INSURANCE REQUIREMENTS

C.11 52.252-2 CLAUSES INCORPORATED BY REFERENCE (FEB 1998)

C.12 VAAR 852.212-70 PROVISIONS AND CLAUSES APPLICABLE TO VA

ACQUISITION OF COMMERCIAL ITEMS (APR 2020)

C.13 VAAR 852.219-74 LIMITATIONS ON SUBCONTRACTING – MONITORING AND

COMPLIANCE (JUL 2018)

C.14 VAAR 852.237-70 INDEMNIFICATION AND MEDICAL LIABILITY INSURANCE

(OCT 2019)

C.15 VAAR 852.237-75 KEY PERSONNEL (OCT 2019)

C.16 52.212-5 CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT

STATUTES OR EXECUTIVE ORDERS—COMMERCIAL ITEMS (NOV 2020)

SECTION D - CONTRACT DOCUMENTS, EXHIBITS, OR ATTACHMENTS

D.1 List of Attachments

Attachment: 1. D.1 VA Rules of Behavior

Attachment: 2. D.2 Background Investigation Procedure and Documents

Attachment: 3. D.3 QASP

Attachment: 4. D.4 Immigration and Nationality Act Requirement

Attachment: 5. D.5 VA Handbook 6500.6

Attachment: 6. D.6 Organizational Conflict of Interest

SECTION E - SOLICITATION PROVISIONS

E.1 52.212-1 INSTRUCTIONS TO OFFERORS—COMMERCIAL ITEMS (JUN 2020) 80

E.2 PROPOSAL SUBMITTAL INSTRUCTIONS

E.3 52.204-24 REPRESENTATION REGARDING CERTAIN TELECOMMUNICATIONS

AND VIDEO SURVEILLANCE SERVICES OR EQUIPMENT (AUG 2020)

E.4 52.209-7 INFORMATION REGARDING RESPONSIBILITY MATTERS (OCT 2018)

E.5 52.216-1 TYPE OF CONTRACT (APR 1984)

E.6 52.233-2 SERVICE OF PROTEST (SEP 2006)

E.7 52.252-1 SOLICITATION PROVISIONS INCORPORATED BY REFERENCE (FEB

1998)

E.8 52.212-2 EVALUATION—COMMERCIAL ITEMS (OCT 2014)

E.9 52.212-3 OFFEROR REPRESENTATIONS AND CERTIFICATIONS—

COMMERCIAL ITEMS (AUG 2020)

SECTION B - CONTINUATION OF SF 1449 BLOCKS

B.1 CONTRACT ADMINISTRATION DATA

1. Contract Administration: All contract administration matters will be handled by the following individuals:

a. CONTRACTOR:

b. GOVERNMENT: Contracting Officer

Name: Andrew Schoenecker Email: andrew.schoenecer@va.gov Phone: 651-293-3035

NETWORK 23 CONTRACTING OFFICE

Attention: Andrew Schoenecker

2. CONTRACTOR REMITTANCE ADDRESS: All payments by the Government to the contractor will be made in accordance with:

[X] 52.232-33, Payment by Electronic Funds Transfer—System For Award Management, or

[] 52.232-36, Payment by Third Party

3. INVOICES: Invoices shall be submitted in arrears:

a. Quarterly []

b. Semi-Annually []

c. Other [X] MONTHLY

4. GOVERNMENT INVOICE ADDRESS: All Invoices from the contractor shall be submitted electronically in accordance with VAAR Clause 852.232-72 Electronic Submission of Payment

Requests.

Department of Veterans Affairs Financial Services Center PO Box 149971 Austin TX 78714-9971

ACKNOWLEDGMENT OF AMENDMENTS: The offeror acknowledges receipt of amendments to the Solicitation numbered and dated as follows:

AMENDMENT NO DATE

B.2 SCHEDULE OF SERVICES

SCHEDULE OF SERVICES

The contractor shall furnish all personnel to provide services necessary to perform onsite Radiation Oncology Medical Physicist Services to eligible beneficiaries of the Department of Veterans Affairs Medical Center, Minneapolis VA Health Care System (hereinafter referred to as VAMC). This requirement will be for an estimated, 2.0 FTE Radiation Oncology Medical Physicists.

