R607--National File Scanning Request for Information

Department of Veterans Affairs Veterans Health Administration

Health Information Management Program (HIM) Office

Performance Work Statement Attachment 1A

for the

National Health Record Document Scanning and Processing Blanket Purchase Agreement

February 2022

DRAFT DOCUMENT SUBJECT TO REVISION

Document Revision History

Mod. No.

Description of Changes

Requested By

Approved By

Date

None

Initial version (DRAFT)

E. Smith

Adam Chin

02/10/2022

Table of Contents

1.0 General 3

2.0 Specific Requirements/Tasks 8

3.0 Performance Measures and Contractor Quality Assurance 16

4.0 Delivery or Deliverables 17

5.0 Meetings 19

6.0 Required Travel and Other Direct Costs (ODCs) 19

7.0 Special Instructions 19

8.0 Government Furnished Property/Equipment/Information 19

9.0 Glossary of Abbreviations and Acronyms 20

Performance Work Statement (PWS)

ATTACHMENT 1A

for the

National Clinical Documentation Imaging Blanket Purchase Agreement

General

Introduction

The Veterans Health Administration (VHA) is the largest integrated health care system in the United States, providing care at 1,293 health care facilities, including 171 VA Medical Centers and 1,112 outpatient sites of care of varying complexity (VHA outpatient clinics) to over 9 million Veterans enrolled in the VA health care program.

The Health Information Management (HIM) Program Office, as the custodian of the health record, is responsible for assuring an accurate, timely, clinically pertinent, readily accessible health record that is maintained and retrievable for 75 years after the last date of patient activity. HIM is responsible for policy development that includes regulatory and accrediting requirements relevant to health records and is an active participant in the development of national VHA standards that impact health records and health data. The HIM Program Office also provides expertise and resources for the national HIM community around electronic health record (EHR) documentation and data capture while preserving the integrity of the health record to support direct patient care, business functions, and population health.

The intent of this acquisition is to obtain enterprise-wide services for the scanning and/or importing, indexing and incorporation of paper and electronic documents into the VHA EHR as electronic image files. Although VHA has transitioned to electronic health records, occasionally legacy paper forms and paper-based administrative and clinical workflows result in paper documentation which must be incorporated into Veterans health records. Additionally, due to Veteran eligibility for care provided outside of VA in the community, VA facilities regularly receive clinical documentation from community providers which requires incorporation into the EHR.

The BPAs are intended to augment facility clinical documentation imaging capabilities and may be used to mitigate scanning backlogs resulting from unexpected staffing shortages or process changes.

Objective

In order to provide world-class healthcare to Veterans, by ensuring an accurate, timely, clinically pertinent, readily accessible health record is maintained, VHA wishes to obtain cost-effective, enterprise-wide services for the scanning and/or importing, indexing and incorporation of paper and electronic documents into the VHA EHR as electronic image files in a manner that efficiently augments facility capabilities.

Scope of Work

Contractor shall provide all resources necessary to scan/import and accurately index designated paper and/or electronic documentation for inclusion into the EHR in accordance with VA standards and requirements. Work to be completed will involve source documentation generated by VA and/or community providers depending on each site s needs as outlined in individual task orders (TO), which will be issued at the facility level. VHA facilities may have differing processes and workflows related to document processing, so varying levels of effort shall be required for each of the facilities. All work will be completed utilizing VA approved software and depending on the site, may involve working in different EHR platforms. The volume of work may also vary in the document sets needing to be scanned at any given time, so estimates for work to be done, as well as the place of performance (either on site or remote), shall be determined at the TO level.

Services not included in this BPA are as follows:

It is not expected that special considerations shall be made for diagnostic quality imaging. The digital capture of x-rays or other diagnostic media is not within the scope of work. Digital capture of x-rays or other diagnostic media received from non-VA sources shall be sent to the Radiology Service.

Document destruction by the Contractor is not included in the scope of services.

Contractor storage of records or electronic files is not part of the BPA.

Scanning/digitizing federal agency records other than records related to the Veteran health record is not included in the scope of services in this BPA.

Scanning/digitizing clinical documents and providing image files in a shared environment outside of the medical record as the end result is not part of the BPA. Contractor shall be required to complete the scanning process for the electronic document by incorporating, indexing, and associating the scanned image with a consult (if needed) in the VA's EHR.

