RFI FINAL 06-2025 - Revised.docx

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The Cleland-Dole Act Section 194 Independent Assessments
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VA-RFQ1762127
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This is a Request for Information (RFI) from the Department of Veterans Affairs (VA) seeking market research for an independent assessment of VA health care delivery systems and management processes, as mandated by the Cleland-Dole Act Section 194. The VA requires a contractor to coordinate and produce comprehensive assessments covering 14 specific areas, including veteran demographics, healthcare demand forecasting, staffing levels, information technology strategies, and organizational leadership competency. The first independent assessment must be completed by December 31, 2025, with the VA planning to award a contract by June 2024.

The RFI outlines a three-month performance period where the selected contractor will develop an integrated assessment plan, provide monthly status reports, manage communications, conduct individual assessments, and produce a final report to be submitted to the VA Secretary, Senate and House Veterans Affairs Committees, and published in the Federal Register. Interested contractors must respond by June 17, 2025, at 2 PM ET, submitting a 5-page capabilities statement addressing experience in healthcare system optimization, organizational transformation, and previous similar contract work. The VA is specifically seeking a private sector entity with proven outcomes in healthcare delivery systems that is not currently providing patient care services to the VA.

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Request for Information (RFI) The Department of Veterans Affairs (VA) is issuing this RFI in accordance with FAR 15.201(e). The agency does not intend to award a contract but rather gather information on capability, delivery and other market information pertinent for acquisition planning. The result of this market research will contribute to determining the method of procurement and identify parties having an interest in and the resources to support this requirement.

In accordance with Subchapter I of chapter 17 of title 38, United States Code, § 1704A (add . Independent assessments of health care delivery systems and management processes requires any contractor that is awarded a contract under this bill to adhere to the following:

(d) PRIVATE SECTOR ENTITIES DESCRIBED.—A private sector entity described in this subsection is a private entity that— ‘‘(1) has experience and proven outcomes in optimizing the performance of national health care delivery systems, including the Veterans Health Administration, other federal health care systems, and systems in the private, non-profit, or public health care sector;

‘‘(2) specializes in implementing large-scale organizational and cultural transformations, especially with respect to health care delivery systems; and ‘‘(3) is not currently under contract with the Department to provide direct or indirect patient care or related clinical care services or supplies under the laws administered by the Secretary.

Required Outcome: The VA Secretary delivers to Congress an integrated independent assessment of the hospital care, medical services, and other health care furnished by VA as required by Section 194 of the Cleland-Dole Act, grounded in health care delivery science and reflective of health industry best practices, that supports a case for action to improve the health and well-being of Veterans.

PERFORMANCE WORK STATEMENT (PWS)

BACKGROUND

On December 29, 2022, the Consolidated Appropriations Act of 2022 became public law 117-328. Section 194 of the Cleland-Dole Act, included as Division U in P.L. 117-328, requires VA to conduct an independent assessment of VA health care delivery systems and management processes at least every ten years. Specifically, this provision requires VA to enter into one or more contracts with a private entity or entities to conduct the independent assessment of the hospital care, medical services, and other health care furnished by a combination of VA Federal workforce and contracted support by other private entities. Section 194 of the Cleland-Dole Act outlines at least 14 different requirements for the Independent Assessment. These include the current and projected demographics and unique health care needs of the patient population, the accuracy of models and forecasting methods, the organization, workflow processes, and tools to support clinical staffing, access to care, effective length of stay management and care transitions, positive patient experience, accurate documentation, and subsequent coding of inpatient services, among others. The first Independent Assessment is required to be completed by December 31, 2025. To meet this mandated completion date, VA must enter into such a contract with a private sector entity or entities by June 2024. Subsequent reports, every 10 years, will require new requests for funding and new contracts through December 2055. This EDM for review and approval is only for the initial assessment for Cleland-Dole’s Section 194.

This statutory requirement is similar in nature and scope to the independent assessment completed as required by the Veterans Access, Choice, and Accountability Act of 2014 (P.L. 113-146). At that time, VA entered into a multimillion dollar contract with the MITRE Corporation, a Federally Funded Research and Development Center (FFRDC), to serve as Program Integrator. In turn, MITRE subcontracted with several entities to complete the evaluation of the required elements, resulting in a series of reports submitted to congress. VA will need to pursue a similar course of action to complete the independent assessment required in Section 194. Although an FFRDC will not be appropriate for this assessment, VA will need to contract with an entity that will likely have to subcontract work to complete the assessment on time.

