SOW BD Pyxis System 2-26-26.pdf

STATEMENT OF WORK

TITLE: BD PYXIS ™ SERVICES AND EQUIPMENT

2/26/2026

The Contractor shall provide all labor, personnel, equipment, tools, materials, supervision, and other items necessary to perform the onsite and remote services and support as outlined in this statement of work.

The Contractor shall provide onsite and remote service and support of both the hardware and software associated with all components of BD Pyxis, BD Logistics and BD IV Prep systems located at Providence Veterans Affairs Medical Center (PVAMC), Rhode Island and outpatient clinics located in Rhode Island and Massachusetts. The following systems fall under this scope:

o BD ES Platform o BD IV Prep o BD Logistics o Interfaces between the three BD Systems

1. EQUIPMENT:

The contractor shall provide all tools and equipment necessary to properly and safely perform the services set forth within this statement of work. This shall include, but is not limited, to all Personal Protective Equipment (PPE) which may be required for the work to be completed in a safe manner.

All media is to be retained by PVAMC upon replacement or removal.

• ES Platform System o ES Medstations o Auxiliary Columns o ES Anesthesia Systems o ES Refrigerators o Medication Label Modules o Smart Remote Managers o Software Licensing o Enterprise User Management o CII Safe o ES Servers

• IV Prep System (Cato) o Cato Software Subscription o MAPortal 3 for less than 150 beds o IV Prep Gravimetric Pack o Barcode Printers o IV Prep Servers

• Logistics System o Logistics ES Software Licensing o Carousel and accessories o Handheld Scanner o Logistics Servers

• Interfaces between the three Pyxis Systems o Pyxis Check Software License o HealthSite Viewer

2. AREAS TO BE SERVICED:

Providence VA Medical Center 830 Chalkstone Ave Providence, RI 02908

Eagle Square VA Clinic 589 Atwells Ave Providence, RI 02909

Middletown VA Clinic One Corporate Pl Middletown, RI 02842-6406

New Bedford VA Clinic 175 Elm St New Bedford, MA 02740

Hyannis VA Clinic 233 Stevens St Hyannis, MA 02601

3. TASK FREQUENCY AND INSTRUCTIONS:

This contract covers the period of April 1, 2026, to March 31, 2027, and includes service coverage: 24 hours a day, 7 days a week, 365 days a year through the technical support center. During the Support Term, CareFusion and Customer, as applicable, will provide Support necessary to keep the BD Pyxis, BD Logistics and BD IV Preps Products and the contractor’s side of any applicable interfaces performing in accordance with the material specifications of the applicable User Guide for BD Pyxis, BD Logistics and BD IV Prep systems. For Pyxis equipment, the VA can call the Technical Support Center (TSC) 24/7/365 and they will try to resolve the issue remotely. IV Prep Technical Support is available from M-F 8am-5pm PST. For HealthSite, the Technical Support Center is available from 6am-5pm PST Monday – Friday for remote assistance. The VA can call TSC for updates on the issue or visit the customer portal to view any status updates. If the call cannot be resolved remotely, then the technical support center will dispatch a Field Service Engineer.

The Contractor shall provide the VA with updated electronic equipment user manuals prior to the contract start date and notify the VA of any maintenance requirement frequency changes. In addition to the service manuals the Contractor shall provide a list to the VA with all maintenance due dates by January 1 of calendar year in which the maintenance is due. BD will use reasonably best efforts to provide updates quote(s) before contract expiration that will include equipment eligibility period of performance dates.

All equipment maintenance will be performed according to the manufacturer equipment service manual schedule. All field service and preventive maintenance reports will be provided to the VA at the conclusion of the service call via email to the VA and available through the online BD service portal or by calling the Technical Support Center. The VA will reach out to the Contractor the month prior to schedule all equipment maintenance. The Vendor must provide a list of all equipment that is being serviced by a 3rd party vendor.

