S02_VA RFO-36C24126Q0457_AEEG Technical Services_20260602.docx
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- Solicitation number
- 36C24126Q0457
About this file
This is a Request for Offer (RFO) for Ambulatory Electroencephalogram (aEEG) Technical Services issued by the Department of Veterans Affairs Network Contracting Office 1. The solicitation number is 36C24126Q0457, with an offer due date of June 30, 2026, at 15:00 EDT. This is a 100% small business set-aside with an estimated contract value of $19 million. The contract will be firm-fixed unit price, covering a base year of 12 months beginning July 15, 2026, through July 14, 2027, with four optional one-year extension periods. Award is anticipated for Summer 2026.
The contractor shall provide qualified technical personnel, all equipment, supplies, materials, and transportation necessary to perform aEEG studies in Veterans' homes or government-approved locations across five designated service areas: Northport, New York; Baltimore, Maryland; Gainesville, Florida; Detroit, Michigan; and Saginaw, Michigan, with service coverage extending up to 200 miles from each facility. Services include study setup, electrode placement per ACNS standards, video capture when ordered, study completion, and upload to a secure cloud-based interoperable platform within 8 hours of completion. Six study categories are priced separately: 24-hour, 48-hour, and 72-hour aEEG studies with and without video. The Performance Work Statement requires contracted EEG technologists to hold minimum qualifications including high school diploma, completion of a CAAHEP-accredited EEG training program, minimum one year of EEG specialty experience, and current board registry certification (R.EEGT) and BLS certification. Contractor personnel must complete background investigations, VA security training, and sign Rules of Behavior prior to accessing veteran information or homes. Key performance metrics include 95% compliance with 8-hour study upload timeliness, 98% ACNS technical compliance, 100% response to government inquiries within one business day, 99% platform uptime, 100% training completion prior to service delivery, and contingency activation within four hours of disruption.
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Other files
| File | Type | Posted |
|---|---|---|
| AEEG RFO_36C24126Q0457_Amendment 0001.pdf | ||
| S02_VA RFO-36C24126Q0457_AEEG Technical Services_20260602.pdf | ||
| D.5_36C24126Q0457_Attach 5_AEEG Pricing Index.xlsx | XLSX spreadsheet | |
| D.4_36C24126Q0457_Attach 4_AEEG Past Performance Survey.docx | DOCX document |
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36C24126Q0457
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.
UEI:
EFT:
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. NOV 2021)
PREVIOUS EDITION IS NOT USABLE
Prescribed by GSA - FAR (48 CFR) 53.212
7. FOR SOLICITATION
INFORMATION CALL:
STANDARD FORM 1449
SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES
OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24, & 30
523-26-3-1487-0016 36C24126Q0457 06-01-2026 Alison Myers Email Only 06-30-2026 15:00
EDT
Department of Veterans Affairs Network Contracting Office 1 (NCO 1) Contracting Officer (90C) 718 Smyth Rd.
Manchester NH 03104 X X 621610 $19 Million N/A X Department of Veteran Affairs VA Medical Centers (multiple) See PWS for details
Department of Veterans Affairs Network Contracting Office 1 (NCO 1) Contracting Officer (90C) 718 Smyth Rd.
Manchester NH 03104
Department of Veterans Affairs Financial Services Center http://www.fsc.va.gov/einvoice.asp See VAAR 852.232-72 Austin TX 78714-9971 See CONTINUATION Page The Contractor shall provide Ambulatory Electroencephalogram aEEG ) Technical Services in accordance with the Performance Work Statement attached herein.
Offerors have 12 calendar days to submit questions to this Request for Offer (RFO); all questions must be received
NLT 11:59PM EST 14 JUNE 2026.
Offers are due NLT 15:00PM EST 30 JUNE 2026.
SECTION E houses Instructions to Offerors and Evaluation Criteria.
A Firm-Fixed Unit Price contract with a base year and four option years is anticipated.
Target award is Summer 2026.