As part of the Consolidated Appropriations Act of 2023 (P.L. 117-328), Section 194 of Division U (also referred to as the Joseph Maxwell Cleland and Robert Joseph Dole Memorial Veterans Benefits and Health Care Improvement Act, or Cleland-Dole Act) requires VA to contract with the private sector to conduct an independent assessment of VA health care delivery systems and management processes at least every ten years. The first Independent Assessment is required to be completed by a contracted private entity(ies) by December 31, 2025.

1.0 SCOPE OF WORK

The contractor shall provide independent and objective analyses and recommendations to VHA for implementation of Section 194 of the Cleland-Dole Act. The contractor shall coordinate the overall planning and outcomes of the assessments conducted by all participating entities as described in the law, as well as provide enabling program management, process engineering, content analysis, and acquisition support as required to ensure the Veterans Administration produces a final report that is in full compliance with law. The contractor shall gather data and/or reports for each of the areas of assessment and integrate them into a single report for submission to Congress, and for publication in the Federal Register and on a VA public-facing website.

2.0 PERFORMANCE DETAILS

2.1 PERFORMANCE PERIOD

The period of performance shall be 3 months from the date of the award of this contract.

2.2 PLACE OF PERFORMANCE

The contractor shall work primarily at its offices. Work will be primarily remote but with possible intermittent travel (subject to COR approval in accordance with existing processes for the task order, which may include a contract modification) as required to perform the tasks associated with the effort. Space will not be assigned on a regular basis on VA premises. If travel to a VA facility is required, space may be shared with contracted staff on an ad hoc basis.

The contractor will be required to participate in these primarily remote meetings with VA via Microsoft Teams or other conferencing capabilities within VA’s and the contractor’s capabilities.

2.3 TRAVEL

The contractor may need to perform travel to complete the requirements of this task order (TO) as authorized, in advance, by the Contracting Officer (CO) or the Contracting Officer’s Representative (COR). Travel requests require justification and will be approved by VA beforehand. Travel costs will be paid in accordance with the Federal Acquisition Regulations (FAR) and Federal Travel Regulations (FTR) in effect at the time travel is taken. Local travel is defined as travel within 50 miles of an employee’s main office location. However, reimbursement for the first and last trip of the workday, which are considered commuting, will not be reimbursed by the government, and as a result, these costs will not be invoiced to the government.

2.4 REASSIGNMENT AND REPLACEMENT OF CONTRACTOR PERSONNEL

The Government reserves the right to request that the Contractor reassign Contractor employees whose continued effort under this contract is deemed contrary to the best interests of the Government. Notice of such reassignment will be given in writing by the Contracting Officer (CO). In the event the Contractor finds it necessary to replace any of the essential personnel during the performance of this contract, the CO and COR shall be notified in writing. In cases of a Contractor initiated reassignment of personnel, notice shall be provided at least 15 calendar days prior to reassignment. Replacement personnel shall meet or exceed the qualifications of the originally assigned personnel.

2.5 CONTRACTOR FURNISHED ITEMS

Unless otherwise specified, the Contractor shall furnish all necessary management, supervision, labor, facilities, equipment, supplies and materials necessary to perform under this contract.

2.6 ESSENTIAL PERSONNEL

At a minimum, the contract shall be managed by an Executive Director with overall responsibility for managing and directing the activities and work of the contract. The Director shall have full responsibility for all aspects of the contract’s operations and shall ensure the effective and efficient use of the contract’s personnel and resources to achieve the goals and objectives as specified in each task order and work request. All essential personnel shall ensure the complete objectivity of the contractor’s operations as well as the technical accuracy and reliability of the contractor’s products, reports and recommendations. Essential personnel are required to attend committee meetings, as appropriate, and shall keep the Government advised of all issues affecting the contractor or the Independent Assessments. The essential personnel shall work closely with committees, as required, and other VA officials as appropriate, to aid in conducting, coordinating and reporting on the technical and strategic assessment of related VA health care system components.

Conversely, the Government will make the essential personnel aware of issues relating to Information Systems policies and strategies which affect the performance of the contractor.

