SOW - Transcription.docx

Statement of Work for Medical Transcription Services VA Health Care System

1. OVERVIEW/SCOPE OF WORK

1.1. VA Central Iowa Health Care System (CIHCS), VA Nebraska-Western Iowa Health Care System (NWIHCS), VA Iowa City Health Care System (ICHCS) and Sioux Falls VA Health Care System (SFHCS) have a requirement for traditional and speech recognition, and voice recognition editing medical transcription services. The contractor shall provide medical transcription services via a remote connection to access and utilize the VA-owned VISTA system while meeting VA information security requirements.

1.2. The Contractor shall provide off-site, remote-access, medical transcription services for CIHCS, NWIHCS, ICHCS, and SFHCS per this Performance Work Statement (PWS) and the resulting associated contract documents.

1.3. Medical transcription services shall be provided by the Contractor twenty-four (24) hours a day, seven (7) days a week, including all holidays.

1.4. The Contractor shall have the ability to adapt to monthly staff and resident changes in various medical specialties. Workload can vary significantly depending on dictator’s response to delinquent reports and/or resident rotation. Due to the transitional nature of medical record automation, which directly impacts the amount of dictation and transcription to be performed, the estimated quantities indicated herein are the best estimates available. Conditions affecting requirements may not be constant.

1.5. The Contractor shall assign a Project Manager for the purpose of supervising and training contractor personnel and ensuring compliance with the provisions of the contract. The Project Manager shall have the full authority to act on behalf of the contractor to handle day-to-day operations and problems or concerns as they arise. The Project Manager or an alternate shall be available during the VA’s normal business hours (0800-1630 Central Time Monday through Friday).

1.6. The Contractor shall have an established work force of either Certified Healthcare Documentation Specialists (CHDS) or transcriptionists having past experience transcribing various types of acute care clinical dictation, e.g. medical, surgical, psychiatric, radiological, etc., to include all specialty areas and clinical vocabularies.

1.7. The Contractor shall transcribe dictated material into the required report format pertinent to the medical care of patients at the Veterans Health Care System consisting of divisions and VA Clinics for VA. These reports include, but are not limited to, discharge summary, operative reports, history and physical reports, consults, compensation and pension exams, non-operative procedure notes, assessment reports, letters, telephonic consents, STAT Reports, and clinic notes. The subjects will include but are not limited to medical, surgical, and diagnostic services. Additional transcription services required may include recorded conversations, and other miscellaneous and administrative reports as required by VA.

1.8. Material is dictated by a variety of clinical staff and requires adaption to variations in accents, speech, tone, voice volume, delivery, pronunciations, and enunciation, and may require corrections to grammar. Transcription of dictated materials includes a high incidence of technical terminology and requires knowledge of specialized vocabulary particular to a wide variety of specialty services.

1.9. The contracted medical transcriptionists shall use the formatting guidelines set forth in the ASSOCIATION FOR HEALTHCARE DOCUMENTATION INTEGRITY (AHDI)’S “BOOK OF STYLE FOR MEDICAL TRANSCRIPTION,” THIRD EDITION. Correct grammar, punctuation, spelling, and dictation and shall be transcribed in the proper tense. Incorrect grammar, incorrect punctuation, misspelling, and blank spaces will be considered as errors. The contractor is required to exercise proper judgment in discerning between errors or omissions without changing sentence structure. Changes in sentence structure, which are clerical in nature, misspelling of proper names, incorrect social security numbers, incorrect admission and/or discharge dates, and incorrect date of surgery, are all errors. The contractor shall edit the document for grammatical errors while ensuring that the medical content of the document is not altered in doing so. The contractor shall refer ambiguous items needing correction or clarification to the VA Contracting Officer’s Representative (COR) or designee for clarification or correction, and do so by means of (VISTA) mail, e-mail, or telephone.

1.10. The contractor shall not subcontract or upload work to another transcription firm. Due to security and privacy concerns associated with the sensitive data that is the subject of this contract, without exception, all transcription, verification, and uploading of reports must be physically located and the work conducted in the United States. All transcription and verification services must be performed in the United States of America, including US territories. No work shall be moved off-shore of the United States of America. here are no exceptions.

1.11. The contractor shall provide the following to meet the requirements of this agreement to include: PIV card readers, personnel, computers, internet, software management program, transcription equipment (headsets/foot pedals, etc.), reference material, telephones w/connection. Installation, maintenance, training, updating, and repair to the contractor-owned equipment and software are the sole responsibility of the contractor. There will be no Government furnished equipment provided for services under this agreement.