The Clinical Engineering department will provide basic support to the end users in practices, basic hardware, and networking support. The contractor will provide on-site Field Support for diagnostic and repair services. If during the initial remote troubleshooting it is determined that the issue cannot be resolved remotely, on-site support will arrive within the guaranteed response time of 24 hours. Contractor will provide software updates and upgrades, but does not include hardware, 3rd Party Software or any other software that CareFusion generally licenses separately.

If the Contractor is required to be onsite, they must be escorted by VA personnel. Under no circumstances shall a Contractor be working with a medication dispensing system without VA personnel observation. The Contractor must schedule all maintenance and service activities in advance with the VA.

Patching and Update Requirements:

• The Contractor will provide a list of all approved patches and updates. The contractor will work with the VA to approve/disapprove security vulnerabilities submitted by the VA to TSC.

• Updates and patches are typically released on a monthly basis. The device will notify the customer when an update is ready to be installed. Devices can be configured to automatically reboot on a specific cadence, which will install the updates. If a device is not configured to automatically reboot, the customer can manage the timing on when they will do the manual reboots of the devices to install the updates. Contractors provides patch information online that the customer can view each month.

• All patching of servers must be initiated by 7am EST to reduce impact to patient care. After patching is completed, the Contractor must notify the VA to ensure equipment is properly working. Patching local Medstations will be pushed by the Contractor’s remote services, and the VA will be responsible for ensuring Medstations are rebooted.

Break/fix for BD equipment not covered under contract: BD will respond to issues for non-contract equipment that connects to BD systems. BD will provide a quote for service and parts and will charge the then current time and materials rate. BD will provide a service report VA at the conclusion of the service call via email to the VA and be available through the online BD service portal or by calling the Technical Support Center.

Customer Training: Contractor will provide training one time to a mutually agreed-upon number of designated customer personnel to perform maintenance activities that are not covered by the Contractor under this service agreement.

Guaranteed Response Time: BD/CareFusion guarantees that a field service representative will arrive at the location of the BD Pyxis, BD Logistics or BD IV Prep Product within the timeframe set forth in the table below, calculated from the time of dispatch from TSC (“Guaranteed Response Time”). If CareFusion is solely responsible for failing to meet the Guaranteed Response Time, then as Customer’s sole and exclusive remedy, CareFusion will apply the credit set forth below, provided that Customer gives written notice to CareFusion within the time period specified below. This subsection does not apply to Support cases for Integral Software only.

4. SPECIAL WORK REQUIREMENTS:

None.

5. PROPERTY DAMAGE:

The contractor shall take all necessary precautions to prevent damage to any government property.

The contractor shall report any damage immediately and shall be assessed current. Replacement costs for property damaged by the contractor will be the responsibility of the contractor unless corrective action is taken. Any damaged material (i.e., trees, shrubs, lawn/turf, curbs, gutters, sidewalks, etc.) will be replaced in a timely manner or corrected by the contractor with like materials, at no extra cost to the government, upon approval of the Contracting Officer.

6. ATTACHMENTS:

None.

7. IDENTIFICATION, PARKING, SMOKING, CELLULAR PHONE USE AND VA REGULATIONS:

The contractor's employees shall always wear visible identification while on the premises of the VA property. It is the responsibility of the contractor to park in the appropriate designated parking areas.

Information on parking is available from the VA Police-Security Service. The VA will not invalidate or make reimbursement for parking violations of the contractor under any conditions. Smoking is prohibited inside any buildings at the VA. Cellular phones and two-way radios are not to be used within six feet of any medical equipment. Possession of weapons is prohibited. Enclosed containers, including tool kits, shall be subject to search. Violations of VA regulations may result in a citation answerable in the United States (Federal) District Court, not a local district state, or municipal court.

8. COMPLIANCE WITH OSHA BLOODBORNE PATHOGENS STANDARD:

The contractor shall comply with the Federal OSHA Bloodborne Pathogens Standard. The contractor shall:

A. Have methods by which all employees are educated as to risks associated with bloodborne pathogens.

B. Have policies and procedures which reduce the risk of employee exposure to bloodborne pathogens.

C. Have mechanisms for employee counseling and treatment following exposure to bloodborne pathogens.

D. Provide appropriate personal protective equipment/clothing such as gloves, gowns, masks, protective eyewear, mouthpieces for the employee during performance of the contract.