2.7 ORGANIZATIONAL REQUIREMENTS

With respect to its operations under this contract, the contractor shall operate in the public interest with objectivity and be free from any organizational conflicts of interest, whether real or apparent, and whether financial or non-financial. Employees and agents of the contractor shall, with respect to the performance of their duties, be free from personal conflicts of interest, whether real or apparent, and whether financial or non-financial.

The contractor shall fully disclose its operations, financial and other business interests to the government. The organization operating, managing, or administering the contract shall be prepared to disclose its operations, financial and other business interests fully to the government.

Use of the contract is appropriate for activities and mission objectives that support the continuing and long-term challenges of the government’s mission. The contractor shall not perform work that is inherently governmental in nature. As described in the Office of Federal Procurement Policy (OFPP) Letter 11-01, Performance of Inherently Governmental and Critical Functions (76 Fed Reg 56227), the contractor may perform work that is “closely associated with the performance of inherently governmental functions, or work that is critical to maintaining control of an agency’s mission and operations”. The contractor provides critically needed support that would otherwise be inappropriate or problematic if performed by the government. The contractor enables the government to use private sector resources to accomplish tasks that are integral to the mission and operation of the government. Accordingly, the contractor shall work in concert with the private sector, public sector and academia to facilitate successful outcomes and to mitigate risk to the government.

3.0 SPECIFIC TASKS AND DELIVERABLES

3.1 Program Integration

The contractor shall collaborate closely with the VA Section 194 Integrated Project Team (IPT) to establish the operating framework for the program, including goals, roles, and operating cadence to manage all work associated with meeting the requirements of the Cleland-Dole Act Section 194. Support shall also include requirements and milestone planning, status reporting, governance, and risk management.

The Contractor shall provide a detailed independent assessment plan and roadmap which shall include an illustration of the recommended sequencing of assessments and recommendations to prioritize, link, de-conflict, and sequence actions for government reviews and decisions.

The Contractor shall provide the planning, coordination, and integration activities necessary to conduct, at minimum, 14 assessments and one final report as described in Section 194. The contractor shall provide a plan describing how each assessment will be conducted, who is assigned, the schedule, milestones, and any associated risks. The plan may include recommendations for the contractor to conduct separate procurements.

Deliverables:

A. Independent Assessment Plan and Roadmap with alternative plans that include pros and cons, and justification of pursuing the recommended plan and roadmap.

B. Status Reports, monthly.

3.2 WORK PLAN

All work to be accomplished under each task order shall be managed by the contractor via a Work Plan (WP) – a formal deliverable, subject to VA’s review and written approval.

The contractor shall update and resubmit the WP to VA to accommodate changing priorities and work requirements. The contractor’s WP will serve as the primary tool through which the COR will oversee the work performed by the contractor. The WP provides a specific description of the anticipated contractor activities, deliverables, and/or projected outcomes by major task area. The WP will list Government Furnished Information/Government Furnished Property requested and issued.

The WP is a “living” document that shall be periodically reviewed for any necessary updates. Any revisions to the WP shall be agreed to by the contractor and COR before being made effective in the task order. The WP will be updated at least on a quarterly basis.

The contractor shall submit a draft WP within 15 workdays after award. The CO and COR will have an opportunity to review the draft WP and return recommended changes to the contractor. If no changes are required, or after appropriate changes are made and the WP is resubmitted, the WP will be deemed final. The WP and schedule shall demonstrate the capability to provide competent resources within a logical management framework to accomplish the scope of performance anticipated for the task support areas. The contractor shall also demonstrate the capability to reallocate resources to meet changing requirements, provide economy of performance, and ensure overall quality. The Government will review and approve the final WP and schedule.

Significant milestones and delivery dates shall not be changed without the COR’s approval.

A change to the WP may occur for a number of reasons. A change is defined as any alteration to the core structure of the WP, including amendments, deviations, and/or adjustments to the described approach, activities, deliverables, or projected costs. The following illustrates the most likely scenarios in which a change to the WP may be needed:

· The Program Office determines the need for revised services or modifications to the existing WP;

· The contractor recommends to the Program Office a proposed change to the WP; and

· The Program Office and the contractor collaboratively agree that a change to the WP is warranted.

Any changes to the WP occurring during the period of performance of a task order will be immediately coordinated via email between the COR and the contractor’s Program Manager (PM). The request will be documented via email. Work associated with any changes shall not commence without written direction via email from the COR. In all cases, the COR will participate in revising a WP.