1.12. The contractor shall provide and pay for leased communications lines and/or communications equipment that are used for their access to the VA VISTA System and printers. The equipment must be compatible with the VA communications network.

1.13. The contractor shall provide, at their location, dictation lines compatible with and capable of being accessed twenty-four (24) hours/day, seven (7) days/week including federal holidays with at least one toll-free number available for dictation access.

2. PERIOD OF PERFORMANCE

2.1. The agreement will be effective for one year with the option to extend services for up to four one-year option periods. Award of an option year is at the sole discretion of VA and award is subject to the availability of VA funds for each fiscal year. Therefore, no services shall be performed in any option year until authorized in writing by the VA Contracting Officer (CO), and a signed task order is issued.

2.2. The Period of Performance is:

3. GENERAL REQUIREMENTS AND DELIVERABLES

3.1. Material is dictated by physicians and providers from many disciplines and shall require adaptation by the medical transcriptionists due to variations in speech, tone, voice volume, delivery, pronunciation, and enunciation. Dictators may include persons for whom English is a second language; however, all dictations will be in English. The contractor is responsible for correct spelling, including unfamiliar words.

3.2. The contractor shall be responsible to check medical and English dictionaries as needed for distinguishing between similar sounding medical, surgical, radiology, pharmaceutical, laboratory, and other terms; the preferred dictionary being the most recent edition of TABER’S CYCLOPEDIC MEDICAL DICTIONARY.

3.3. A list of approved and “VA Unapproved Abbreviations” shall be provided to the contractor upon award of the contract and upon each subsequent revision. If an approved abbreviation list is not provided, the contractor shall use the most recent edition of STEDMAN’S ABBREVIATIONS, ACRONYMS, AND SYMBOLS. VA will provide a reference list of physicians and other personnel whose names may be required for use in reports.

3.4. No abbreviations are to be used in the diagnosis or listing of operations and procedures. Standard abbreviations shall be acceptable in the body of the summary should be limited to those on an approved abbreviations list and only if dictated. If providers dictate using unacceptable abbreviations, they are to be spelled out by the transcriptionist. The following abbreviations are never to be used: U, u, IU, Q.D., Q.O.D., MS, MSO4, MGSO4, TIW, H.S., lack of zero before a number (example .1 mg shall be 0.1 mg) and trailing zero after a number (example 1.0 mg shall be 1). If any unapproved abbreviation was dictated, the contractor is to spell out the word(s). The VA Contracting Officer’s Representative (COR) or designee shall periodically inspect the contractor’s final output for accuracy.

Unapproved Abbreviations

Dangerous Abbreviation

3.5. The contractor shall be responsible for all proofreading. Transcribed work received by VA which contains omissions, spelling/grammatical errors, and/or is completed in a manner which is unacceptable to VA shall be returned to the contractor for correction at no additional charge to the government. Transcribed reports, other than STAT reports, returned to the contractor shall be corrected by the contractor and returned to VA within four working hours from receipt of notification at no additional cost to the government. Transcribed STAT reports returned to the contractor shall be corrected by the contractor and returned to VA within one working hour from receipt of notification at no additional cost to the government.

3.6. Visible Black Character (VBC) – A Visible Black Character is defined strike-able and visible characters and includes any printed letter, number, symbol, and/or punctuation mark excluding any or all formatting (e.g., bold, underline, italics, table structure, formatting codes). All visible black characters can be seen with the naked eye as a mark, regardless of whether viewed electronically or on a printed page.

3.7.

3.8. Visual Black Character (VBC) Line or ASCII no Spaces Line – A VBC line is defined as the total number of characters you can see with the naked eye, divided by 65. It includes any character contained within a header or footer. Spaces, carriage returns, and hidden format instructions, such as bold, underline, text boxes, printer configurations, spell check, etc., which are not counted in the total character count. A VBC line is calculated by counting all visual characters and simply dividing the total number of characters by 65 to arrive at the number of defined lines.

3.9. Exact execution of VA format is mandatory. VA format follows the AHDI BOOK OF STYLE FOR MEDICAL TRANSCRIPTION GUIDELINES. Formats for various reports may change throughout the life of the contract. If the transcription format changes, the Contractor will be provided with the new specifications. When this occurs, the Contractor shall be required to convert to the new format immediately.