9. RECORDS MANAGEMENT LANGUAGE:

1. Citations to pertinent laws, codes, and regulations such as 44 U.S.C chapters 21, 29, 31 and 33; Freedom of Information Act (5 U.S.C. 552); Privacy Act (5 U.S.C. 552a); 36 CFR Part 1222 and Part 1228.

2. Contractor shall treat all deliverables under the contract as the property of the U.S.

Government for which the Government Agency shall have unlimited rights to use, dispose of, or disclose such data contained therein as it determines to be in the public interest.

3. Contractor shall not create or maintain any records that are not specifically tied to or authorized by the contract using Government IT equipment and/or Government records.

4. Contractor shall not retain, use, sell, or disseminate copies of any deliverable that contains information covered by the Privacy Act of 1974 or that which is generally protected by the Freedom of Information Act.

5. Contractor shall not create or maintain any records containing any Government Agency records that are not specifically tied to or authorized by the contract.

6. The Government Agency owns the rights to all data/records produced as part of this contract.

7. The Government Agency owns the rights to all electronic information (electronic data, electronic information systems, electronic databases, etc.) and all supporting documentation created as part of this contract. Contractor must deliver sufficient technical documentation with all data deliverables to permit the agency to use the data.

8. Contractor agrees to comply with Federal and Agency records management policies, including those policies associated with the safeguarding of records covered by the Privacy Act of 1974. These policies include the preservation of all records created or received regardless of format [paper, electronic, etc.] or mode of transmission [e-mail, fax, etc.] or state of completion [draft, final, etc.].

9. No disposition of documents will be allowed without the prior written consent of the Contracting Officer. The Agency and its contractors are responsible for preventing the alienation or unauthorized destruction of records, including all forms of mutilation. Willful and unlawful destruction, damage or alienation of Federal records is subject to the fines and penalties imposed by 18 U.S.C. 2701. Records may not be removed from the legal custody of the Agency or destroyed without regard to the provisions of the agency records schedules.

10. Contractor is required to obtain the Contracting Officer's approval prior to engaging in any contractual relationship (sub-contractor) in support of this contract requiring the disclosure of information, documentary material and/or records generated under, or relating to, this contract. The Contractor (and any sub-contractor) is required to abide by Government and Agency guidance for protecting sensitive and proprietary information.

10. VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE FOR

INCLUSION INTO CONTRACTS:

1. GENERAL

Contractors, contractor personnel, subcontractors, and subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security.

2. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS

a. Contractor/subcontractor shall request logical (technical) or physical access to VA information and VA information systems for their employees, subcontractors, and affiliates only to the extent necessary to perform the services specified in the contract, agreement, or task order.

b. All contractors, subcontractors, and third-party services and associates working with VA information are subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations Security and Preparedness is responsible for these policies and procedures.

BD Exception: BD will work to complete all vetting requirements through the sponsorship and facilitation of Providence VA Medical Center who will provide all necessary guidance, documentation, and contact support. Providence VA Medical Center will also review with Contracting Officer or Contracting Officer Representative if background investigations are necessary to support this contract.

c. Custom software development and outsourced operations must be located in the U.S. to the maximum extent practical. If such services are proposed to be performed abroad and are not disallowed by other VA policy or mandates, the contractor/subcontractor must state where all non-U.S. services are provided and detail a security plan, deemed to be acceptable by VA, specifically to address mitigation of the resulting problems of communication, control, data protection, and so forth. Location within the U.S. may be an evaluation factor.

BD Exception: BD Pyxis software is manufactured in the United States, Mexico, India, Ukraine, Austria, and Israel.

d. The contractor or subcontractor must notify the Contracting Officer immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the contractor or subcontractor’s employ. The Contracting Officer must also be notified immediately by the contractor or subcontractor prior to an unfriendly termination.