All VA Radiation Oncology Services are accredited by American College of Radiology (ACR) and follow the standards & guidelines set forth by ACR. As such any contractor providing on-site radiation oncology services must adhere to all the American College of Radiology Guidelines & Technical Standards for Radiation Oncology:

• http://www.acr.org/Quality-Safety/Standards-Guidelines/Practice-Guidelines-by- Modality/Radiation-Oncology

• http://www.acr.org/Quality-Safety/Appropriateness-Criteria/New-and-Revised

• http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by- Modality/Medical-Physics

Pricing Instructions:

The offeror is instructed to edit the number of sub-clins to correspond with the number of key personnel submitted for the line item number (LIN). Commercial health care offerors shall identify by title/position or level of experience the key personnel submitted. Also, renumber SUB-LINs if adding or removing Key Personnel.

The offeror is instructed to include all other than price and cost information supporting the proposed price as directed in Instructions to Offerors addendum to 52.212-1 and/or Section D- Contract Documents, Exhibits, or attachments.

The contractor shall propose two (2) key personnel to be credentialed and be available for scheduling to meet the requirements of the contract. All Key Personnel shall be Board Certified Therapeutic Medical Physicists.

Contract Type: The Government intends to award a Fixed Price, Indefinite-Delivery, Indefinite-Quantity contract.

In accordance with FAR 16.504(a)(1), the guaranteed minimum and maximum dollar amounts are listed in the table below. These amounts cover the base and all option periods of the contract. The maximum dollar amount listed shall not be exceeded. IDIQ established MIN and MAX dollar amounts for Base and all Option Periods:

Minimum $25,000.00

Maximum $6,750,000.00 http://www.acr.org/Quality-Safety/Standards-Guidelines/Practice-Guidelines-by-Modality/Radiation-Oncology http://www.acr.org/Quality-Safety/Standards-Guidelines/Practice-Guidelines-by-Modality/Radiation-Oncology http://www.acr.org/Quality-Safety/Appropriateness-Criteria/New-and-Revised http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics

Ordering Procedures:

A task order shall be placed only by a NCO 23 Contracting Officer. Each ordering vehicle will document the quantity, and other pertinent data to ensure the services provide the appropriate level of patient care to the maximum order allowable under the resultant contract. No additional services are authorized without prior approval through the Contracting Officer. It is anticipated that a single contract will be awarded.

Place of Performance: Services shall be provided on site in Radiation Oncology Service at the Minneapolis VA Health Care System, One Veterans Drive, Minneapolis, MN 55417.

Period of Performance: Twelve (12) Month Base Period and four (4) 12-Month Option Years (to be exercised at the discretion of the Government)

Base Year: 3/16/2021 to 3/15/2022

Option Year 1 3/16/2022 to 3/15/2023

Option Year 2 3/16/2023 to 3/15/2024

Option Year 3 3/16/2024 to 3/15/2025

Option Year 4 3/16/2025 to 3/15/2026

CONTRACT TOTAL COST (BASE YEAR AND ALL OPTIONS)

Base Year Cost:

Option Year 1 Cost:

Option Year 2 Cost:

Option Year 3 Cost:

Option Year 4 Cost:

Total Contract Cost:

Period of Performance: BASE: March 16, 2021 to March 15, 2022

LIN

No.

SUB-

Description Qty. Unit

Unit Cost Total Annual Cost

0001 None Board Certified Therapeutic Medical Physicist

Services

4,512 Hours

DO NOT PRICE DO NOT PRICE

KEY PERSONNEL

None 0001a

Board Certified Chief Therapeutic Medical

Physicist (CTMP)

NAME: ____________

TITLE/LEVEL OF EXPERIENCE: ____________

2,256 Hours $________/hr $________

None 0001b

Board Certified Therapeutic Medical Physicist

(TMP)

LIN 0001 TOTAL FOR BASE TERM

OPTION YEAR 1: March 16, 2022 to March 15, 2023

Unit Cost Total Annual Cost

1001 None

(Chief) Services

None 1001a

Physicist (CTMP)

None 1001b

Board Certified Therapeutic Medical Physicist

(TMP)

TITLE/LEVEL OF EXPERIENCE ____________

LIN 1001 TOTAL FOR OPTION YEAR ONE

OPTION YEAR 2: March 16, 2023 to March 15, 2024

Unit Cost Total Annual Cost

2001 None

None 2001a

Physicist (CTMP)

None 2001b

Board Certified Therapeutic Medical Physicist

(TMP)

LIN 2001 TOTAL FOR OPTION YEAR TWO

OPTION YEAR 3: March 16, 2024 to March 15, 2025

LIN

No.