See CONTINUATION Page X X X Table of Contents
SECTION A ……………………………………………………………………………………………... 1
A.1 SF 1449 SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES………………………………………………………………1
| SECTION B - CONTINUATION OF SF 1449 BLOCKS | 4 |
| B.1 CONTRACT ADMINISTRATION DATA | 4 |
| B.2 PERFORMANCE WORK STATEMENT | 5 |
| B.3 PRICE/COST SCHEDULE | 17 |
| ITEM INFORMATION | 17 |
| B.4 DELIVERY SCHEDULE | 24 |
| SECTION C - CONTRACT CLAUSES | 25 |
| C.1 ADDENDUM to FAR 52.212-4 CONTRACT TERMS AND CONDITIONS—COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES | 25 |
| C.2 52.217-8 OPTION TO EXTEND SERVICES (NOV 1999) | 25 |
| C.3 52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000) | 25 |
| C.4 52.222-90 ADDRESSING DEI DISCRIMINATION BY FEDERAL CONTRACTORS (DEVIATION APR 2026) | 25 |
| C.5 52.240-91 SECURITY PROHIBITIONS AND EXCLUSIONS (NOV 2025) (DEVIATION) | 26 |
| C.6 52.252-2 CLAUSES INCORPORATED BY REFERENCE (FEB 1998) | 36 |
| SECTION D - CONTRACT DOCUMENTS, EXHIBITS, OR ATTACHMENTS | 38 |
| D.1 ATTACHMENT 1 – AEEG QASP | 38 |
| D.2 ATTACHMENT 2 – AEEG CONTRACTOR RULES OF BEHAVIOR | 44 |
| D.3 ATTACHMENT 3 – AEEG CONTRACTOR CERTIFICATION | 49 |
| D.4 ATTACHMENT 4 – AEEG PAST PERFORMANCE SURVEY | 50 |
| D.5 ATTACHMENT 5 – AEEG PRICING INDEX | 51 |
| D.6 ATTACHMENT 6 – AEEG WAGE DETERMINATIONS | 55 |
| SECTION E - SOLICITATION PROVISIONS | 61 |
| E.1 52.212-1 INSTRUCTIONS TO OFFERORS-COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES (SEP 2023) (DEVIATION OCT 2025) | 61 |
| E.2 ADDENDUM to FAR 52.212-1 INSTRUCTIONS TO OFFERORS—COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES | 62 |
| E.3 52.212-2 EVALUATION—COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES (NOV 2021) (DEVIATION OCT 2025) | 65 |
| E.4 ADDENDUM to FAR 52.212-2 EVALUATION—COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES (NOV 2021) (DEVIATION OCT 2025) | 67 |
| E.5 52.209-7 INFORMATION REGARDING RESPONSIBILITY MATTERS (OCT 2018) | 67 |
| E.6 52.216-1 TYPE OF CONTRACT (NOV 2025) (DEVIATION) | 68 |
| E.7 52.233-2 SERVICE OF PROTEST (SEP 2006) | 68 |
| E.8 52.240-90 SECURITY PROHIBITIONS AND EXCLUSIONS REPRESENTATIONS AND CERTIFICATIONS (NOV 2025) (DEVIATION) | 69 |
| E.9 VAAR 852.233-71 ALTERNATE PROTEST PROCEDURE (OCT 2018) | 73 |
| E.10 52.252-1 SOLICITATION PROVISIONS INCORPORATED BY REFERENCE (FEB 1998) | 73 |
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 36C241 Department of Veterans Affairs Network Contracting Office 1 (NCO 1) Contracting Officer (90C) 718 Smyth Rd.
Manchester NH 03104
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] |
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.
ACKNOWLEDGMENT OF AMENDMENTS: The offeror acknowledges receipt of amendments to the Solicitation numbered and dated as follows:
| AMENDMENT NO |
| DATE |
B.2 PERFORMANCE WORK STATEMENT
Ambulatory Electroencephalogram Technical Services This is a non-personal services contract; the Government shall not exercise any supervision or control over the contract service providers performing the services herein. Such contract service providers shall be accountable solely to the Contractor, who in turn is responsible to the Government.
1.0 GENERAL
1.1. Background: These services are part of the National TeleEEG and TeleEpilepsy program (NTEEG-EP). NTEEG-EP clinical providers have observed the need for ambulatory electroencephalogram (EEG) technical services to provide patients with faster service in areas that are impacted with long wait times, geographically remote constraints and/or lack of qualified resources to provide testing where it’s needed, when it’s needed.
1.2. Scope: The Contractor shall provide qualified technical personnel, supervision, scheduling support, equipment, materials, supplies, transportation, tools, travel, documentation, secure information handling, a propriety cloud based interoperable platform to store and access EEG studies, management necessary to set up, acquire, complete, upload, and support the technical portion of ambulatory electroencephalogram (aEEG) studies to be performed in Veterans’ homes or other Government-approved locations, as ordered by authorized providers. Neurologist professional services providing a study read will be provided by the NTEEG-EP clinicians; Contractor shall not provide Neurologists for study reads. All contracted services shall be performed in accordance with this PWS, the medical order, applicable VA privacy and security requirements, applicable Federal records management requirements, and applicable clinical and technical standards.
1.3. Objectives: In accordance with the full scope identified herein, the Contractor shall fulfill the technical portion of the aEEG study orders that fall into two categories: WITH Video or WITHOUT Video. Each category houses sub-categories which stipulate the duration of the study: 24-hour, 48-hour or 72-hour study, as follows:
TASK: aEEG Study
| Task X001AA |
| 24-hour aEEG study with video |
| Task X001AB |
| 48-hour aEEG study with video |
| Task X001AC |
| 72-hour aEEG study with video |
| Task X001AD |
| 24-hour aEEG study without video |
| Task X001AE |
| 48-hour aEEG study without video |
| Task X001AF |
| 72-hour aEEG study without video |
*** Ordered studies shall primarily consist of 48-hour and 72-hour aEEG recordings, with or without synchronized video as specified in the order. Twenty-four-hour studies shall be performed only when specifically ordered by the Government.
1.4. Period of Performance: The period of performance shall be for one (1) base year of 12-months and four (4) 12-month option years, to be exercised at the discretion of the Government in accordance with the Option to Extend the Term of the Contract and Availability of Funds for the Next Fiscal Year clauses, FAR 52.217-9 and FAR 52.232-19 respectively.
2.0 Applicable Standards, Laws, and Directives
2.1. American Clinical Neurophysiology Society (ACNS) Guidelines, including minimum technical requirements for clinical EEG, standard electrode position nomenclature, standard montages for clinical EEG, and recording clinical EEG on digital media.
2.2. HIPAA Privacy, Security, and Breach Notification Rules, 45 CFR Parts 160 and 164, including Subpart D.
2.3. VAAR 852.204-71, Information and Information Systems Security.
2.4. VA Directive 6500 series and associated VA handbooks governing cybersecurity, contract security, privacy, and electronic media sanitization.
2.5. VA Directive 6300 and applicable records management policies, Federal Records Act requirements, and NARA requirements under 36 CFR Chapter XII.