3.9.1. If appropriate formatting is not utilized, the COR will notify the contractor and the report will be returned. Transcription reports, other than STAT reports, returned to the contractor shall be corrected by the contractor and returned to VA within four working hours from receipt of notification at no additional cost to the government. Transcription reports for STAT reports returned to the contractor shall be corrected by the contractor and returned to VA within one working hour from receipt of notification at no additional cost to the government.

3.9.2. HEADER: Required by each document type, the header shall conform to standards provided by VA based on document type. The header includes the document type, patient social security number, date of encounter, date of surgery or date of admission as applicable, work type, the document author, dictation date and time, location, and attending physicians as applicable. It is the contractor's responsibility to assure all header required information complies with the dictation work type requirements.

3.9.3. FOOTER: Footer information shall include the job number, the date and time dictated, date and time transcribed, and transcriptionist's initials. Transcriptionists will place their initials within the footer of the documentation. These initials are unique to the transcriptionist and represent the transcriptionist who transcribed the dictated report. The footer information typically appears on each document at the lower left-hand corner.

3.9.4. Errors of the Headers/Footers (include but are not limited to): Omitted material that is unintelligible, misspelled words, transposed letters, information located in the wrong category or field unless it cannot be determined where it belongs, typing other than what is dictated by changing the meaning, punctuation if it changes to the context of a sentence, and use of unapproved abbreviations.

3.9.5. Refer to the attached documents for examples of header and footer formats as required per each VA facility.

3.10. Medical transcription reports shall be uploaded by the contractor a minimum of four times each day including weekends and holidays. Additional uploads may be necessary to successfully accomplish turn-around times.

3.11. Reports will be considered transcribed when a report is received in the VA VISTA system.

4. DELIVERABLES FOR ATTAINING & MAINTAINING COMPUTER ACCESS

4.1. Ensure credentials of every AHDI-credentialed transcriptionist, providing proof of such. The contract transcriptionists and validation staff (managers, leads, etc.) must have advanced specialized knowledge of medical record documentation, healthcare documentation integrity, medical terminology, anatomy & physiology, clinical medicine, pathology, and grammar / documentation guidelines for compliance.

4.2. The contractor shall provide VHA personnel access to the contractor’s transcription software to perform daily report and invoice audits.

4.3. The contract transcriptionists will gain access the VA’s VistA software, via a remote connection, after all listed requirements have been met and clearances have been secured.

4.4. The onboarding process will begin within five business days from date of award and all required documents are to be electronically submitted (encrypted email) to the CO, COR, and/or designee:

4.4.1. Fingerprints – either taken at a local VA facility or at an accepted location, and then mailed electronically or manually to the VA VHA Service Center (VSC) for processing / adjudication. Documents to complete will be provided following agreement award.

4.4.2. The position sensitivity impact for this effort has been designated as Low Risk and the level of background investigation is NACI. A background questionnaire will need to be completed, as assigned by the VSC to initiate the background check.

4.4.3. TMS Training Certificates: VA Privacy & Information Security Awareness & Rules of Behavior, and Privacy & HIPAA Focused Training. These are annually recurrent training which must be kept current in order to maintain access.

4.4.4. VISN 23 Authorization for AIS Access Request Form

4.4.5. VA Information Security Officer (ISO) Certification Request Form

4.4.6.

4.4.7. National Contractor Access Program (NCAP) Remote Access Client Account User Datasheet

4.5. Requirements may change including the documents to meet the requirements. The contractor will need to comply with the request for any additional documents should such a request be made.

4.6. The Contractor shall bear the expense of obtaining background investigations. If the investigation is conducted by the Office of Personnel Management (OPM) through the VA, the Contractor shall reimburse the VA within thirty calendar days.

4.7. Background investigations from investigating agencies other than OPM may be permitted if the agencies possess an OPM and Defense Security Service certification. The determination of acceptability will be made by the VSC.

4.8. The contractor shall prescreen all personnel requiring access to the computer systems to ensure they maintain a U.S. citizenship and are able to read, write, speak and understand the English language. After contract award and prior to contract performance, the Contractor shall provide the Security Background Investigation Information to the CO and COR by providing a copy of the Certificate of Investigation (COI) or Certificate of Eligibility (COE).

4.9. The contractor, when notified of an unfavorable determination by the government, shall withdraw the employee from consideration from working under the agreement.

4.10. A staff roster will be created and maintained by the contractor with the submittal of each new package and approval. It shall include the employee’s position description as well as education and credentials.