Unit Cost Total Annual Cost

3001 None

Physicist (Chief) Services

None 3001a

Physicist (CTMP)

None 3001b

Board Certified Therapeutic Medical Physicist

(TMP)

LIN 3001 TOTAL FOR OPTION YEAR THREE

Hours

OPTION YEAR 4: March 16, 2025 to March 15, 2026

LIN

No.

Unit Cost Total Annual Cost

4001 None

None 4001a

Physicist (CTMP)

None 4001b

Board Certified Therapeutic Medical Physicist

(TMP)

LIN 4001 TOTAL FOR OPTION YEAR FOUR

TOTAL FOR BASE AND ALL OPTION PERIODS: $________________________

B.3 PERFORMANCE WORK STATEMENT

Onsite Radiation Oncology Therapeutic Medical Physicist Services

Performance Work Statement (PWS)

1. GENERAL:

1.1. Services Required: The VA Radiation Oncology Services are accredited by ACR and follow the standards & guidelines set forth by American College of Radiology (ACR). As such any contractor providing on-site radiation oncology services must adhere to all the American College of Radiology Guidelines & Technical Standards for Radiation Oncology: a contractor providing on-site radiation oncology services must provide evidence the radiation oncology practice meets or exceeds the American College of Radiology Guidelines for Radiation Oncology. Contractor will only compensated only for hours ordered and received. http://www.acr.org/Quality-

Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics

The Minneapolis VA Healthcare System (MVAHCS) has a requirement for two (2) full-time

Medical Physicists working on-site at the Minneapolis VA Medical Center, Monday – Friday providing services a minimum of 80 hours every two (2) weeks. One Physicist must be designated as a Senior Medical Physicist to serve as the Chief Physicist to oversee all medical physics and dosimetry aspects in support of radiation oncology physics program at the medical center. One other Medical Physicist will be provided to assist and support the Chief Physicist in performing the requirements of the contract.

All personnel provided must be board certified or board eligible in Medical Physics or

Therapeutic Medical Physics by the American Board of Radiology (ABR) or the American Board of Medical Physicists (ABMP). Contract providers shall have the qualifications, training and experience necessary for all medical equipment and services required for the performance of their duties and responsibilities under this contract.

http://www.acr.org/Quality-Safety/Standards-Guidelines/Practice-Guidelines-by-

Modality/Radiation-Oncology http://www.acr.org/Quality-Safety/Appropriateness-Criteria/New-and-Revised http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-

1.2. Place of Performance: All services will be provided within the Minneapolis VA Health Care

System with the primary place of performance being on-site at the Minneapolis VA Medical

Center, One Veterans Drive, Minneapolis, Minnesota 55417.

1.3. Authority: Title 38 USC 8153, Health Care Resources (HCR) sharing Authority and FAR 12 in combination with 15.

http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics http://www.acr.org/Quality-Safety/Standards-Guidelines/Practice-Guidelines-by-Modality/Radiation-Oncology http://www.acr.org/Quality-Safety/Standards-Guidelines/Practice-Guidelines-by-Modality/Radiation-Oncology http://www.acr.org/Quality-Safety/Appropriateness-Criteria/New-and-Revised http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics

1.4. Policy/Handbooks:

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=1364

1.4.3. VHA Handbook 1100.19: Credentialing and Privileging

https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=2910

1.4.4. VHA Handbook 1105.04: Fluoroscopy Safety

http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=2764

1.4.5. VHA Directive 1192.01: Seasonal Influenza Prevention Program https://www.publichealth.va.gov/docs/flu/VHA_Directive_1192_Sep2017.pdf

1.4.6. VHA Directive 1220: Facility Procedure Complexity Designation Requirements to Perform

Invasive Procedures in Any Clinical Setting https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=8365

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

1.4.8. VHA Handbook 1907.01: Health Information Management and Health Records https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=3088

1.4.9. Privacy Act of 1974 (5 U.S.C. 552a) as amended

http://www.justice.gov/oip/foia_updates/Vol_XVII_4/page2.htm

1.4.10. Primary American Association of Medical Physicists Reports http://www.aapm.org/pubs/reports/

1.4.11. US Nuclear Regulatory Commission for management and use of radioactive materials for medical use and radiation safety requirements, to include (but not limited to) 10 CFR