2.6. VA Directive and Handbook 0710, Personnel Security and Suitability Program, as applicable.
2.7. Section 508 of the Rehabilitation Act, 29 U.S.C. § 794d, for contractor-provided electronic and information technology and related materials furnished under this requirement.
2.8. Applicable FDA requirements and manufacturer maintenance requirements for medical devices and equipment used in performance.
2.9. Applicable VA infection control standards, home-based care safety requirements, and patient privacy requirements for in-home services.
3.0 Definitions
3.1. Ambulatory Electroencephalogram (aEEG): Continuous EEG recording performed in the Veteran’s home or other approved location for the ordered duration, with or without synchronized video.
3.2. Authorized Provider: A VA credentialed clinician authorized to order an aEEG study.
3.3. Certified EEG Technologist: A technologist trained and qualified to perform ACNS-compliant setup, electrode placement, impedance checks, annotation, clipping/pruning, technical troubleshooting, and electrode removal.
3.4. Interoperable Platform: A secure, contractor-hosted web-based system used to upload and make EEG studies and related technical data available to authorized Government users.
3.5. Contingency Operations: Documented contractor measures used to sustain uninterrupted performance during weather events, staffing shortages, equipment failures, connectivity issues, or other disruptions.
3.6. Study Completion: The point at which the ordered aEEG recording period has ended, electrodes have been removed as appropriate, required technical actions have been completed, and the study is ready for upload and Government access.
4.0 Place of Performance
4.1. Critical areas. Northport, New York; Baltimore, Maryland; Gainesville, Florida; Detroit, Michigan and Saginaw, Michigan.
4.2. Additional coverage. The Contractor shall support a service radius up to 200 miles from five designated Veterans Affairs Medical Centers (VAMC) referenced below.
NORTHEAST
NORTHPORT VA MEDICAL CENTER
79 Middleville Rd.
Northport, NY 11768
BALTIMORE VAMC
10 North Greene Street Baltimore, MD 21201-1524
SOUTHEAST
MALCOLM RANDALL VA MEDICAL CENTER
1601 SW Archer Rd.
Gainesville, FL 32608
MIDWEST
JOHN D DINGELL VA MEDICAL CENTER
4646 John R St.
Detroit, MI 48201
ALEDA E LUTZ VA MEDICAL CENTER
1500 Weiss St.
Saginaw, MI 48602
4.3. Orders placed over 200 miles from the VAMCs noted above are not authorized under this contract and shall not be fulfilled.
4.4. The Contractor shall maintain consistent quality, timeliness, privacy, security, and technical performance across all permissible order locations, as noted in this section.
4.5. The contractor shall provide one single interoperable web-based platform across all permissible locations for the upload, retrieval and review of EEG studies acquired.
5.0 Contractor Performance Requirements
5.1. Personnel Screening, Training, and Conduct
5.1.1. Before performing services or obtaining access to VA information, VA information systems, or PHI, Contractor personnel shall complete all required background investigations, screening, onboarding, and training required by VA.
5.1.2. Contractor personnel shall sign the applicable VA Rules of Behavior before access is granted and shall complete required annual VA privacy and information security training, including any role-based training required by the Government.
5.1.3. The Contractor shall provide training completion evidence to the CO and/or COR within required timeframes and annually thereafter.
5.1.4. Contractor personnel shall conduct themselves professionally in Veterans’ homes and shall comply with all VA patient rights, privacy, infection control, and home-based safety requirements.
5.2. Equipment, Materials, and Supplies
5.2.1. The Contractor shall provide all equipment, supplies, consumables, video capability when ordered, transportation resources, and other materials required to perform ordered aEEG services.
5.2.2. All EEG equipment used in Veterans’ homes shall be FDA-cleared, electrically safe, maintained in accordance with manufacturer requirements, sanitized between uses, and suitable for secure clinical use.
5.2.3. The Contractor shall maintain sufficient backup equipment and supplies to support contingency events for uninterrupted performance.
5.3. Study Setup and Acquisition
5.3.1. The Contractor shall perform patient head measurement and electrode placement according to the International 10/20 and 10/10 system, as clinically appropriate, and in accordance with ACNS guidelines.
5.3.2. The Contractor shall document beginning and ending, impedance checks in the study record.
5.3.3. The Contractor shall apply required montages, technical parameters, annotations, and metadata consistent with ACNS guidelines and the medical order.
5.3.4. When video is ordered, the Contractor shall provide synchronized video capture, intermittent technical monitoring, annotation, clipping, pruning, and related technical support, as stipulated in the order.
5.3.5. The Contractor shall complete electrode removal, finalize the study, and prepare the technical record for upload and Government review.
5.4. Ordering
5.4.1. The NTEEG-EP will receive an Interfacility Consult (IFC) from the ordering provider. This consult will be contained within the electronic health record internal to the VA. NTEEG-EP will communicate with the contractor of the aEEG request.
5.4.2. Once the Contractor receives notification from NTEEG-EP, which includes all aEEG order specifications along with patient contact information, the Contractor shall coordinate directly with the Veteran, or caregiver, to schedule the aEEG.
5.4.3. The Contractor shall perform services at times mutually agreeable to the Veteran and consistent with the medical order.
5.4.4. The exact number, timing, and frequency of studies are not guaranteed. Performance shall be scheduled at times mutually agreeable to the Veteran and consistent with the medical order.
5.4.5. Actual quantities and service location will depend on Government orders, clinical need, and available funding.
5.4.6. Both the Contractor and the Government shall/will manage ordering to ensure ordering does not exceed the available funding obligation(s). The Contractor shall not perform services beyond funded amounts without prior written direction from the Contracting Officer.