The COR will review the proposed change(s) and determine the following:

· If the proposed change(s) is within scope;

· If there are sufficient existing task order funds to accommodate the proposed change(s); and

· If the proposed work can be accomplished within the timeframe remaining on the task order.

The COR will then notify the contractor’s PM via email, with a copy to the Contracting Officer, of the accepted revised WP and provide direction to proceed on the mutually agreed upon change(s). Before accepting the revised work, the contractor must validate, in writing, to the COR, that the revised work is within scope and can be performed within the existing task order funding. A repository of the emails shall be maintained by the COR and the contractor to serve as a record of the change until the quarterly WP update is delivered. Updates to the WP shall be recorded using Microsoft Word’s editing tracked changes feature. In addition, the contractor’s monthly progress report deliverable shall reflect any changes made to the WP as a result of this process.

The COR will consult with the Contracting Officer if it is determined the proposed change(s) cannot be performed within the scope, funds, or period of performance of the existing task order. The Contracting Officer will determine the appropriate course of action.

Deliverable(s):

A. Work Plan. Due 15 workdays after task order award and reviewed monthly thereafter throughout the period of performance.

3.3 REPORTING REQUIREMENTS

The Contractor shall provide the COR with Monthly Progress Reports in electronic form for each task order awarded, unless otherwise specified by the Government. The reports shall include detailed instructions and explanations for each required data element, ensuring that data is accurate and consistent. These reports shall reflect data as of the last day of the preceding month.

The Monthly Progress Reports shall cover all work completed during the preceding month and work planned for the subsequent month. The report shall also identify any problems or risks that arose and a description of how the problems were resolved and how the risks can be or were mitigated. If problems have not been completely resolved, the contractor shall provide an explanation, including its plan and timeframe for resolving the issue. The contractor shall monitor performance against the WP and report any deviations. The contractor shall keep in communication with VA so that issues that arise are transparent to both parties and to prevent escalation of outstanding issues. The monthly report shall also include at a minimum, key project information on scope, schedule, cost, and risk items:

· Funds expended against the current funded value of the project.

· Hours expended to date against hours proposed.

· Status of the activities as they relate to the schedule, either confirming that the activities are on schedule or explaining the nature and extent of the delay.

· Significant differences between planned, revised and actual schedule accomplishment for that month and the reasons for these differences.

· Any managerial actions taken as a result of variances relating to requirements.

· A listing of deliverables completed, including when they were delivered and to whom.

· Summary of effort and costs incurred for current period, cumulative periods to date, and projections for next period (month).

· Highlight any problem areas with respect to expenditures relative to current task order funding; progress relative to schedule and overall resource allocation; and any managerial actions to resolve these problem areas.

Deliverable(s):

A. Monthly Progress Report due the fifteenth (15) day of each month throughout the period of performance.

3.4 COMMUNICATIONS SUPPORT

Communications support will be required throughout this project to ensure success toward producing an independent assessment. Communication materials for each of the requirements must provide consistent content, formatting, and structure to be easily understood by VA staff and participants.

Provide strategic messaging, facilitated work sessions, facilitated leadership meetings, visioning sessions, internal and external message segmentation and stakeholder management to support all areas.

Provide legislative insight and experienced support to shepherd potentially high-visibility areas to national, state, and local government officials.

Provide high impact technical writing and graphic support for all communications products, reports, and briefings.

Deliverables:

A. Monthly, communication material that will be shared with leadership teams on the status of the assessment(s).

B. Field communication material explaining the project(s). Material may be used to garner support from the field.

3.5 INDEPENDENT ASSESSMENTS

There are, at minimum, 14 requested assessments as outlined in Section 194 of the Cleland-Dole Act. The contractor shall allocate the appropriate combination of technical, functional, and subject matter expertise for each assessment requested. In some instances, and according to the roadmap approved in section 4.2, the work may be performed by sub-contractors. The contractor shall work with all resources in order ensure each assessment is completed timely. Assessments shall be completed, and a final report prepared, within 3 months of entering into the contract. Each individual assessment and the overall integrated assessment shall provide high quality, substantive findings and recommendations feasible for implementation by the Department. The contractor shall benchmark the findings against the private sector. The contractor shall, upon completion of each individual assessment review the assessment report for accuracy, technical sufficiency, compliance with the requirements for that assessment as described in Section 194 of the Cleland-Dole Act, and completeness. VA is responsible for providing the reports resulting from the assessments to the Secretary, and Senate and House Veterans Affairs Committees. VA will publish the report in the Federal Register and on a VA public-facing website.