Definitions

Scanning/Digitizing: Converting paper records to an electronic format (TIFF, PDF, JPEG, etc.). This may be accomplished using standard national imaging software or by other VHA-approved means.

Importing: The action of bringing electronic files into standard national imaging software for inclusion into the Veteran s electronic health record.

Indexing: Applying nomenclature to the electronic file in the standard national scanning software that is used to add context and improve search functionality.

Document Set: A paper or electronic document set contains a Veteran s documents associated with a clinical visit/encounter/hospital stay or administrative form.

Example #1: A 5-page cardiology outpatient visit progress note equates to one (1) document set.

Example #2: A 20-page inpatient packet of documents for a Veteran s hospitalization inpatient stay that came from an outside hospital equates to one (1) document set.

Example #3: A 6-page advance directive form for a Veteran equates to one

document set.

Background

This procurement will replace the current BPA being utilized by VHA for medical record scanning, importing and indexing services, and VA anticipates a multiple-award BPA to be utilized nationally with 2-6 awardees depending on technical evaluations.

It should be noted that although a majority of VAMC s are currently utilizing VistA Imaging Capture and Display software, within the legacy VistA/CPRS electronic health record environment, VA is transitioning to the Cerner Millennium platform. This transition is expected to occur over several years. There is a possibility that sites requiring services under this BPA may be using either platform and differences in the workflows associated with document imaging and indexing in each platform is a consideration.

Performance Details

The Contractor shall make certain that appropriate physical care and security measures are taken to ensure that documents and health records and the VA information they contain are not damaged or compromised throughout the entire process from the point of receipt through the return shipment. The Contractor shall be compliant with all VA established security policies to ensure VA data, whether captured electronically or on paper or other media are not compromised. The Contractor shall adhere to established VA physical security policy prior to receipt and while in possession of documents and health records off and on-site.

Place of Performance

Depending on individual task orders, work may be performed entirely at a government facility (on site); partially at the Contractor s primary facility, and partially at other locations or facilities (off-site, remotely); within the United States and its territories. If performed at a government facility, work will only be completed on days on which government operations are being conducted and as authorized by the facility Contracting Officer Representative (COR).

Applicable Documents

In the performance of the tasks associated with this PWS, the Contractor shall comply with the following:

44 U.S.C. § 3541, Federal Information Security Management Act (FISMA) of 2002 https://csrc.nist.gov/publications/detail/fips/201/2/final

FIPS Pub 201-2, Personal Identity Verification of Federal Employees and Contractors, August 2013; https://nvlpubs.nist.gov/nistpubs/FIPS/NIST.FIPS.201-2.pdf

5 U.S.C. § 552a, as amended, The Privacy Act of 1974 ; https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title5- section552a&num=0&edition=prelim

Health Insurance Portability and Accountability Act (HIPAA); 45 Code of Federal Records (CFR) Part 160, 162, and 164; Health Insurance Reform: Security Standards; Final Rule dated February 20, 2003.

VHA Directive 1907.01, Health Information Management and Health Records, April 5, 2021; https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=9235

VHA Handbook 1907.07, Management of Health Records File Room and Scanning, May 12, 2016; https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=3201

VHA HIM Practice Brief, Office of Community Care VistA Imaging Capture Best Practice and Minimum Documentation Requirements, March 2021

Records Control Schedule (RCS) 10-1; https://www.va.gov/vhapublications/RCS10/rcs10-1.pdf

VHA System of Records Notice (SORN) "24VA10A7, Patient Medical Records-VA, Record Retention Specification; https://www.federalregister.gov/documents/2015/07/30/2015-18646/privacy- act-of-1974-system-of-records

VistA Imaging System Clinical Capture User Manual, Revision 9, November 2017; https://www.va.gov/vdl/documents/Clinical/Vista_Imaging_Sys/mag_capture_u ser_manual.pdf

VA Directive 0710, VHA Personnel Security and Suitability Program, October 11, 2018; https://vaww.va.gov/vapubs/viewPublication.asp?Pub_ID=487&FType=2

VA Handbook 0710, Personnel Security and Suitability Program, May 2, 2016; https://vaww.va.gov/vapubs/viewPublication.asp?Pub_ID=832&FType=2

VA Directive 6102, Internet and Intranet Services, August 5, 2019; https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=1056&FType=2