BD Exception: Due to the large size of the organization of those who provide support, Contractor does not have a process in place to notify the VA if an employee leaves.

Contractor will make a reasonable effort to notify the VA when an employee leaves or when an employee is subject to an unfriendly termination.

3. VA INFORMATION CUSTODIAL LANGUAGE

a. Information made available to the contractor or subcontractor by VA for the performance or administration of this contract or information developed by the contractor/subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of the VA. This clause expressly limits the contractor/subcontractor's rights to use data as described in Rights in Data- General, FAR 52.227-14(d) (1).

b. VA information should not be co-mingled, if possible, with any other data on the contractors/subcontractor’s information systems or media storage systems in order to ensure VA requirements related to data protection and media sanitization can be met. If co-mingling must be allowed to meet the requirements of the business need, the contractor must ensure that VA’s information is returned to the VA or destroyed in accordance with VA’s sanitization requirements. VA reserves the right to conduct on-site inspections of contractor and subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures are following VA directive requirements.

c. Prior to termination or completion of this contract, contractor/subcontractor must not destroy information received from VA, or gathered/created by the contractor in the course of performing this contract without prior written approval by the VA. Any data destruction done on behalf of VA by a contractor/subcontractor must be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management and its Handbook 6300.1 Records Management Procedures, applicable VA Records Control Schedules, and VA Handbook 6500.1, Electronic Media Sanitization. Self-certification by the contractor that the data destruction requirements above have been met must be sent to the VA Contracting Officer within 30 days of termination of the contract.

d. The contractor/subcontractor must receive, gather, store, back up, maintain, use, disclose and dispose of VA information only in compliance with the terms of the contract and applicable Federal and VA information confidentiality and security laws, regulations, and policies. If Federal or VA information confidentiality and security laws, regulations and policies become applicable to the VA information or information systems after execution of the contract, or if NIST issues or updates applicable FIPS or Special Publications (SP) after execution of this contract, the parties agree to negotiate in good faith to implement the information confidentiality and security laws, regulations, and policies in this contract.

e. The contractor/subcontractor shall not make copies of VA information except as authorized and necessary to perform the terms of the agreement or to preserve electronic information stored on contractor/subcontractor electronic storage media for restoration in case any electronic equipment or data used by the contractor/subcontractor needs to be restored to an operating state. If copies are made for restoration purposes, after the restoration is complete, the copies must be appropriately destroyed.

f. If VA determines that the contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be sufficient grounds for VA to withhold payment to the contractor or third party or terminate the contract for default or terminate for cause under Federal Acquisition Regulation (FAR) part 12.

g. If a VHA contract is terminated for cause, the associated BAA must also be terminated and appropriate actions taken in accordance with VHA Handbook 1600.01, Business Associate Agreements. Absent an agreement to use or disclose protected health information, there is no business associate relationship.

h. The contractor/subcontractor must store, transport, or transmit VA sensitive information in an encrypted form, using VA-approved encryption tools that are, at a minimum, FIPS 140-2 validated.

i. The contractor/subcontractor’s firewall and Web services security controls, if applicable, shall meet or exceed VA’s minimum requirements. VA Configuration Guidelines are available upon request.

j. Except for uses and disclosures of VA information authorized by this contract for performance of the contract, the contractor/subcontractor may use and disclose VA information only in two other situations: (i) in response to a qualifying order of a court of competent jurisdiction, or (ii) with VA’s prior written approval. The contractor/subcontractor must refer all requests for demands for production of, or inquiries about, VA information and information systems to the VA contracting officer for response.

k. Notwithstanding the provision above, the contractor/subcontractor shall not release VA records protected by Title 38 U.S.C. 5705, confidentiality of medical quality assurance records and/or Title 38 U.S.C. 7332, confidentiality of certain health records pertaining to drug addiction, sickle cell anemia, alcoholism or alcohol abuse, or infection with human immunodeficiency virus. If the contractor/subcontractor is in receipt of a court order or other requests for the above-mentioned information, that contractor/subcontractor shall immediately refer such court orders or other requests to the VA contracting officer for response.

l. For service that involves storage, generating, transmitting, or exchanging of VA sensitive information but does not require C&A or an MOU-ISA for system interconnection, the contractor/subcontractor must complete a Contractor Security Control Assessment (CSCA) on a yearly basis and provide it to the COTR.