4.11. The contractor will be responsible for the actions of all individuals provided to work for the VA under this agreement. In the event that damages arise from work performed by contractor personnel, under the auspices of this agreement, the contractor will be responsible for all resources necessary to remedy the incident.

4.12. Access will be provided to these software packages:

4.12.1. Citrix Access Gateway (CAG) – CAG Remote Access to VA Systems. CAG is a method of providing applications to a user without having to install the application directly onto the user’s endpoint device. CAG works with all operating systems deployed within the VA Enterprise and offers support for stationary and mobile devices. Some of the supported operating systems are Windows, MAC OSX, iOS and Linux. CAG presents users with a desktop look (virtual desktop) and feel that lists the available applications. Note specifically that the contractor will not be able to run their contractor-owned software system for transcribing dictations when using CAG. CAG does not allow third-party software applications to be run within CAG.

4.12.2. PIV Card – Use of the PIV Card will be required for access to VA Systems at all times

4.12.3. PKI – Email Encryption

4.12.4. Veterans Health Information Systems and Technology Architecture (VistA)

4.13. Notification of contractor resignation will be made immediately in order to terminate all accesses.

4.14. Upon request of the Contracting Officer, the Contractor shall remove any Contractor staff that do not comply with VHA policies or meet the competency requirements for the work being performed.

5. TURNAROUND TIME (TAT) REQUIREMENTS

5.1. If any dictation should prove to be significantly or completely inaudible or otherwise not able to be transcribed, the Contractor shall notify the COR within one (1) hour of the discovery of such issue(s).

5.2. The turnaround is defined as the period of time from the end of dictation of the document to the time the work is uploaded to the facility. The Contractor shall provide all transcribed reports in accordance with the turnaround times as followed in the Turnaround Times (TAT) Table as follows. Reports shall be completed and returned to the VA Medical Center within the stated times.

5.3. Turnaround time requirements of transcription, including transmission, shall be in effect twenty-four (24) hours/day, seven (7) days/week including Federal holidays. Transcription not completed within the required turnaround time shall be brought to the COR’s attention.

5.4. With the exception of STAT Reports, Operative Reports, History and Physical Exam Reports, and Informed Consent Reports, all other reports shall be transcribed in the order of receipt (first in, first out). STAT reports will be transcribed within 4 hours of the time dictated and take precedence over other reports. STAT reports will be transcribed and returned on the next available transmission.

Turnaround Times (TAT) Table

24 (outpatient)

6. POINTS OF CONTACT

6.1. The contractor shall ensure that a responsible individual is available to provide telephone support and service to VA twenty-four hours a day, seven days a week, including holidays.

6.2. The contractor must inform the COR of any problems or questions with dictations to avoid confusion in transcription.

6.3. Phone inquiries to the contractor will be responded to during the same working day unless initiated after normal working hours. A phone answering service or machine utilized by the contractor during normal working hours will not constitute an answer to VA and will require an individual response.

6.4. The VA COR will furnish a list of current physicians and other staff names, as appropriate, after award of the contract and updates as appropriate.

7. VISTA REQUIREMENTS

7.1. The contractor will be given access to the VA VISTA System in order to accomplish various tasks required by this agreement.

7.2. The contractor is responsible for any cost incurred in connecting to the VA VISTA System.

7.3. The contractor shall comply with all VA memorandums and Information Technology policies concerning Automatic Data Processing Security and Access to the VISTA system. Copies of all memoranda and policies will be provided to the contractor. Any new memoranda and policies or changes to existing memoranda or policies will be communicated to the contractor within thirty (30) days of implementation. The contractor shall have thirty (30) days to identify any adverse impact to the Contracting Officer.

7.4. The COR or designee delegated for technical guidance on computer functions will be designated after award.

7.5. The contractor will provide a list of all-current employees on an annual basis as well as new employees as they are hired who will be performing transcription so that unique Access Codes and Verify Codes can be assigned on the VITSA System. Individual “applications” for such access/verify codes will be required.

7.6. The contractor shall not maintain a list of their employees Access Codes or Verify Codes to the VISTA System. The contractor shall ensure that their employees do not divulge their Access Code or Verify Code to the VISTA System to anyone else.

7.7. The contractor’s employees will be given access to only those VISTA System menu options needed for the input and editing of transcription reports.