36 C.F.R. Part 1194 Electronic and Information Technology Accessibility Standards, July 1, 2011; CFR-2011-title36-vol3-part1194.pdf (govinfo.gov)

An Introductory Resource Guide for Implementing the Health Insurance Portability and Accountability Act (HIPAA) Security Rule, October 2008; https://csrc.nist.gov/publications/detail/sp/800-66/rev-1/final

VA Directive 6500, VA Cybersecurity Program, February 24, 2021; https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=1254&FType=2

VA Handbook 6500, Risk Management Framework for VA Information Systems VA Information Security Program, February 24, 2021; https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=1255&FType=2

VA Handbook 6500.6, Contract Security, March 12, 2010; https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=471&FType=2

VA Handbook 6500.8, Information System Contingency Planning , April 6, 2011; https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=542&FType=2

VA Directive 6300, Records and Information Management, September 21, 2018; https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=997&FType=2

VA Handbook, 6300.1, Records Management Procedures, March 24, 2010; https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=34&FType=2

NIST Special Publication 800-116 Revision 1 Guidelines for the Use of PIV Credentials in Facility Access, June 2018; https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-116r1.pdf

OMB Memorandum M-07-16, Safeguarding Against and Responding to the Breach of Personally Identifiable Information, May 22, 2007; https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/200 7/m07-16.pdf

VA Memorandum, VAIQ # 7011145, VA Identity Management Policy, June 28, 2010 (reference Enterprise Architecture Section, PIV/IAM (reference https://www.voa.va.gov/documentlistpublic.aspx?NodeID=514)

Office of Information Security (OIS) VAIQ #7424808 Memorandum, Remote Access , January 15, 2014, https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28

Proper use of Email and Other Messaging Services; https://www.voa.va.gov/DocumentView.aspx?DocumentID=4847

aa. VA Memorandum, Implementation of Federal Personal Identity Verification (PIV) Credentials for Federal and Contractor Access to VA IT Systems , (VAIQ# 7614373) July 9, 2015;

https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28

bb. VA Memorandum Mandatory Use of PIV Multifactor Authentication to VA Information System (VAIQ# 7613595), June 30, 2015; https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28

cc. VA Memorandum Mandatory Use of PIV Multifactor Authentication for Users with Elevated Privileges (VAIQ# 7613597), June 30, 2015; https://www.voa.va.gov/DocumentListPublic.aspx?NodeId=28

dd. Sections 504 and 508 of the Rehabilitation Act (29 U.S.C. § 794d), as amended by the Workforce Investment Act of 1998 (Public Law (P.L.) 105-220), August 7, 1998

ee. Homeland Security Presidential Directive (12) (HSPD-12)

ff. National Bureau of Standards and Technology (NBS) SP500-153, Guide to Auditing for Controls and Security: A System Development Life-Cycle Approach,

April 1988

gg. Federal Travel Regulation (FTR) https://www.gsa.gov/cdnstatic/FTR_Amdt_2020-03.pdf

Specific Requirements/Tasks

General

The Contractor shall provide, at a minimum, all tasks and deliverables described within this document and BPA orders placed against this BPA. All deliverables shall be submitted to the local Ordering Officer (OO) and local Contracting Officer Representative (COR), in accordance with each individual BPA order. Unless otherwise stipulated, written deliverables shall be phrased in plain English. Statistical and technical terminology shall not be used without providing a glossary of terms.

The Contractor shall provide any specialized management, labor, resources, computer software, equipment needed to provide Scanning and/or Importing and Indexing of Records, and Project Management based on specific task order requirements. The Contractor shall define a VA-approved project workflow that shall not impede the day-to-day operations of the specific department. Working parameters and workspace shall be delineated per facility.

The individual BPA Orders shall specify the expected turnaround time for each ordered service and any facility specific standards. When the Contractor cannot meet specified deadlines, they must inform the local facility COR immediately. If the Contractor is uncertain concerning a policy or procedure, the Contractor shall consult with the local facility COR for clarification.