5.5. Platform Interoperability, Upload and Availability
5.5.1. The Contractor shall provide, operate, and maintain a single, proprietary, cloud‑based, secure, and fully interoperable platform that is identically deployed and configured across all designated locations. This platform shall be the sole system used to provide NTEEG‑EP and all authorized Government personnel with timely access to completed studies and all associated technical data.
5.5.2. The Contractor shall not implement alternate versions, site‑specific configurations, customized builds, or any variation of the platform across locations. A single, standardized, uniform system is required to ensure interoperability, data consistency, and seamless access for NTEEG‑EP.
5.5.3. All databases utilized to track patient information, event reporting, and communications shall be fully encrypted in accordance with applicable security requirements.
5.5.4. The Contractor shall maintain platform compatibility, usability, and availability sufficient to support uninterrupted Government access and review.
5.5.5. The Contractor shall upload completed aEEG studies, including EEG data and synchronized video, when ordered, to a secure interoperable platform within the required performance timeframes.
5.5.6. The Contractor shall maintain platform uptime of at least 99%, excluding scheduled maintenance communicated in advance to the Government.
5.5.7. The Assessment and Authorization (A&A) requirements do not apply, and a Security Accreditation Package is not required.
5.6. Quality Management, Support and Reviews
5.6.1. The Contractor shall maintain a quality management process that ensures consistent technical quality, turnaround times, accessibility, and platform compatibility across all service locations.
5.6.2. The Contractor shall provide monthly quality and capacity reporting and shall participate in quarterly review meetings with the Government to review performance, service capacity, trends, deficiencies, and remediation actions.
5.6.3. The Contractor shall respond to Government clinical and operational inquiries within one business day.
5.6.4. The Contractor shall provide initial training, orientation, and updated support materials for Government-designated personnel on contractor systems and workflows.
5.7. Continuity of Operations
5.7.1. The Contractor shall maintain documented contingency plans and operational redundancy sufficient to continue services during inclement weather, staffing shortages, acts of God, equipment failures, connectivity issues, or other disruptions.
5.7.2. The Contractor shall activate contingency measures within four hours of a disruption affecting performance and shall document the actions taken, restoration time, root cause, and corrective actions.
6.0 Personnel Staffing
6.1. Personnel Staffing and Qualifications
6.1.1. The Contractor shall provide registered or otherwise properly qualified electroencephalogram (EEG) technologists; the minimum qualification standard for all EEG technologists assigned is as follows:
| Minimum Qualification Standard |
| Preferred |
| Education: |
| High School diploma or GED equivalent |
| Graduate of a CAAHEP accredited END training program or completion of an ABRET recognized program. |
| Experience: |
| Minimum one year performing in the EEG specialty; |
includes training in ACNS standards;
10/20 and 10/10 electrode placement;
impedance checks, annotation, clipping, pruning, and electrode removal.
Two years performing in EEG specialty
Certification:
Current board registry in EEG (R.EEGT) American Board of Registration of Electroencephalographic and Evoked Potential, and Basic Life Support (BLS)
6.1.2. The Contractor shall provide sufficient qualified personnel to perform all ordered services without degradation in timeliness, quality, or compliance across all locations.
6.2. Key Personnel
6.2.1. The Contractor shall designate a Program Manager or Operations Lead; this position is considered a key personnel position.
6.2.2. Substitution of key personnel shall require prior written approval by the Contracting Officer and shall meet or exceed the qualifications of the individual being replaced.
6.2.3. The Contractor shall notify the COR and Contracting Officer when key personnel departure or removal is anticipated; notification of this kind shall be made as soon as possible, and a replacement identified within 30 days.
6.3. Background Checks
6.3.1. The Contractor shall complete background checks on all aEEG technologist assigned to complete orders PRIOR to receiving any order.
6.3.2. The Contractor shall administer a background check and receive zero negative findings in order to be assigned/perform any aEEG studies either in-home or at other Government facilities.
7.0 Security, Privacy and Information Protection Requirements
7.1. The Contractor shall comply with VAAR 852.204-71 and all applicable VA privacy and information security requirements.
7.2. The Contractor shall execute and maintain a Business Associate Agreement (BAA) before creating, receiving, maintaining, or transmitting PHI on behalf of the Government.
7.3. The Contractor shall not connect contractor-owned systems to the VA network unless expressly authorized in writing by the Contracting Officer and approved in accordance with VA security requirements. Government users may access the Contractor’s secure, cloud-based system through authorized means.
7.4. The Contractor shall encrypt VA sensitive information and PHI in transit and at rest using FIPS 140-2 or FIPS 140-3 validated cryptographic modules, as applicable.
7.5. Contractor-hosted environments storing or processing VA sensitive information shall be located within the United States unless otherwise authorized in writing by the Contracting Officer.
7.6. The Contractor shall limit logical and physical access to VA information and systems to only those personnel whose access is necessary for contract performance.
7.7. The Contractor shall immediately notify the COR, designated ISO, and Privacy Officer of any known or suspected security incident, privacy incident, or unauthorized disclosure involving VA information or PHI, and shall cooperate fully with VA and any law enforcement entity having jurisdiction.
7.8. The Contractor shall maintain and make available upon request compliance evidence, including training records and, as applicable, security documentation such as system security plans, privacy threshold analyses/privacy impact assessments, vulnerability scan results, continuous monitoring artifacts, or equivalent evidence required by VA.