7.8. The contractor shall identify any delays in transcribing reports due to computer or communications downtime to the COR or Designee. Extensions in transcription time frames will be negotiated based on the time of downtime, extent of downtime, and cause of downtime. VA shall not be held financially liable for any delays in transcription services due to computer or communication downtime

8. EQUIPMENT

8.1. The contractor shall provide, at their location, dictation lines compatible with and capable of being accessed twenty-four (24) hours/day, seven (7) days/week including federal holidays with at least one toll-free number available for dictation access.

8.2. The contractor shall provide dictation equipment accessible by toll-free (to the Government) telephone with allowance for simultaneous author/dictators. The contractor shall be responsible for establishment of, maintenance and all costs associated with toll-free telephone lines.

8.3. The contractor shall have equipment capable to transcribe from a backup dictation system on occasion.

8.4. The contractor shall provide a secure (128-bit SSL) World-wide Web site or one remote management PC workstation which will allow VA employees to view current and post dictation jobs received, work pending, report type and/or patient report number, date and time of dictation, date and time assigned, reporting capabilities for transcribed reports up to one (1) year, and management reports such as statistics, trends, productivity and length of report by author/user.

8.5. Contractor-owned equipment shall have the ability to interface with the Veterans Information Systems Technology Architecture (VISTA) environment utilizing Intersystem’s Cache` (or other VA Electronic Medical Record environment) using either the national VA's TIU Upload routine (TIUUPLD) or Health Level 7 (HL7) version 2.3 (or higher) transaction processing. Connectivity between the Contractor and the VA computer systems will be through a secure means of transmission such as use of the national VA's Virtual Private Network (VPN) solution or Public Key Encryption (PKI) technologies. The method of connectivity (either to an Internet Service Provider then using VPN, or directly to the VA), and its maintenance costs will be the expense of the contractor.

8.6. The Contractor and its employees must comply with the Health Insurance Portability & Accountability Act of 1996 (HIPAA) and VA security policies the same as all VA employees.

8.7. Generic user accounts are expressly prohibited on VA computer systems. Each user of VA computer systems must be given their own personal access authority to the VA computer systems.

8.8. Other software can be used for the contractor's transcription data entry, but it will not be supported by the VA. If any software other than what is listed is utilized on contractor’s computer system, training of VA personnel will be provided by the contractor or designee.

9. DICTATION REQUIREMENTS

9.1. The contractor shall protect against loss or misuse of all dictated and transcribed documents. The documents are irreplaceable medical information.

9.2. The contractor shall ensure the confidentiality of all patient information and shall be held liable in the event of breach of confidentiality.

9.3. The contractor shall ensure that dictation is never co-mingled in any way with data for another agency or corporation.

9.4. Social Security Numbers (SSN) must never be included in the body of any report to eliminate identity theft issues. SSN reduction requires limited use of the full SSN. If the body of the report includes the SSN it may be missed in redaction.

10. QUALITY ASSURANCE VIA QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

10.1. The contractor shall return transcribed notes to VA using one of two methods at the discretion of the facility: (1) direct entry into VISTA system, or (2) uploading directly to VISTA for the respective VA facility. The contractor will be notified of any changes to the method of returning reports thirty calendar days in advance of the change. The contractor shall have thirty calendar days to identify any changes or adverse impact to the CO and COR. Items not uploaded into VISTA, such as letters and administrative documents, shall be sent/delivered to the VA by other acceptable means for transporting confidential information.

10.2. Reports will meet the professional quality standards set forth below including the body of the text as well as the information in the header and the footer. All transcription must be completed in accordance with prescribed formats. Completed work will contain no blanks from dictation, which is unintelligible to the VA. Contractor must maintain a quality control system to assure complete and accurate reports. The contractor will maintain a high level of accuracy with a quality assurance standard of 98% accuracy based on error to lines.

10.3. Any transcribed documents considered unacceptable, in the opinion of the Contracting Officer’s Representative (COR) or the Quality Assurance Evaluator, will be re-typed at the Contractor’s expense

10.4. QUALITY MONITORING: The Contactor will perform a random sampling at least once per month by comparing the completed report with the voice dictation. The random sampling may be either a sampling of all reports or a subset of reports. Any report with three or more blanks may also be included in this sampling. If significant errors (non-compliance) are determined, the contractor will be requested to provide a corrective action plan to the Contracting Officer and COR.

10.4.1. All transcription services required during the month will have an accuracy rate of 98%.

10.4.2. Failure to meet the 98% accuracy rate for two consecutive months will result in a 10% reduction in payments until the 98% accuracy rate is re-established.