Parts 19, 20, 30, 33, 35, and 71 http://www.nrc.gov/reading-rm.html

1.4.12. VHA Directive 1156 Accreditation of VHA Radiation Oncology Services/Sections:

https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=7450

1.4.13. VHA Directive 1414 Stereotactic Body Radiotherapy

https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=8197 https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=2135 https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=1364 https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=2910 http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=2764 https://www.publichealth.va.gov/docs/flu/VHA_Directive_1192_Sep2017.pdf https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=8365 https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=969&FType=2 https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=3088 http://www.justice.gov/oip/foia_updates/Vol_XVII_4/page2.htm http://www.aapm.org/pubs/reports/ http://www.nrc.gov/reading-rm.html https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=7450 https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=8197

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. AAPM: American Association of Physics in Medicine

1.5.2. ACGME: Accreditation Council for Graduate Medical Education

1.5.3. ABR: American Board of Radiology

1.5.4. ACR: American College of Radiology (www.acr.org/)

1.5.5. ACO: Administrative Contracting Officer

1.5.6. AOA: American Osteopathic Association

1.5.7. BAA: Business Associate Agreement

1.5.8. CAMPEP: Commission on Accreditation of Medical Physics Educational Programs

(http://www.campep.org/default.asp)

1.5.9. CDC: Centers for Disease Control and Prevention

1.5.10. CEU: Certified Education Unit

1.5.11. CME: Continuing Medical Education

1.5.12. CMS: Centers for Medicare and Medicaid Services

1.5.13. CO: Contracting Officer

1.5.14. COR: Contracting Officer’s Representative

1.5.15. COS: Chief of Staff

1.5.16. CPARS: Contractor Performance Assessment Reporting System

1.5.17. CTMP: Chief Therapeutic Medical Physicist

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

1.5.19. FSMB: Federation of State Medical Boards

1.5.20. Full Time Equivalent (FTE): VA’s definition for full time - working the equivalent of 80 hours every two (2) weeks, 2080 hours per year. In calculating FTE, any hours not worked on national holidays shall not be included.

1.5.21. HDR: High Dose Radiation

1.5.22. HHS: Department of Health and Human Services

http://www.acr.org/ http://www.campep.org/default.asp

1.5.23. HICPAC (Healthcare Infection Control Practices Advisory Committee): A federal advisory committee made up of 14 external infection control experts who provide advice and guidance to the CDC and the Secretary of HHS regarding the practice of health care infection control, strategies for surveillance and prevention and control of health care associated infections in United States health care facilities.

1.5.24. HIPAA: Health Insurance Portability and Accountability Act

1.5.25. IGRT: Image Guided Radiation Therapy is the process of frequent two and three-dimensional imaging, during a course of radiation treatment, used to direct radiation therapy utilizing the imaging coordinates of the actual radiation treatment plan.

1.5.26. IMRT: Intensity Modulated Radiation Therapy is the process of delivering highly conformal radiotherapy to the tumor while sparing the surrounding normal tissues by varying radiation intensity across treatment portals.

1.5.27. ISO: Information Security Officer

1.5.28. LDR: Low Dose Radiation

1.5.29. MU: Monitor Unit is a measure of machine output of a linear accelerator in radiation therapy.

1.5.30. NHPP (National Health Physics Program): Provides regulatory oversight for the Nuclear

Regulatory Commission master materials license issued to VHA to include permitting for use of materials, on-site inspections, and investigations of allegations, medical events, and incidents. In addition, we provide oversight for machine sources of ionizing radiation used for radiation therapy. Finally, we provide assistance and technical information for uses of ionizing radiation for healthcare diagnosis and treatment and non-human biomedical research. (http://www.patientcare.va.gov/NHPP.asp)

1.5.31. NROP: National Radiation Oncology Program

1.5.32. NRC: National Radiation Safety Committee

1.5.33. POP: Period of Performance

1.5.34. PWS: Performance Work Statement

1.5.35. QA/QI: Quality Assurance/Quality Improvement

1.5.36. QM/PI: Quality Management/Performance Improvement

1.5.37. QASP: Quality Assurance Surveillance Plan

1.5.38. QMP: Quality Management Program

1.5.39. RPC: Radiological Physics Center

http://www.patientcare.va.gov/NHPP.asp

1.5.40. RSP: Radiation Safety Program

1.5.41. SBRT/SRT: Stereotactic Body Radiation Therapy

1.5.42. SPE: Senior Procurement Executive

1.5.43. SRS: Stereotactic Radio Surgery: a minimally invasive form of surgical intervention which makes use of a three-dimensional coordinated system to locate small targets inside the body and to perform on them some action such as ablation, biopsy, lesion, injection, stimulation, implantation, radiosurgery (SRS) etc.