7.9. The Contractor shall flow down all applicable privacy and security requirements to subcontractors and third-party service providers that create, receive, maintain, or transmit VA information or PHI.
7.10. The Contractor shall notify the Contracting Officer immediately when an employee with access to VA information, VA systems, or contract data is reassigned, departs employment, or is subject to an unfriendly termination.
7.11. Liquidated Damages. If a breach involving sensitive personal information occurs, liquidated damages may apply in accordance with applicable VA policy. Where required by VA, the Contractor shall cooperate with the Government’s independent risk analysis and any associated mitigation actions.
7.11.1. Consistent with the requirements of 38 U.S.C. §5725, a contractor may require access to sensitive personal information (SPI). If so, the contractor is liable to VA for liquidated damages in the event of a data breach or privacy incident involving any SPI the Contractor processes or maintains under this contract.
7.11.2. The Contractor shall provide notice to VA of a “security incident” as set forth in the Security Incident Investigation section above. Upon such notification, VA must secure from a non-Department entity or the VA Office of Inspector General an independent risk analysis of the data breach to determine the level of risk associated with the data breach for the potential misuse of any sensitive personal information involved in the data breach. The term 'data breach' means the loss, theft, or other unauthorized access, or any access other than that incidental to the scope of employment, to data containing sensitive personal information, in electronic or printed form, that results in the potential compromise of the confidentiality or integrity of the data. Contractor shall fully cooperate with the entity performing the risk analysis. Failure to cooperate may be deemed a material breach and grounds for contract termination.
8.0 Records Management, Confidentiality and Nondisclosure
8.1. The Contractor shall comply with all applicable records management laws and policies, including the Federal Records Act, NARA requirements, VA Directive 6300, and applicable VA records schedules.
8.2. All records created in the performance of this contract and delivered to or under the legal control of the Government are Federal records and shall be managed accordingly.
8.3. The Contractor shall not destroy, remove, alter, or disclose Government records or VA information without prior written authorization from the Government.
8.4. At contract completion or termination, the Contractor shall return or otherwise manage records and data as directed by the Contracting Officer, and any authorized destruction shall comply with applicable NARA and VA media sanitization requirements.
8.5. The Contractor shall not release information related to this contract, including press releases, marketing materials, or responses to external inquiries, without prior written approval of the Contracting Officer.
8.6. The preliminary and final deliverables, supporting work papers, and other materials generated in performance of this contract are the property of the U.S. Government unless otherwise specified by law or contract.
9.0 Performance Metrics and Surveillance Basis
The Contractor shall meet the following minimum performance requirements. Failure to meet these requirements may result in corrective action, increased surveillance, price reductions or withholding where authorized, and other contractual remedies.
| Metric |
| Performance Requirement |
| Acceptable Quality Level (AQL) |
| Surveillance Method |
| Study upload timeliness |
| Completed studies shall be uploaded and available to the Government within 8 hours of study completion. |
| ≥95% |
| Monthly performance report and platform timestamps |
| Data quality / ACNS compliance |
| Studies shall meet ACNS technical standards, including correct montage, documented impedance checks, and complete annotations when required. |
| ≥98% |
| Monthly quality analysis, Clinical reviews and sample technical audits |
| Data quality / ACNS compliance |
| Studies shall meet ACNS technical standards, including correct montage, documented impedance checks, and complete annotations when required. |
| ≥98% |
| Monthly quality analysis and sample technical audits |
| Response to inquiries |
| Contractor shall respond to Government clinical/operational inquiries within 1 business day. |
| 100% |
| Communication logs |
| System uptime |
| Interoperable platform availability, excluding scheduled maintenance. |
| ≥99% |
| System availability reports |
| Training completion |
| Assigned personnel shall complete required orientation, privacy, and security training before performing services. |
| 100% |
| Training certificates and records |
| Contingency activation |
| Contractor shall activate contingency plans and document actions when a disruption affects performance. |
| Within 4 hours |
| Incident and continuity reports |
10.0 Deliverables
| Deliverable |
| Content / Format |
| Due |
| Completed aEEG study |
| EEG dataset and synchronized video (if ordered); technical notes; annotations; required metadata; uploaded via secure interoperable platform. |
| Per ordered study and performance metric |
| Monthly Quality and Capacity Report |
| Turnaround times, study volumes, ACNS compliance, exceptions, platform performance, deficiencies, and corrective actions. |
| Monthly, not later than the 5th business day |
| Incident / Continuity Report |
| Description of disruption, actions taken, restoration time, root cause, and prevention measures. |
| Per event; within 2 business days after restoration |
| Training and Support Materials |
| User guides, workflow aids, system training materials, and updates following material system changes. |
| Prior to service start; updates as needed |
| Quarterly Review Presentation |
| Attendance/participation and presentation of performance, capacity, trends, and remediation status. |
| Quarterly, as scheduled by the Government |
11.0 Inspection, Acceptance and Invoicing
11.1. The Government will inspect and accept services to determine conformance with this PWS and any applicable order requirements.
11.2. Non-conforming services shall be corrected, re-performed, or otherwise remedied by the Contractor at no additional cost to the Government, unless the Government directs another remedy authorized by the contract.
11.3. Invoices shall be submitted in accordance with contract instructions and shall reference accepted services and corresponding order numbers, if applicable.
12.0 Government Responsibilities
12.1. The Government will issue authorized orders based on clinical need and available funding.
12.2. The Government will identify authorized ordering providers and Government-designated points of contact for operational coordination.