4. SECURITY INCIDENT INVESTIGATION

a. The term “security incident” means an event that has, or could have, resulted in unauthorized access to, loss or damage to VA assets, or sensitive information, or an action that breaches VA security procedures. The contractor/subcontractor shall immediately notify the COTR and simultaneously, the designated ISO and Privacy Officer for the contract of any known or suspected security/privacy incidents, or any unauthorized disclosure of sensitive information, including that contained in system(s) to which the contractor/subcontractor has access.

b. To the extent known by the contractor/subcontractor, the contractor/subcontractor’s notice to VA shall identify the information involved, the circumstances surrounding the incident (including to whom, how, when, and where the VA information or assets were placed at risk or compromised), and any other information that the contractor/subcontractor considers relevant.

c. With respect to unsecured protected health information, the business associate is deemed to have discovered a data breach when the business associate knew or should have known of a breach of such information. Upon discovery, the business associate must notify the covered entity of the breach. Notifications need to be made in accordance with the executed business associate agreement.

d. In instances of theft or break-in or other criminal activity, the contractor/subcontractor must concurrently report the incident to the appropriate law enforcement entity (or entities) of jurisdiction, including the VA OIG and Security and Law Enforcement. The contractor, its employees, and its subcontractors and their employees shall cooperate with VA and any law enforcement authority responsible for the investigation and prosecution of any possible criminal violations associated with any incident. The contractor/subcontractor shall cooperate with VA in any civil litigation to recover VA information, obtain monetary or other compensation from a third party for damages arising from any incident, or obtain injunctive relief against any third party arising from, or related to, the incident.

BD Exception: Per the BAA, BD will provide a written report of any possible security incident within 10 business days.

5. LIQUIDATED DAMAGES FOR DATA BREACH

a. Consistent with the requirements of 38 U.S.C. §5725, a contract may require access to sensitive personal information. 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/subcontractor processes or maintains under this contract.

b. The contractor/subcontractor 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.

c. Each risk analysis shall address all relevant information concerning the data breach, including the following:

(1) Nature of the event (loss, theft, unauthorized access).

(2) Description of the event, including:

(a) Date of occurrence.

(b) Data elements involved, including any PII, such as full name, social security number, date of birth, home address, account number, disability code.

(3) Number of individuals affected or potentially affected.

(4) Names of individuals or groups affected or potentially affected.

(5) Ease of logical data access to the lost, stolen or improperly accessed data in light of the degree of protection for the data, e.g., unencrypted, plain text.

(6) Amount of time the data has been out of VA control.

(7) The likelihood that sensitive personal information will or has been compromised

(Made accessible to and useable by unauthorized persons).

(8) Known misuses of data containing sensitive personal information, if any.

(9) Assessment of the potential harm to the affected individuals.

(10) Data breach analysis as outlined in 6500.2 Handbook, Management of Security and Privacy Incidents, as appropriate; and

(11) Whether credit protection services may assist record subjects in avoiding or mitigating the results of identity theft based on the sensitive personal information that may have been compromised.

d. Based on the determinations of the independent risk analysis, the contractor shall be responsible for paying to the VA liquidated damages in the amount of $______ per affected individual to cover the cost of providing credit protection services to affected individuals consisting of the following:

(1) Notification.

(2) One year of credit monitoring services consisting of automatic daily monitoring of at least 3 relevant credit bureau reports.

(3) Data breach analysis.

(4) Fraud resolution services, including writing dispute letters, initiating fraud alerts and credit freezes, to assist affected individuals to bring matters to resolution.

(5) One year of identity theft insurance with $20,000.00 coverage at $0 deductible; and

(6) Necessary legal expenses may incur to repair falsified or damaged credit records, histories, or financial affairs.