1.5.44. TJC: The Joint Commission

1.5.45. TMP: Therapeutic Medical Physicist

1.5.46. TLD: Thermoluminescent Dosimeter- a device that measures radiation dose

1.5.47. VA: Department of Veterans Affairs

1.5.48. VAMC: Veterans Affairs Medical Center

1.5.49. VetPro: A federal web-based credentialing program for healthcare providers.

1.5.50. VHA: Veterans Health Administration

2. QUALIFICATIONS:

2.1. Board Certification: All contract personnel must have professional certification. 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.

2.1.1.1. The Chief Therapeutic Medical Physicist (CTMP) Chief Therapeutic Medical

Physicists must be Board Certified in Medical Physics or Therapeutic Medical Physics by the American Board of Radiology (ABR) and maintain licensure with the Board of

Licensure for Professional Medical Physicists, if applicable. Certification must be maintained throughout the contract POP. In the event that Contractor’s medical physicist(s) is/are not directly employed by the treating facility, documentation must be provided to ensure adequate certification.

2.1.1.2. The Therapeutic Medical Physicist (TMP) – reference 2.2 Qualifications

2.1.2. Credentialing and Privileging Credentialing and privileging is to be done in accordance with the provisions of VHA Handbook 1100.19 referenced above. The contractor is responsible to ensure that proposed provider(s) possesses the requisite credentials enabling the granting of privileges. No services shall be provided by any contractor’s provider(s) prior to obtaining approval by the (Minneapolis VAHCS) Professional Standards Board, Medical

Executive Board and Medical Center Director.

2.1.2.1. If a contractor’s provider(s) are 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.

2.1.2.2. Credentialing of Health Care Professionals other than physicians. In accordance with

VHA Directive 2012-030, all health care professional who claim licensure, certification, or registration, as applicable to the position (this applies to all who are appointed or utilized on a full-time, part-time, intermittent, consultant , without compensation, on-station fee-basis, on-station contract, or on-station sharing agreement basis) and who are not currently credentialed in accordance with VHA Handbook 1100.19, must be credentialed in accordance with this directive. NOTE: The credentialing requirements are found in Attachment A of this Directive.

2.2. Qualifications:

2.2.1. Board Certified Medical Physicist – MS Level: Candidate can either be master’s Level or PhD. Must be Board Certified with at least two years of continuous working experience within the last three (3) years to ensure TMP’s experience is current and relevant. Junior TMP must also have the following minimum years of experience, expertise, and knowledge on the following procedures, equipment and software:

2.2.1.1. Two (2) years of experience: Documentation detailing experience in performing

QA procedures.

2.2.1.2. One (1) year of experience: Documentation detailing Therapeutic Medical

Physics in a healthcare system that is ACR certified.

2.2.1.3. One (1) year of experience: Varian Linear Accelerators: IX and Trilogy with

Brain Lab Accessories following standards of TG-142.

2.2.1.4. One (1) year of experience: Image Guided Radiation Therapy (IGRT) including

Cone Beam CT (following standards of TG-142).

2.2.1.5. One (1) year of experience: Eclipse treatment planning system; and ARIA record & verify system, including the following treatment modalities: 2D/3D

Conformal, SRS, SRT, SBRT, and IMRT/VMAT (following standards of TG-53).

2.2.1.6. One (1) years of experience: IMRT QA: MapCheck I/II (or equivalent)

2.2.1.7. One (1) year of experience: Toshiba CT Simulator (or equivalent) and following standards of TG-66.

2.2.1.8. One (1) year of experience: Using Superficial X-ray Machine

2.2.2. Technical Proficiency: Contractor’s provider(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’s provider(s) shall have knowledge of professional care theories, principles, practices, and procedures to serve radiation oncology patient population. Contractor’s provider(s) shall demonstrate knowledge of growth and development, and pathophysiology of disease processes specific radiation oncology patient population.