10.5. HEADER ERRORS: Headers include but are not limited to: Incorrect work type/title, patient name, SSN, date of service, author, date/time of dictation, attending surgeon/expected cosigner, and transcriber. Errors in the header shall not exceed five in one month.

10.6. Uploading reports to a wrong VHA facility is considered a privacy/security violation and is a reportable incident under HIPAA.

11. ANALYSIS OF QUALITY ASSURANCE VIA QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

11.1. Performance Evaluation: VA shall use the monitoring methods cited within the Quality Assurance Surveillance Plan (QASP) to determine whether the performance standards and performance levels have been met. If the contractor has not met the minimum requirements as stated in the QASP, it may be asked to develop a corrective action plan to show how and by what date it intends to remediate issues.

11.2. Reporting: At the end of each quarter, the COR will prepare a written report for the CO and contractor summarizing the overall results of the quality assurance surveillance of the contractor’s performance. This written report, which includes the contractor’s submitted monthly report and the completed quality assurance monitoring forms, will become part of the contract documentation. It will enable the government to demonstrate whether the contractor is meeting the stated objectives and performance standards, including cost, technical, and scheduling objectives.

11.3. Reviews and Resolution: The CO and the COR may require the contractor to meet with the CO and COR and other government personnel as deemed necessary to discuss performance evaluations. The CO and COR will define a frequency of in-depth reviews with the contractor, including appropriate self-assessments by the contractor; however, if the need arises, the contractor will meet with the CO and COR as often as required or per the contractor’s request.

11.4. The CO, COR, and contractor should jointly formulate tactical and long-term courses of action. Decisions regarding changes to metrics, thresholds, or service levels should be clearly documented via a contract modification. Changes to service levels, procedures, and metrics will be incorporated as a written contract modification signed by the VA CO.

12. CONTINGENCY PLAN

12.1. The contractor shall maintain a written contingency plan.

12.1.1. The contingency plan shall address how the contractor plans to provide continuity of transcription services during contractor employee outages; telecommunications failure; dictating system failure; other atmospheric problems, which, if not addressed, could impede operations. Outages may be a cause of a natural disaster, emergency, or any other cause.

12.1.2. The Contractor shall maintain a written, comprehensive contingency plan describing the methodology for meeting turnaround times (TAT) at all times and for all work fluctuations.

12.2. In the event of a prolonged failure (lasting, or expecting to last for four or more hours) of the leased lines used by the contractor to access the VISTA system, the contractor shall fax all transcribed reports to the COR that were to be filed in the VISTA system. Additionally, as soon as the communication line(s) are restored, the contractor shall be required to file these reports into VISTA at no additional cost to VA.

12.3. VA will notify the contractor via phone and/or email when VA system downtimes occur. The medical transcription turn-around times may be adjusted to account for the downtime.

13. CONFIDENTIALITY, PRIVACY, AND SECURITY

13.1. Confidentiality: The VA will provide the contractor with access to pertinent patient information for the purposes of providing medical transcription services to VA. The contractor shall ensure the confidentiality of patient information, and shall be held liable in the event of breach of confidentiality. Contractor shall adhere to Health Insurance Portability and Accountability Act (HIPAA) standards. Any person who knowingly or willingly discloses confidential information from the VA may be subject to criminal penalties.

13.2. Privacy Act and Authorization to Release Information: As a result of this contract, the contractor shall be subject to the Privacy Act of 1974. The medical reports described in this solicitation are irreplaceable medical information that must be safeguarded at all times. Contractor shall refer to the Privacy Act Notification (FAR 52.224-1) and Privacy Act Clause (FAR 52.224-2) as found in the clauses section. The contractor shall develop and maintain a method of tracking all dictated and transcribed documents. The contractor is not authorized to release any medical record information. The VA is the sole entity authorized to release any information upon written authorization from the patient.

13.3. Patient Medical Information: Contractor personnel who obtain access to medical records or access hardware/software that may store drug or alcohol abuse data, sickle cell anemia treatment records, records or tests or treatment for infection with HIV, medical quality assurance records, or any other sensitive information protected under 38 U.S.C. 4132 or 3305, as defined by VA, shall not have access to the records unless absolutely necessary to perform the requirement. Any contractor employee required to access pertinent data shall not disclose to anyone that is not involved in the performance of this task. Any violation of these provisions may involve criminal penalties.

13.4. Patient Medical Records Handling and Storage: VA will allow the contractor personnel to work off-site, remote from the VA facility. However, the contractor is responsible for ensuring that the employees maintain the records in a safe and secure environment. Any examples for content, reference, or formatting must be de-identified.