The Contractor is responsible for the management of contract staff and responsible for training new Contract staff (including subcontractors, if applicable) on Veterans Affairs policy and procedures, and ensure completion of any Veterans Affairs mandatory training, security clearances, or other tasks required for Contractor staff to perform the services outlined in this PWS. Each facility shall provide the Contractor with a high-level explanation of the clinical document imaging processes including any unique facility indexing requirements. The Contractor shall bear the costs of any other training. The Contractor is responsible for performing quality reviews of staff work. The Contractor shall bear the cost of any re-work and/or corrections that are required due to Contractor error, and take corrective action when services are found deficient or substandard.

The Contractor shall attend a kick-off meeting within five (5) business days after BPA award date. BPA Order kick-off meetings shall be addressed in each individual order. The Contractor shall perform the tasks and complete the associated deliverables by the scheduled dates within the overall period of performance of the related order.

Scanning and/or Importing and Indexing of Medical Records

Scanning and/or Importing and Indexing of Records may be performed on-site (i.e., at the VA facility), or by using a combination of on-site and off-site processing (e.g., scanning/digitizing paper documents at the VA facility, and then indexing and importing the resulting electronic file from an off-site location). The physical location of where documents are processed by the Contractor, along with the format of the documents (i.e., paper or electronic) will determine pricing under the BPA.

Documentation to be scanned and/or imported and indexed may include internal VA- generated documents, or documents from external sources. The format of the documents shall be either paper or an electronic file and shall be identified in each individual task order. The document types are categorized as follows:

Community Care (OCC) Document Type Scanning/Importing/Indexing

Includes Clinical documentation from outside providers paid for by VA. Community Care clinical documents will need to be associated with facility- specific community care progress note titles. Ordering facility is responsible for identifying and communicating to Contractor where processed images will be attached in the health record. Examples include:

Community Care clinical document with consult request association and consult result note creation.

Community Care clinical document without consult request association.

Unauthorized inpatient hospitalization and emergency room care covered under Millennium Bill (Mill Bill).

Outside Clinical Document Type Scanning/Importing/Indexing (Non-OCC)

Clinical document from outside provider not paid for by VA. VA providers request for these document types to be incorporated into the Veteran s health record due to clinical relevance and continuity of care.

Outside clinical documents may need to be associated with facility-specified progress note titles or episodes of care. Ordering facility is responsible for identifying and communicating to Contractor where processed images will be attached in the health record.

VA-Generated Document Type Scanning/Importing/Indexing

These documents are incorporated into the Veteran s health record based on clinical or administrative relevance. Examples include:

VHA generated administrative documents

VHA generated clinical document or image

STAT Importing/Indexing

Contractor shall provide STAT (STAT- requires immediate or without delay) scanning, importing, and indexing of documents when requested by facility. STAT scanning is defined by a turnaround time of less than 1 hour of receipt of request during normal business hours. Business hours shall be defined by the local BPA Order. STAT scanning/importing shall be a separate production CLIN document type and will only include electronic documents processed off-site.

General Scanning, Importing and Indexing of Records Requirements

Contractor shall be required to scan documents with a minimum resolution of 300 x 300 dots per inch (dpi) and ensure that images are correctly indexed, oriented, legible, and complete, including signature by the originating provider. Scanned documents may be scanned in black/white, gray scale, true color (24-bit), or 256 colors (8-bit), depending on the type of document. Individual BPA Orders shall specify requirements. X-rays shall not be scanned, however, photographs (e.g., Polaroid s, etc.) shall be scanned.

Contractor may be required to manipulate pdf and image file formats in order to rotate, remove, and re-order pages.

Some VA facilities may use a vendor product, secured portal or secured messaging during the document imaging process (i.e., document retrieval). If a vendor product, portal, or secured messaging is used, the facility shall provide the guidance/policy on the requirements for using the program.

Whether scanning or importing, the Contractor shall incorporate the documents into standard national imaging software by applying the appropriate index terms. The local facility shall provide the Contractor with guidance to identify and assign indexing values for all document types.

The Contractor shall create progress notes to link scanned or imported clinical documents. When Contractor creates a consult result note, the Contractor shall locate the associated consult request in the EHR and link the consult result note to the appropriate consult request.

The Contractor shall review all document sets individually prior to scanning and/or importing to identify the type of document and perform the following:

The Contractor shall review the EHR and determine if the document has previously been scanned/imported. If the document is a duplicate, it will not be scanned by the Contractor.

Determine the correct indexing values. To ensure accurate indexing, the local facility COR shall work with the Contractor to identify document index terms and shall update the indexing reference list accordingly as new document index terms become available.