Contractor shall provide verifiable evidence of all educational and training experiences including any gaps in educational history for all contractor’s provider(s) shall be responsible for abiding by the Facility's Medical Staff By-Laws, rules, and regulations

(referenced herein) that govern medical staff behavior.

2.3. Continuing/CEU Requirements: Contractor shall provide the COR copies of current CMEs as required or requested by the VAMC. Contractors registered or certified by national/medical associations shall continue to meet the minimum standards for CME to remain current. CME hours shall be reported to the credential’s office for tracking. These documents are required for initial and renewal privileging. Failure to provide shall result in loss of privileges.

2.4. 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 contractor’s physicists as required by the VA. Other training may become required. VA will communicate any changes to the training requirement to the contractor.

Training Frequency Annual Hours

Active Threat Training – TMS Course 24638

Once 1 hour

Government Ethics Once a Year 1 hour

Prevention of Workplace Harassment/No Fear Act

Once a Year 1.5 hours

VA Privacy and Information Security Awareness and Rules of Behavior – TMS course # 10176

Once a Year 1 hour

VA Core Values Training (ICARE Recommitment) – TMS course 3901227

Once a Year .5 hour

Mandatory Training for Transient Clinical Staff – TMS course # 20152

Once a Year 1.5 hours

BLS - TMS course # 324129 Every 24 months 4 hours

CPRS Once 4 hours

VISTA Imaging Once 1 hour

Additional training may be required per VHA or Medical Center directives

Unknown Unknown

2.5. Standard Personnel Testing (PPD, etc.): Contractor shall provide proof of the following tests for physicians within five (5) calendar days after contract award and prior to the first duty shift to the

COR and Contracting Officer. Tests shall be current within the past year.

2.5.1. TUBERCULOSIS TESTING: Contractor shall provide proof of a negative

Tuberculosis Skin Test (TST) or interferon-gamma release assays (IGRA) for all contractor’s provider(s) {This is applicable to all health care workers}. A negative chest radiographic report for active tuberculosis shall be provided in cases of positive TST or IGRA results. The TST or IGRA testing shall be repeated annually.

https://www.cdc.gov/tb/topic/infectioncontrol/healthcarepersonnel-faq.htm https://www.cdc.gov/tb/topic/infectioncontrol/healthcarepersonnel-faq.htm

2.5.2. MEASLES, MUMPS, & RUBELLA TESTING: Contractors shall provide proof of immunity for all contractor provider(s) {This is applicable to all health care workers}.

2.5.3. VARICELLA: Contractors shall provide proof of immunity for all contractor provider(s) {This is applicable to all health care workers}.

2.5.4. ACELLULAR PERTUSSIS: Contractors shall provide proof of 1 dose of Tdap vaccination for all contractor provider(s) {This is applicable to all health care workers}.

2.5.5. INFLUENZA: Contractors shall provide proof that all contractor provider(s) have received the annual Influenza vaccine unless it is contraindicated. If the contractor provider has a medical contraindication to the vaccine, they shall be required to wear a mask during the Influenza season. {This is applicable to all health care workers}.

2.5.6. OSHA REGULATION CONCERNING OCCUPATIONAL EXPOSURE TO

BLOODBORNE PATHOGENS: Contractor shall provide evidence of completing and passing generic self-study blood-borne pathogen training for all contractor’s provider(s) {This is applicable to all health care workers}; provide their own Hepatitis B vaccination series and Hepatitis B surface antigen test results following the Hepatitis B vaccination series; maintain an exposure determination and control plan; maintain required records; and ensure that proper follow-up evaluation is provided following an exposure incident.

2.5.7. The VAMC shall notify the contractor of any significant communicable disease exposures 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.

2.6. Conflict of Interest: The contractor and all contract provider(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 (Jan 2008) and fully outlined in response to the subject attachment in Section D of the solicitation document.

2.7. Citizenship related Requirements:

http://www.cdc.gov/hicpac/pdf/InfectControl98.pdf

2.7.1. 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;

2.7.2. 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.

2.7.3. 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.

2.7.4. 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.

2.7.5. 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.

2.8. 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.

2.8.1. 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 provider(s) is 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 http://oig.hhs.gov/exclusions/index.asp enter into contracts with excluded individuals to provide items or services to Federal program beneficiaries.