12.3. The NTEEG-EP, through the applicable VA contracting office and program office, will administer the contract and adjudicate invoices in accordance with contract terms.
13.0 Subcontracting and Flow-Down Requirements
13.1. The Contractor shall remain fully responsible for the performance of all subcontractors.
13.2. The Contractor shall flow down the substance of all applicable technical, privacy, security, records management, training, and nondisclosure requirements contained in this PWS and incorporated contract clauses to all subcontractors performing under this requirement.
13.3. The Contractor shall obtain Contracting Officer approval before entering into a subcontract relationship that requires disclosure of Government information, documentary materials, or records generated under this contract, when such approval is required by contract or VA policy.
14.0 Section 508 and Electronic Information
Any electronic and information technology, web-based materials, user guides, training materials, or related electronic deliverables furnished under this requirement shall comply with applicable Section 508 accessibility requirements.
B.3 PRICE/COST SCHEDULE
ITEM INFORMATION
| ITEM NUMBER |
| DESCRIPTION OF SUPPLIES/SERVICES |
| QTY |
| UNIT |
| UNIT PRICE |
| AMOUNT |
1.00
LT
________NSP
AMBULATORY EEG IN HOME TECHNICAL SERVICES
Contract Period: Base POP Begin: 07-15-2026 POP End: 07-14-2027
0001AA
5.00
EA
24-HOUR aEEG Study - with VIDEO
AMBULATORY EEG IN HOME TECHNICAL SERVICES
Contract Period: Base
0001AB
25.00
48-HOUR aEEG Study - with VIDEO
Contract Period: Base
0001AC
55.00
72-HOUR aEEG Study - with VIDEO
Contract Period: Base
0001AD
24-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Base
0001AE
48-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Base
0001AF
72-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Base
AMBULATORY EEG IN HOME TECHNICAL SERVICES
Contract Period: Option 1 POP Begin: 07-15-2027 POP End: 07-14-2028
1001AA
24-HOUR aEEG Study - with VIDEO
Contract Period: Option 1
1001AB
48-HOUR aEEG Study - with VIDEO
Contract Period: Option 1
1001AC
72-HOUR aEEG Study - with VIDEO
Contract Period: Option 1
1001AD
24-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 1
1001AE
48-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 1
1001AF
72-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 1
AMBULATORY EEG IN HOME TECHNICAL SERVICES
Contract Period: Option 2 POP Begin: 07-15-2028 POP End: 07-14-2029
2001AA
24-HOUR aEEG Study - with VIDEO
Contract Period: Option 2
2001AB
48-HOUR aEEG Study - with VIDEO
Contract Period: Option 2
2001AC
72-HOUR aEEG Study - with VIDEO
Contract Period: Option 2
2001AD
24-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 2
2001AE
48-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 2
2001AF
72-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 2
AMBULATORY EEG IN HOME TECHNICAL SERVICES
Contract Period: Option 3 POP Begin: 07-15-2029 POP End: 07-14-2030
3001AA
24-HOUR aEEG Study - with VIDEO
Contract Period: Option 3
3001AB
48-HOUR aEEG Study - with VIDEO
Contract Period: Option 3
3001AC
72-HOUR aEEG Study - with VIDEO
Contract Period: Option 3
3001AD
24-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 3
3001AE
48-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 3
3001AF
72-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 3
AMBULATORY EEG IN HOME TECHNICAL SERVICES
Contract Period: Option 4
4001AA
24-HOUR aEEG Study - with VIDEO
Contract Period: Option 4
4001AB
48-HOUR aEEG Study - with VIDEO
Contract Period: Option 4
4001AC
72-HOUR aEEG Study - with VIDEO
Contract Period: Option 4
4001AD
24-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 4
4001AE
48-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 4
4001AF
72-HOUR aEEG Study - WITHOUT VIDEO
Contract Period: Option 4
GRAND TOTAL
B.4 DELIVERY SCHEDULE
| ITEM NUMBER |
| SHIPPING INFORMATION |
| QUANTITY |
| DELIVERY DATE |
| IAW PWS |
| 1.00 |
| TBD |
| IAW PWS |
| 1.00 |
| TBD |
| IAW PWS |
| 1.00 |
| TBD |
| IAW PWS |
| 1.00 |
| TBD |
| IAW PWS |
| 1.00 |
| TBD |
Page 1 of Page 1 of
SECTION C - CONTRACT CLAUSES
C.1 ADDENDUM to FAR 52.212-4 CONTRACT TERMS AND CONDITIONS—COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES Clauses that are incorporated by reference (by Citation Number, Title, and Date), have the same force and effect as if they were given in full text. Upon request, the Contracting Officer will make their full text available.
The following clauses are incorporated into 52.212-4 as an addendum to this contract:
C.2 52.217-8 OPTION TO EXTEND SERVICES (NOV 1999)
The Government may require continued performance of any services within the limits and at the rates specified in the contract. These rates may be adjusted only as a result of revisions to prevailing labor rates provided by the Secretary of Labor. The option provision may be exercised more than once, but the total extension of performance hereunder shall not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractor within 30 days.
(End of Clause)
C.3 52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000)
(a) The Government may extend the term of this contract by written notice to the Contractor within 30 days; provided that the Government gives the Contractor a preliminary written notice of its intent to extend at least 60 days before the contract expires. The preliminary notice does not commit the Government to an extension.
(b) If the Government exercises this option, the extended contract shall be considered to include this option clause.
(c) The total duration of this contract, including the exercise of any options under this clause, shall not exceed five (5) years.