Each assessment covers a unique set of requirements. Some of the assessments are related by subject matter, e.g., health care demand and capacity, or functional domain, e.g., policies and workflow processes. Some assessments have additional specifications in the language of the legislation. Below is an itemization of the required assessments. All costs for each assessment should be tracked separately by the Contractor.

As set out in Section 194(a)(2) of the Cleland-Dole Act, the assessments will cover:

(A) Current and projected demographics and unique health care needs of the patient population served by the Department.

(B) The accuracy of models and forecasting methods used by the Department to project health care demand, including with respect to veteran demographics, rates of use of healthcare furnished by the Department, the inflation of health care costs, and such other factors as may be determined relevant by the Secretary.

(C) The reliability and accuracy of models and forecasting methods used by the Department to project the budgetary needs of the Veterans Health Administration and how such models and forecasting methods inform budgetary trends.

(D) The authorities and mechanisms under which the Secretary may furnish hospital care, medical services, and other health care at facilities of the Department and non-Department facilities, including through Federal and private sector partners and at joint medical facilities, and the effect of such authorities and mechanisms on eligibility and access to care.

(E) The organization, workflow processes, and tools used by the Department to support clinical staffing, access to care, effective length-of-stay management and care transitions, positive patient experience, accurate documentation, and subsequent coding of inpatient services.

(F) The efforts of the Department to recruit and retain staff at levels necessary to carry out the functions of the Veterans Health Administration and the process used by the Department to determine staffing levels necessary for such functions.

(G) The staffing level at each medical facility of the Department and the productivity of each health care provider at the medical facility, compared with health care industry performance metrics, which may include the following:

(i) An assessment of the case load of, and number of patients treated by, each health care provider at such medical facility during an average week.

(ii) An assessment of the time spent by each such health care provider on matters other than the case load of the health care provider, including time spent by the health care provider as follows:

(I) At a medical facility that is affiliated with the Department.

(II) Conducting research.

(III) Training or supervising other health care professionals of the Department.

(iii) An assessment of the complexity of health care conditions per patient treated by each health care provider at such medical facility during an average week.

(H) The information technology strategies of the Department with respect to furnishing and managing health care, including an identification of any weaknesses or opportunities with respect to the technology used by the Department, especially those strategies with respect to clinical documentation of hospital care, medical services, and other health care, including any clinical images and associated textual reports, furnished by the Department in facilities of the Department or non-Department facilities.

(I) Business processes of the Veterans Health Administration, including processes relating to furnishing non-Department health care, insurance identification, third-party revenue collection, and vendor reimbursement, including an identification of mechanisms as follows:

(i) To avoid the payment of penalties to vendors.

(ii) To increase the collection of amounts owed to the Department for hospital care, medical services, or other health care provided by the Department for which reimbursement from a third party is authorized and to ensure that such amounts collected are accurate.

(iii) To increase the collection of any other amounts owed to the Department with respect to hospital care, medical services, or other health care and to ensure that such amounts collected are accurate.

(iv) To increase the accuracy and timeliness of payments by the Department to vendors and providers.

(v) To reduce expenditures while improving the quality of care furnished.

(J) The purchase, distribution, and use of pharmaceuticals, medical and surgical supplies, medical devices, and health care related services by the Department, including the following:

(i) The prices paid for, standardization of, and use by, the Department with respect to the following:

(I) Pharmaceuticals.

(II) Medical and surgical supplies.

(III) Medical devices.

(ii) The use by the Department of group purchasing arrangements to purchase pharmaceuticals, medical and surgical supplies, medical devices, and health care-related services.

(iii) The strategy and systems used by the Department to distribute pharmaceuticals, medical and surgical supplies, medical devices, and health care-related services to Veterans Integrated Service Networks and medical facilities of the Department.

(K) The competency of Department leadership with respect to culture, accountability, reform readiness, leadership development, physician alignment, employee engagement, succession planning, and performance management.