2.8.2. 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.

2.9. 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. Clinical/Professional direction of all clinical personnel covered by this contract will be provided by the VAMC COS and/or the Chief of the

Service or his/her 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.

2.10. Non-Personal Healthcare Services: The parties agree that the contractor and all contract provider(s) shall not be considered VA employees for any purpose.

2.11. Inherent Government Functions: Contractor and contract provider(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.

2.12. No Employee status: The contractor shall be responsible for protecting contract provider(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:

2.12.1. Workers’ compensation

2.12.2. Professional liability insurance

2.12.3. Health examinations

2.12.4. Income tax withholding, and

2.12.5. Social security payments.

2.13. Tort Liability: The Federal Tort Claims Act does not cover contractor or contract provider(s).

When a contractor or contract provider(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 provider(s)) action or non-action shall be the responsibility of the contractor and/or insurance carrier.

2.13.1. Medical Liability Insurance: The contractor shall furnish their own medical liability insurance and will hold certificate of insurance for general liability and malpractice insurance. Prior to award of the contract, the contractor shall furnish to the VA a certificate of insurance evidencing that all required coverage has been obtained. The contractor shall be responsible for maintaining this certificate/coverage for the duration of the contract.

Under no circumstances will contract providers be considered a MVAHCS employee nor will contractor personnel be covered by VA liability insurance.

2.14. Key Personnel: Contractor shall provide the number of qualified staff as is necessary to perform the services required under this contract, at the staffing level determined to be professionally acceptable by the Minneapolis VAHCS Chief of Staff and in accordance with American College of Radiology staffing guidelines.

2.14.1. The VA Full Time Equivalency (FTE): FTE is defined by VA as a minimum of 80 hours every two (2) weeks and does not include holidays.

2.14.2. The number of Therapeutic Medical Physicists required to be on site on a daily basis is two (2). One physicist must be a Senior Medical Physicist and will serve as the

Chief Therapeutic Medical Physicist and must be board certified; the other physicist will serve as a Therapeutic Medical Physicist and may be board certified. Hours of operation, tour of duty and services required are defined below in Sections 3 and 4.

2.15. 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 fifteen (15) calendar days after the occurrence of any of these events and provide the information required below. After ninety (90) days, the contractor shall submit the information required below to the CO at least fifteen (15) calendar days prior to making any permanent substitutions.

2.15.1. 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 fifteen (15) 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.

2.15.2. For temporary substitutions where the key person shall not be reporting to work for three (3) consecutive workdays 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 (2) weeks will require the procedure as stated above.

2.15.3. The Government reserves the right to refuse acceptance of any contractor personnel at any time after performance begins, if personal or professional conduct jeopardizes patient care or interferes with the regular and ordinary operation of the facility.

Breaches of conduct include intoxication or debilitation resulting from drug use, theft, patient abuse, dereliction or negligence in performing directed tasks, or other conduct resulting in formal complaints by patient or other staff members to designated

Government representatives. Standards for conduct shall mirror those prescribed by current federal personnel regulations. Should the VA COS or designee show documented clinical problems or continual unprofessional behavior/actions with any contract provider(s), s/he may request, without cause, immediate replacement of said contract provider(s).

2.15.4. The CO and COR shall deal with issues raised concerning contract provider(s) conduct. The final arbiter on questions of acceptability is the CO.

2.16. Contingency Plan: Continuity of care and uninterrupted operations of a Radiation Oncology

Program are essential components of this contract and will be primary factors in contractor’s assignment of staff and frequency of substitutions. The contractor shall have a contingency plan in place to be utilized if the contract provider(s) leaves contractor’s employment or is unable to continue performance in accordance with the terms and conditions of the resulting contract.

3. VA HOURS OF OPERATION/SCHEDULING:

3.1. VA Business Hours: The Minneapolis VA Medical Center is open 24 hours per day, 7 days a week, 365 days per year. Administrative offices, clinics, and the operating room general hours of operation are Monday through Friday 7:00 a.m. – 5:00 p.m. The services covered by this contract shall be furnished by the contractor as defined below in the work schedule. The contractor will not be required to furnish emergency on-call services on a national holiday or during off-duty hours.