(End of Clause) C.4 52.222-90 ADDRESSING DEI DISCRIMINATION BY FEDERAL CONTRACTORS (DEVIATION APR 2026) (a)Definitions. As used in this clause— Program participation means membership or participation in, or access or admission to: training, mentoring, or leadership development programs; educational opportunities; clubs; associations; or similar opportunities that are sponsored or established by the contractor or subcontractor.
Racially discriminatory diversity, equity, and inclusion (DEI) activities means disparate treatment based on race or ethnicity in the recruitment, employment (e.g., hiring, promotions), contracting (e.g., vendor agreements), program participation, or allocation or deployment of an entity's resources.
(b) In connection with the performance of work under this contract, the Contractor agrees as follows:
(1) The Contractor will not engage in any racially discriminatory DEI activities;
(2) The Contractor will furnish all information and reports, including providing access to books, records, and accounts, as required by the Contracting Officer, for purposes of ascertaining compliance with this clause;
(3) In the event of the Contractor's or a subcontractor's noncompliance with this clause, this contract may be canceled, terminated, or suspended in whole or in part, and the Contractor or subcontractor may be declared ineligible for further Government contracts;
(4) The Contractor will report any subcontractor's known or reasonably knowable conduct that may violate this clause to the Contracting Officer and take any appropriate remedial actions directed by the Contracting Officer; and
(5) The Contractor will inform the Contracting Officer if a subcontractor sues the Contractor and the suit puts at issue, in any way, the validity of this clause.
(6) The Contractor recognizes that compliance with the requirements of this clause are material to the Government's payment decisions for purposes of 31 U.S.C. 3729(b)(4).
(c) The Contractor must include the substance of this clause, including this paragraph (c), in subcontracts at any tier, including those for commercial products and commercial services, except those where the place of delivery or performance is outside the United States.
(End of Clause)
C.5 52.240-91 SECURITY PROHIBITIONS AND EXCLUSIONS (NOV 2025) (DEVIATION)
(a) Definitions. As used in this clause— American Security Drone Act-covered foreign entity means an entity included on a list that the Federal Acquisition Security Council (FASC) develops and maintains and publishes in the System for Award Management (SAM) at https://www.sam.gov (section 1822 of Pub. L. 118-31, 41 U.S.C. 3901 note prec.).
Backhaul means intermediate links between the core network, or backbone network, and the small subnetworks at the edge of the network (e.g., connecting cell phones/towers to the core telephone network). Backhaul can be wireless (e.g., microwave) or wired (e.g., fiber optic, coaxial cable, Ethernet).
Covered application means the social networking service TikTok or any successor application or service developed or provided by ByteDance Limited or an entity owned by ByteDance Limited.
Covered article, as defined in 41 U.S.C. 4713(k), means:
(1) Information technology, as defined in 40 U.S.C. 11101, including cloud computing services of all types;
(2) Telecommunications equipment or telecommunications service, as those terms are defined in section 3 of the Communications Act of 1934 (47 U.S.C. 153);
(3) The processing of information on a Federal or non-Federal information system, subject to the requirements of the Controlled Unclassified Information program (see 32 CFR part 2002); or
(4) Hardware, systems, devices, software, or services that include embedded or incidental information technology.
Covered foreign country means The People’s Republic of China.
Covered telecommunications equipment or services means—
(1) Telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities);
(2) For the purpose of public safety, security of Government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities);
(3) Telecommunications or video surveillance services provided by such entities or using such equipment; or
(4) Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the government of a covered foreign country.
Critical technology means—
(1) Defense articles or defense services included on the United States Munitions List set forth in the International Traffic in Arms Regulations under subchapter M of chapter I of title 22, Code of Federal Regulations;
(2) Items included on the Commerce Control List set forth in Supplement No. 1 to part 774 of the Export Administration Regulations under subchapter C of chapter VII of title 15, Code of Federal Regulations, and controlled—
(i) Pursuant to multilateral regimes, including for reasons relating to national security, chemical and biological weapons proliferation, nuclear nonproliferation, or missile technology; or
(ii) For reasons relating to regional stability or surreptitious listening;
(3) Specially designed and prepared nuclear equipment, parts and components, materials, software, and technology covered by part 810 of title 10, Code of Federal Regulations (relating to assistance to foreign atomic energy activities);
(4) Nuclear facilities, equipment, and material covered by part 110 of title 10, Code of Federal Regulations (relating to export and import of nuclear equipment and material);
(5) Select agents and toxins covered by part 331 of title 7, Code of Federal Regulations, part 121 of title 9 of such Code, or part 73 of title 42 of such Code; or
(6) Emerging and foundational technologies controlled pursuant to section 1758 of the Export Control Reform Act of 2018 (50 U.S.C. 4817).
FASC-prohibited unmanned aircraft system means an unmanned aircraft system manufactured or assembled by an American Security Drone Act—covered foreign entity.
FASCSA order means any of the following orders issued under the Federal Acquisition Supply Chain Security Act (FASCSA) requiring removing covered articles from executive agency information systems or excluding one or more named sources or named covered articles from executive agency procurement actions, as described in 41 CFR 201-1.303(d) and (e):
(1) The Secretary of Homeland Security may issue FASCSA orders that apply to civilian agencies, to the extent not covered by paragraph (2) or (3) of this definition. This type of FASCSA order may be referred to as a Department of Homeland Security (DHS) FASCSA order.
(2) The Secretary of Defense may issue FASCSA orders that apply to the Department of Defense (DoD) and national security systems other than sensitive compartmented information systems. This type of FASCSA order may be referred to as a DoD FASCSA order.