13.5. In accordance with Federal Acquisition Regulation (FAR) 4.703, the Contractor’s contract files must be maintained for three years after final payment. The Contractor shall destroy the files on the anniversary of the third year after final payment has been received. The destruction shall be coordinated with VA.

13.5.1. Onsite Final Destruction – Acceptable methods of onsite final destruction for all content would include burning, pulping, and/or macerating. In addition, shredding with a shredder device that has a crosscutting capability to produce particles that are no larger than one millimeter by five millimeters (1 x 5 mm) in size, or that will pulverize/disintegrate paper material using disintegrator devices with a 3/32 inch security screen.

13.5.2. Offsite Final Destruction – An acceptable method offsite final destruction would be to shred the paper onsite to a minimum of 5/8 inch or less, and then take the shredded paper offsite to be pulped and recycled. If this methodology is used, the contractor shall provide the VA Contracting Officer Representative (COR) with an unbroken VA chain of custody throughout the destruction process, otherwise known as cradle to the grave.

13.5.3. Chain of Custody – A written means of tracking the records that have been marked for destruction throughout the entire destruction process until a certificate of destruction is received.

13.5.4. Certification of Destruction – Written documentation by a records destruction or recycling contractor or vendor that attests to the completion of the destruction process after the destruction of VA records has taken place. This certification is not considered a valid certification of destruction if submitted prior to the actual destruction of the records.

14. SECURITY

14.1. The contractor shall ensure adequate LAN/Internet, data, information, and system security in accordance with VA standard operating procedures and standard contract language, conditions, laws, and regulations.

14.2. The contractor’s firewall and web server that will be utilized for this contract shall meet or exceed the government minimum requirements for security. All government data shall be protected behind an approved firewall.

14.3. Antiviral software shall be installed by the contractor and kept current.

14.4. Any security violations or attempted violations shall be reported to the VA COR and VA Information Security Officer (ISO) within one hour of the incident.

14.5. Equipment should be housed and protected in such a way that reduces the risks from environmental threats and hazards, and the opportunities for unauthorized access, use, or removal.

14.6. Only VA-approved remote access solutions, certified and accredited by VA, may be used. All remote connections to VA networks must be through Office of Cyber Security authorized configurations and access points.

14.7. Computers used to access the VA network remotely are subject to the following:

14.7.1. The configurations, processes, and procedures described in the VA Remote Access Guidelines, published and updated by the Office of Cyber Security (OCS), must be adhered to;

14.7.2. Any remote access to VA systems that contain sensitive information must be done through One VA Portal exclusively with use of the PIV Card; all work may be done exclusively on the CAG (VA System). After contract award and prior to VA granting access, the contractor shall be required to complete or provide proof of all security requirements;

14.7.3. All remote access devices used to connect to VA networks will be configured to provide protection from malicious code and unauthorized access.

14.7.4. VA Directive 6500 shall be adhered to and all requirements met.

14.7.5. Contract employees are required to log onto VPN access point at a minimum of every two weeks in order to maintain access and VISTA at a minimum of every two weeks in order to maintain access.

14.8. VA information may not reside on non-VA systems or devices unless specifically designated and approved as appropriate for the terms of the contract.

14.9. The contractor shall provide assurance to VA Information Resources Management (IRM) Chief, Information Security Officer (ISO), and/or designee that they have adhered to the remote access requirements, that systems are properly configured and that appropriate security mechanisms and monitoring devices are up to date with best practices and technical standards.

14.10. Upon termination or completion of the contract, computer equipment used in performance of contractual obligations will be sanitized according to VA standards and guidelines. When non-VA equipment is transferred or disposed, the equipment will be sanitized according to VA standards and guidelines. Sanitization of equipment shall include the requirement for the contractor to surrender the hard drives of the equipment to VA for destruction. Additional sanitization of electronic media can be found in VA Handbook 6500.1 “Electronic Media Sanitization.”

14.11. The contractor shall follow all applicable VA policies and procedures governing information security, especially those that pertain to certification and accreditation.

14.12. Contractors are prohibited from establishing communication configurations that would permit access to be established from outside the VA onto VA private networks that bypass established authentication and authorization processes, such as enabling unsecured modems on computers connected to VA internal networks.

15. CONTRACTOR PERSONNEL SECURITY REQUIREMENTS

15.1. Users will not divulge their passwords and will follow VA guidelines for creating passwords.

15.2. While on the VA computer network, users will abide by VA directives, policies, and procedures.

15.3. Users are not authorized to use remote access services to engage in any activity that is illegal under local, state, federal, or international laws; or that violates VA policies.