6. SECURITY CONTROLS COMPLIANCE TESTING

Contractor requires all associates to complete annual Training that is comparable to the below.

BD can complete security controls assessments if required.

On a periodic basis, VA, including the Office of Inspector General, reserves the right to evaluate any or all of the security controls and privacy practices implemented by the contractor under the clauses contained within the contract. With 10 working-days’ notice, at the request of the government, the contractor must fully cooperate and assist in a government-sponsored security controls assessment at each location wherein VA information is processed or stored, or information systems are developed, operated, maintained, or used on behalf of VA, including those initiated by the Office of Inspector General. The government may conduct a security control assessment on shorter notice (to include unannounced assessments) as determined by VA in the event of a security incident or at any other time.

a. All contractor employees and subcontractor employees requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and its systems:

(1) Sign and acknowledge (either manually or electronically) understanding of and responsibilities for compliance with the Contractor Rules of Behavior, Appendix E relating to access to VA information and information systems.

(2) Successfully complete the VA Cyber Security Awareness and Rules of Behavior training and annually complete required security training.

(3) Successfully complete the appropriate VA privacy training and annually complete required privacy training; and

(4) Successfully complete any additional cyber security or privacy training, as required for VA personnel with equivalent information system access [to be defined by the VA program official and provided to the contracting officer for inclusion in the solicitation document – e.g., any role-based information security training required in accordance with NIST Special Publication 800-16, Information Technology Security Training Requirements.]

b. The contractor shall provide the contracting officer and/or the COTR a copy of the training certificates and certification of signing the Contractor Rules of Behavior for each applicable employee within 1 week of the initiation of the contract and annually thereafter, as required.

c. Failure to complete the mandatory annual training and sign the Rules of Behavior annually, within the timeframe required, is grounds for suspension or termination of all physical or electronic access privileges and removal from work on the contract until such time as the training and documents are complete.

7. TRAINING

a. All contractor employees and subcontractor employees requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and its systems:

(1) Sign and acknowledge (either manually or electronically) understanding of and responsibilities for compliance with the Contractor Rules of Behavior, Appendix E relating to access to VA information and information systems.

(2) Successfully complete the VA Cyber Security Awareness and Rules of Behavior training and annually complete required security training.

(3) Successfully complete the appropriate VA privacy training and annually complete required privacy training; and

(4) Successfully complete any additional cyber security or privacy training, as required for VA personnel with equivalent information system access [to be defined by the VA program official and provided to the contracting officer for inclusion in the solicitation document – e.g., any role-based information security training required in accordance with NIST Special Publication 800-16, Information Technology Security Training Requirements.]

BD Exception: BD will adhere to VA training requirements through the facilitation of VA COR or other identified VA point of contact from the Providence VA Medical Center to coordinate training information dissemination and collection. Delays in BD receiving Providence VA Medical Center point(s) of contact or information will not impact the contract initiation/start date deliverables or any other BD obligations.

For the Technical Support Center and Field Service Engineers, Contractor requires all associates to complete annual training that is comparable to VA requirements.

Contractor will be responsible for ensuring that their employees meet the standards agreed upon between the Contractor and VA and for continuously monitoring and tracking the status of all Contractor employees. Contractor is responsible for managing our associates to ensure that all training is completed by our associates.

b. The contractor shall provide the contracting officer and/or the COTR a copy of the training certificates and certification of signing the Contractor Rules of Behavior for each applicable employee within 1 week of the initiation of the contract and annually thereafter, as required.

BD Exception: BD personnel will be assigned to complete all training requirements at the direction of Providence VA Medical Center once initial project kick off meetings have concluded to meet the 30day requirement, not at the initial award of the contract.

Additional time will be required to coordinate with BD’s Technical Support Center’s associates for the tasking and completing of requested training.

c. Failure to complete the mandatory annual training and sign the Rules of Behavior annually, within the timeframe required, is grounds for suspension or termination of all physical or electronic access privileges and removal from work on the contract until such time as the training and documents are complete.