3.2. Work Schedule:

3.2.1. Each Medical Physicist will be considered as full-time equivalent (FTE) positions.

Medical Physicists shall be present providing services on-site at the Minneapolis

VAHCS, Monday through Friday, for a minimum of 80 hours every two (2) weeks, with the exception of Federal Holidays. The normal daily tour will be established by the

Chief of Radiation Oncology and may be revised as deemed appropriate for patient care. Currently, the regularly scheduled daily tour for both physicists’ is Monday through Friday, from 8:30 a.m. to 5:00 p.m.

3.2.2. The CTMP/TMP may perform work after normal business hours as their calibrations and measurements have to be done after patient treatments.

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

Affairs:

• New Year’s Day

• Martin Luther King’s Birthday

• President’s Day

• Memorial Day

• Independence Day

• Labor Day

• Columbus Day

• Veterans Day

• Thanksgiving

• Christmas

• Any day specifically declared to be a national holiday.

3.2.4. Cancellation/Rescheduling: Unless a state of emergency has been declared, the

Contractor shall be responsible for providing services.

4. CONTRACTOR RESPONSIBILITIES:

4.1. Services Required: The contractor shall provide contractor’s provider(s) who are competent, qualified per this performance work statement and adequately trained to perform assigned duties.

4.1.1. Contractor will provide two (2) full-time Medical Physicists on-site at the Minneapolis

VAHCS, working Monday – Friday providing services a minimum of 80 hours every two (2) weeks. The contractor must provide one (1) physicist who will be designated as Senior

Medical Physicist to serve as the Chief Therapeutic Medical Physicist to oversee all medical physics and dosimetry aspects and to ensure the quality of the Radiation Oncology Physics program at the medical center. The other Medical Physicist will be provided as a

Therapeutic Medical Physicist to support the Chief Therapeutic Medical Physicist in the

Radiation Oncology Physics program and perform the requirements of this contract.

4.1.2. Medical Physicists will be primarily and professionally engaged in the design, optimization and technical evaluation of radiation treatment plans as well as ensuring precise and accurate radiation dose delivery. Medical Physicists are responsible for radiation protection of patients and staff, and their role may include clinical, research, and educational duties.

4.1.3. The Medical Physicists will work in the Radiation Oncology Service to provide expert knowledge and competence in the field of Radiation Oncology Physics. Medical Physicists will maintain a high level of knowledge of radiation safety and will be available, when necessary, for consultation with the Radiation Oncologists and will provide advice or direction to technical staff when radiation treatments are being planned or when patients are being treated. Where possible, the Medical Physicists shall be present to observe and/or help supervise complicated simulations and/or treatment set-ups.

4.1.4. Contractor’s provider(s) shall be responsible for signing in and out when in attendance.

Time sheets will be used by the COR to confirm hours/day and services provided against the contractor’s invoices.

4.2. Standards of Practice: The medical practice and patient care provided by contractor shall be evidence based best practices that meet or exceed all standards of professional practice and performance measures applicable to the Minneapolis VAHCS medical professionals, including, but not limited to, NHPP, AAPM and TJC standards and ACR current practice guidelines in radiation oncology.

Contractor’s care shall cover the range of services as would be provided in a state-of-the-art civilian medical treatment facility. Contractor shall provide evidence the contractor’s radiation oncology standard of care is of a quality that meets or exceeds currently recognized VA and

ACR national standards as established by:

4.2.1. The American College of Radiology (ACR) Guidelines for Radiation Oncology.

http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-

4.2.2. The professional standards of the TJC or equivalent accreditation http://www.jointcommission.org/standards_information/hap_requirements.aspx http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics http://www.acr.org/Quality-Safety/Standards-Guidelines/Technical-Standards-by-Modality/Medical-Physics http://www.jointcommission.org/standards_information/hap_requirements.aspx

4.2.3. The standards of the American Hospital Association

http://www.hpoe.org/resources?show=100&type=8 and;

4.2.4. The requirements contained in this PWS.

4.3. Resident Supervision and Teaching: Reserved

4.4. Medical Records:

4.4.1. Authorities: Contract physician (s) providing healthcare services to VA patients shall be considered as part of the Department Healthcare Activity and shall comply with the

U.S.C.551a (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. Based on this exception, a BAA is not required for this contract. Treatment and administrative patient records generated by this contract or provided to the contractors by the VA are covered by the VA system of records entitled ‘Patient Medical Records-VA’ (24VA19). Contractor generated VA

Patient records are the property of the VA and shall not…

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