15.4. Use of PIV Card will always be used to access VA systems.

16. GOVERNMENT RESPONSIBILITIES

16.1. After award, the COR will provide the necessary background investigation forms to the contractor.

16.2. Upon receipt, the VA VSC will review the completed forms for accuracy and forward the forms to the VA Security and Investigations Center (SIC) to conduct the background investigation.

16.3. The VA Security and Investigations Center (SIC) will notify the COR and the contractor after adjudicating the results of the background investigations received from OPM.

16.4. The VA will provide secure and reliable remote access to systems, applications, and information on the VA network for business partners (government agencies, contractors, and others authorized remote access to VA networks).

16.5. VA Information Resource Management Chief, ISO, and/or designee will approve individual requests for remote access based on business requirements, including restrictions and limitations that should be applied.

17. GLOSSARY OF DEFINITIONS

17.1. Commonly used acronyms and their equivalents listed will apply to the contract. Definitions that are used throughout this contract shall have the following meanings:

17.1.1. Government/VA: In this solicitation/contract, government and VA are used interchangeably to mean the US Department of Veterans Affairs, and/or VA Health Care System

17.1.2. Contracting Officer (CO): The government representative with the authority to enter into, administer, and/or terminate contracts and make related determinations and findings

17.1.3. Contracting Officer’s Representative (COR): VA staff person or persons designated by the Contracting Officer to act for the CO within the limits of the delegated authority. The COR has no authority to make changes to the contract terms. This person serves as the point of contact for issues relating to the administration and coordination of services provided under this contract.

17.1.4. Turn-Around-Time (TAT): TAT is the difference in time between the time the author hangs up at the conclusion of dictating into the contractor’s dictation system and the time the contractor’s completed transcription arrives in the appropriate destination at the VA. The VA may implement a program that automatically calculates the difference in time between the time the author hangs up at the conclusion of dictating into the contractor’s dictation system and the time the contractor’s completed transcription arrives in the appropriate destination at the VA.

17.1.5. Discharge Summary: A type of report that summarizes the in-patient stay.

17.1.6. Operative Report: A report done for procedures performed in the Operating room.

17.1.7. Procedure Report: A report done for procedures performed in a Specialty Procedure Room, including but not limited to: Pulmonary Function tests, Echocardiograms, Cardiac Stress tests, EMG/EEG, and Holter monitoring.

17.1.8. Compensation and Pension Exams: These are special exams for rating purposes that include history and physical exam findings as well as conclusions or recommendations.

17.1.9. Consultations: Consultation results that were prepared by a specialist. These may be inpatient or outpatient.

17.1.10. Progress Notes: Transcribed reports of outpatient encounters.

17.1.11. History and Physicals: Transcribed histories, most typically including psychiatric historic information.

17.1.12. Headers/Footers: Defined as redundant information occurring on multiple patients.

17.1.13. ISO: Information Security Officer for VA

17.1.14. PO: Privacy Officer for VA

17.1.15. Date of Dictation: Date and time dictation completed

17.1.16. Date Transcribed: Date and time transcription completed

17.1.17. Blanks: If dictated material, after a full review cannot be understood, a blank space will be represented by the type symbols *-*, which will notify the provider of the need to edit the entry upon return to the VA.

17.1.18. VA Records: In this solicitation, VA records include the dictated (voice) record and the transcribed report (text), as well as any paper copy or storage medium for voice or text.

17.1.19. Acceptable Error Rate: Defined as up to 2% per report.

17.1.20. Line: A Visual Black Character Line (VBC) is defined as the total number of characters you can see with the naked eye, divided by 65. It includes any character contained within a header or footer. Under this contract, the VBC is the unit of measure for billing and payment purposes.

17.1.21. QA: Quality Assurance

17.1.22. STAT Report: A report required to be transcribed and returned to VA within a compressed timeframe. Specifically, STAT reports shall be returned within four hours from end of dictation.

17.1.23. VISTA: Veterans Health Information Systems Technology Architecture is an automated environment that supports day-to-day operations at Department of Veterans Affairs (VA) health care facilities. VISTA is built on a client-server architecture, which ties together workstations and personal computers with graphical user interfaces at VA facilities, as well as software developed by local medical facility staff. VISTA also includes the links that allow commercial off-the-shelf software and products to be used with existing and future technologies.