(3) The Director of National Intelligence (DNI) may issue FASCSA orders that apply to the intelligence community and sensitive compartmented information systems, to the extent not covered by paragraph (2) of this definition. This type of FASCSA order may be referred to as a DNI FASCSA order.
Information technology, as defined in 40 U.S.C. 11101(6)—
(1) Means any equipment or interconnected system or subsystem of equipment, used in the automatic acquisition, storage, analysis, evaluation, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information by the executive agency, if the equipment is used by the executive agency directly or is used by a contractor under a contract with the executive agency that requires the use—
(i) Of that equipment; or
(ii) Of that equipment to a significant extent in the performance of a service or the furnishing of a product;
(2) Includes computers, ancillary equipment (including imaging peripherals, input, output, and storage devices necessary for security and surveillance), peripheral equipment designed to be controlled by the central processing unit of a computer, software, firmware and similar procedures, services (including support services), and related resources; but
(3) Does not include any equipment acquired by a Federal contractor incidental to a Federal contract.
Intelligence community, as defined by 50 U.S.C. 3003(4), means the following—
(1) The Office of the Director of National Intelligence;
(2) The Central Intelligence Agency;
(3) The National Security Agency;
(4) The Defense Intelligence Agency;
(5) The National Geospatial-Intelligence Agency;
(6) The National Reconnaissance Office;
(7) Other offices within the Department of Defense for the collection of specialized national intelligence through reconnaissance programs;
(8) The intelligence elements of the Army, the Navy, the Air Force, the Marine Corps, the Coast Guard, the Federal Bureau of Investigation, the Drug Enforcement Administration, and the Department of Energy;
(9) The Bureau of Intelligence and Research of the Department of State;
(10) The Office of Intelligence and Analysis of the Department of the Treasury;
(11) The Office of Intelligence and Analysis of the Department of Homeland Security; or
(12) Such other elements of any department or agency as may be designated by the President, or designated jointly by the Director of National Intelligence and the head of the department or agency concerned, as an element of the intelligence community.
Interconnection arrangement means arrangements governing the physical connection of two or more networks to allow the use of another’s network to hand off traffic where it is ultimately delivered (e.g., connecting a customer of telephone provider A to a customer of telephone company B) or sharing data and other information resources.
Kaspersky Lab-covered article means any hardware, software, or service that—
(1) Is developed or provided by a Kaspersky Lab-covered entity;
(2) Includes any hardware, software, or service developed or provided in whole or in part by a Kaspersky Lab-covered entity; or
(3) Contains components using any hardware or software developed in whole or in part by a Kaspersky Lab-covered entity.
Kaspersky Lab-covered entity means—
(1) Kaspersky Lab;
(2) Any successor entity to Kaspersky Lab, including any change in name, e.g., “Kaspersky”;
(3) Any entity that controls, is controlled by, or is under common control with Kaspersky Lab; or
(4) Any entity of which Kaspersky Lab has a majority ownership.
National security system, as defined in 44 U.S.C. 3552, means any information system (including any telecommunications system) used or operated by an agency or by a contractor of an agency, or other organization on behalf of an agency—
(1) The function, operation, or use of which involves intelligence activities; involves cryptologic activities related to national security; involves command and control of military forces; involves equipment that is an integral part of a weapon or weapons system; or is critical to the direct fulfillment of military or intelligence missions, but does not include a system that is to be used for routine administrative and business applications (including payroll, finance, logistics, and personnel management applications); or
(2) Is protected at all times by procedures established for information that have been specifically authorized under criteria established by an Executive order or an Act of Congress to be kept classified in the interest of national defense or foreign policy.
Roaming means cellular communications services (e.g., voice, video, data) received from a visited network when unable to connect to the facilities of the home network either because signal coverage is too weak or because traffic is too high.
Sensitive compartmented information means classified information concerning or derived from intelligence sources, methods, or analytical processes, which is required to be handled within formal access control systems established by the Director of National Intelligence.
Sensitive compartmented information system means a national security system authorized to process or store sensitive compartmented information.
Source means a non-Federal supplier, or potential supplier, of products or services, at any tier.
Subsidiary means an entity in which more than 50 percent of the entity is owned directly by a parent corporation or through another subsidiary of a parent corporation.
Substantial or essential component means any component necessary for the proper function or performance of a piece of equipment, system, or service.
Unmanned aircraft means an aircraft that is operated without the possibility of direct human intervention from within or on the aircraft (49 U.S.C. 44801(11)).
Unmanned aircraft system means an unmanned aircraft and associated elements (including communication links and the components that control the unmanned aircraft) that are required for the operator to operate safely and efficiently in the national airspace system (49 U.S.C. 44801(12)).
(b) Prohibitions on providing or using specific products or services in performance of contract. Unless a waiver or exception applies, the Contractor is prohibited from providing any products or services to the Government or using in the performance of the contract any of the following:
(1) A covered application on any information technology owned or managed by the Government, or on any information technology used or provided by the Contractor under this contract, including equipment provided by the Contractor’s employees (section 102 of Division R of the Consolidated Appropriations Act, 2023 (Pub. L. 117-328));
(2) A Kaspersky Lab-covered article (Section 1634 of Division A of the National Defense Authorization Act for Fiscal Year 2018 (Pub. L. 115-91));
(3) Covered telecommunications equipment or services used as a substantial or essential component of any system, or as critical technology as part of any system (paragraphs (a)(1)(A) of section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Pub. L. 115-232)). This does not prohibit contractors from providing—
(i) A service that connects to the…
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