(L) The effectiveness of the authorities and programs of the Department to educate and train health personnel pursuant to Section 7302 of this title.

(M) The conduct of medical and prosthetic research of the Department.

(N) The provision of assistance by the Department to Federal agencies and personnel involved in responding to a disaster or emergency.

(O) Such additional matters as may be determined relevant by the Secretary.

Deliverables:

Minimum of (14) assessments as identified in Section 194 of the Cleland-Dole Act. Assessments shall be completed within 3 months of the Contractor entering into a contract, no later than 12/31/2025.

3.5.1 REPORT WRITING

Each area of assessment will require a supporting report. Reports shall be written and updated as assessments are in progress and finalized as they’re completed. Individual assessment reports will be incorporated into a single report that will be submitted to the Secretary of VA (SECVA), the Senate Veterans Affairs Committee, and the House Veterans Affairs Committee.

Deliverable:

A. One report for each of the assessment areas outlined in Section 194 of the Cleland-Dole Act. Should the SECVA deem additional assessments necessary, additional reports will be required.

3.6 INDEPENDENT ASSESSMENT FINAL REPORT

Once assessments are received for the minimum 14 areas, the contractor shall compose a final report integrating all the individual reports and providing overall observations, findings, and recommendations that reflect an integrated enterprise perspective.

Deliverables:

A. Draft Final Report for VA comment, 60 days after the assessment has been completed.

B. Final Assessment Report for the Secretary, Federal Register, VA public-facing website, the Senate Veterans Affairs Committee, and the House Veterans Affairs Committee.

3.7 TRANSITION SUPPORT TO IPT

The Contractor shall provide transitional support to the Section 194 IPT for the purpose of facilitating the delivery and transition of the Assessment results and recommendations to the SECVA. The contractor shall provide requested clarifications concerning any questions or issues arising from the review of the assessment results.

3.8 RISK MANAGEMENT

To ensure timely and quality delivery of the independent assessment, risk management will be necessary.

Identification of risks or opportunities that may affect the project outcome or timelines.

Deliverables:

A. Development of risk management plan.

B. Risk register with risk identification and mitigation strategies along with assigned responsibilities.

C. Monthly updates, risk monitoring.

D. Risk communication plan.

*************************** End of Draft Performance Work Statement************************ THERE IS NO SOLICITATION AT THIS TIME. This request for capabilities information does not constitute a request for proposals; submission of any information in response to this market survey is purely voluntary; the government assumes no financial responsibility for any costs incurred. Your responses may be shared with all stakeholders, thus the information received will not be considered proprietary.

If your organization has the potential capacity to perform these contract services, please provide the following information:

Cover Sheet – 1 page

Please provide the following information:

1. Organization name, address, and web site.

2. Point of contact to include e-mail address and telephone number.

3. Business size (large or small). If small, please provide type of small business.

4. North American Industry Classification System (NAICS) that best fits these task areas.

5. If applicable, GSA contract number, schedule, and SIN category.

Index – 1 page

Please provide an index to assist the Government in identifying where you have addressed each question below in your Capabilities Statement and Market Information. Please provide question number and corresponding page and section heading and/or paragraph number.

Capabilities Statement and Market Information –

In addition to providing your capabilities statement and market information.

Please respond specifically to the following questions:

(1) Does your company have experience and proven outcomes in optimizing the performance of national health care delivery systems, including the Veterans Health Administration, other federal health care systems, and systems in the private, non-profit, or public health care sector? Please provide details.

(2) Does your company specialize in implementing large-scale organizational and cultural transformations, especially with respect to health care delivery systems? Please provide details and or references.

(3) Please confirm that your company is not currently under contract with the Department to provide direct or indirect patient care or related clinical care services or supplies under the laws administered by the Secretary.

(4) What similar contracts has your company performed work on in the past? Provide details of the past requirements and how your company worked to successfully complete the tasks. Please also provide contract numbers and periods of performance.

(5) Please provide a list of labor categories that you consider applicable for the tasks required in the table below.

Labor Category
Description
Years of Experience
Certifications Required
Estimated Hours

STRUCTURE AND SUBMISSION OF RESPONSES

Contractors should respond to this RFI by June 17, 2025, by 2 PM ET via e-mail to Jacky.Jean-Jacques@va.gov. Limit all responses to 5 pages.

File details come from the government source that posted it. Updated .