Although checking the medical record for duplicate images prior to scanning is required by Contract staff as part of the imaging process, VA staff will make every effort to ensure documents that already exist in the EHR are not provided to the Contractor for processing. Handling and identification of duplicate documentation by Contractor as a separate function is not within scope of this BPA and should not be invoiced separately by the Contractor.

For paper records, Contractor shall perform the following items: remove staples, ensure document is flat, pages are sequenced in order, all pages are present, document is not torn and if so, repair it, all pages are for the correct patient, document is authenticated (i.e., signed), etc.

For electronic records importing, the Contractor shall perform the following items: pages are sequenced in order; all pages are present, pages are readable; page orientation is accurate, etc. The Contractor shall complete the task in a manner that ensures they meet the stated performance metrics indicated in the QASP.

Scanned documents shall be an exact replica of the original document.

The Contractor shall make every attempt to identify unclear information and, and as necessary, request assistance/clarification from the facility point of contact specified in the BPA task order.

Each VA facility shall identify and provide the records/documents to be scanned, imported, and indexed.

VA staff are responsible for identifying and communicating to the Contractor where in the EHR processed images will be associated, attached, or linked. This includes providing specific guidance as to what EHR document, consult, or referral a processed image needs to be associated or linked with when required (e.g., to close out Community Care consults/referrals, etc.). Contract personnel performing this function is not within scope of this BPA.

Contractor shall verify that the documents meet specified VHA scanning or importing criteria prior to incorporating into the EHR.

Contract staff performing scanning, importing, and indexing functions shall perform two self-quality checks on 100% of documents in accordance with VHA policy. The cost of Contractor personnel performing self-quality checks shall be incorporated in the production CLINs for each scanned/imported and indexed document type.

The first quality check shall be performed at the time when the scanned document or electronic file has been imported into Standard national imaging software but not yet incorporated into the Veteran s health record. The image shall be checked

for the overall quality and visibility of the document. The Contractor personnel shall be responsible for reviewing each image, to make sure that the demographic information is correct on every page, the image is positioned as correctly as possible, and that all pages of documents have been captured in VistA Imaging, which may include blank pages when applicable. This shall require comparing the source document to the content that has been scanned or imported into Standard national imaging software.

The second quality check of the scanned document must be verified by logging into VistA Imaging Display after the document has been incorporated into the health record. The Contractor personnel scanning or importing the document shall perform both processes. These checks shall be performed on 100 percent of the documents scanned. Items reviewed during the second quality check shall include the following:

Scanned to correct patient

Correct title/x-ray exam/admin indexing used

Linked to the correct consult when appropriate

Correct additional signers identified when appropriate

Required identifying information on all pages scanned (i.e., patient name, date of birth, etc.).

Progress note entered correctly (containing required information)

Indexed per procedure

Image legible

Image oriented in CPRS

Contract staff shall report any identified quality errors immediately to the Contractor manager/supervisor. In turn, the Contractor manager/supervisor shall notify local VA facility POC of quality error for medical record correction within the timeframe determined by the local BPA Order.

The Contractor manager/supervisor shall perform random Quality Assurance (QA) monitoring of staff work and report results of QA monitoring to the designated VA representative at the interval (daily/weekly/monthly) specified in the facility BPA Order. Any identified errors shall be reported and remediated with the facility POC.

Contractor shall return documents to VA s custody for additional quality assurance monitoring and disposition. Destruction services by the Contractor are not required nor authorized.

Deliverables:

Production CLINs for scanning, importing and indexing documents by document types are as followed:

CLIN

Service

Format

Location

TAT

Unit

Note

X0001

Prep/Scan/Import/Index (E2E)

Paper

On-Site

Routine

Document Set

X0002

Prep/Scan/Import/Index (E2E)

Paper

Hybrid

Routine

Document Set

Hybrid' indicates Prep/Scanning takes place at VAMC; uploading and indexing done off-site.

X0003

Document Prep/Scan ONLY

Paper

On-Site

Routine

Document Set

No separate pricing for STAT documents processed on-site.

X0004

Import and Indexing ONLY

Electronic

On-Site

Routine

Document Set

X0005

Import and Indexing ONLY

Electronic

Off-Site

Routine

Document Set

X0006

Import and Indexing ONLY

Electronic

Off-Site

STAT

(