VA Reno Replacement of Patient Food Trayline

PRE-SOLICITATION NOTICE OF INTENT TO SOLE SOURCE Department of Veterans Affairs (VA) Network Contracting Office (NCO 21) intends to award a sole source, firm fixed price contract to Gill Group Inc. for Brand Name Burlodge POD Style Trayline System. The procurement is on behalf of the Department of Veterans Affairs, Veterans Health Administration, Regional Procurement Office West (RPOW), Network Contracting Office (NCO) 21, on behalf of VA SIERRA NEVADA. VA s Gray Market Items terms and conditions apply pursuant to VAAR 852.212-71 Gray Market Items and VAAR 852.212-72 Gray Market and Counterfeit Items. As a result, vendor shall be an OEM, authorized dealer, authorized distributor or authorized reseller for the items identified to be eligible for participation with this acquisition. Vendor must be able to provide the documentation that demonstrates such aforementioned authority. The solicitation for this action will be posted to beta.sam.gov and all responsible sources may submit a capability statement, proposal, or quotation, which shall be considered by the agency. After consideration, the Government will determine whether to proceed with the sole source acquisition. Please keep in mind that patient care and choice in the decision is the highest priority to the VA. The solicitation will be posted on or about February 7, 2023. Please respond to contact@example.gov no later than Monday, February 6th, 2023 at 10:00 am Pacific time. With your response, please provide evidence showing compliance with the aforementioned Gray Market clauses. Failure to provide the required information may result in a determination that your company is not a viable source. VA Sierra Nevada Healthcare System Nutrition and Food Services 975 Kirman Ave Reno, NV 89502 STATEMENT OF WORK GENERAL GUIDANCE Title of Project - Kitchen and Trayline Remodel Background Nutrition and Food Services relies on the use of specialized equipment to assemble Veteran patient meals trays. The purpose of this contract request is to replace our traditional trayline to the current standard of a POD style tray assembly system and replace our old/out of date equipment that is frequently in need of repair. This equipment is used a minimum of three times a day every day of the year, assuring accuracy and efficiency in tray assembly. Additionally, the equipment assures that food is kept at the correct and safe temperature for food safety and Veteran patient satisfaction as well as providing the necessary tools for the transition to a full room service operation. Existing equipment no longer meets the needs of Nutrition and Food Services. The patient menu will be changed from offering convenience/premade items, to over 90% of the items offered being scratch made and made to order. Also, the trayline was not built for a room service assembly/delivery method. Nor does it have the capability of being reconfigured to fit our current type of service, as the trayline was built as one unit. This has created wasted motion and efficiency, having a negative effect on employee satisfaction, and causing delays in Veterans receiving their meal trays. Scope of Work Procure POD style tray assembly line, and kitchen equipment, based on specifications listed below. Contract must include all equipment, removal/discard of existing trayline equipment, and electrical preparation work to facility to meet the needs of the awarded equipment (noted below in specifications). It must also include equipment installation and staff training. All work must be completed within 14 calendar days (including weekends/nights) of starting to minimize Veteran/patient impact. Requirements, Deliverable, Salient Characteristics and Specifications Must have all of the pieces below to create fully functioning systems. Must fit in existing kitchen space Must have capacity to assemble 100 trays/hour with 4 or fewer staff members Demo/electrical/installation/equipment must all be provided by one vendor. Once work commences, all work must be completed within 14 calendar days (includes weekend/evenings) 3 Gravity Shelves: Unit size: 30-32 wide, 24-26 deep, 69 high Shelf size: 26-28 wide, 18-22 deep (to fit a full size sheet pan) Must have a minimum of 4 shelves Shelves must tilt by raising the back of the shelf 5-7 from horizontal so that products self face / gravity feed to the front of the shelf Must have 7-9 spacing between shelves Must have adjustable divider bars to separate stocked products Must be on wheels, with swivel casters and brakes Safety feature: must have a stopper to prevent back of shelf from falling below horizontal 1 Ambient Slider Table: Unit Size: 60 wide, 21-24 deep, 36 tall Must have internal product storage capacity Must have tray slides that accommodate 15x20 trays and allow trays to slide/be pushed from end to end of table without employee lifting Must have an open top to allow employee to reach in to retrieve products Must have baskets that fit inside unit to store/stock products Must have self-leveling riser(s) to raise baskets/product up within unit Storage space must be a minimum of 21 deep. Must have a drain hole Must be on wheels, with swivel casters and brakes 1 Refrigerated Tray Table: Unit size: 75 wide, 23 deep, 36 tall Must have internal product storage capacity Must be refrigerated to temperatures below 41 degrees Fahrenheit Must have tray slides that accommodate 15x20 trays and allow trays to slide/be pushed from end to end of table without employee lifting Must have an open top to allow employee to reach in to retrieve products Must have an open front to allow for stocking of products Must have baskets that fit inside unit to store/stock products Storage must be a minimum of 21 deep Must be on wheels, with swivel casters and brakes 1 Slider Table Connector w/ Mobile Tray Dispenser: Unit size: 19 wide, 32 deep, 38 tall Must fit in line before refrigerated tray table Must hold between 100-150 15x20 trays Must be able to dispense trays without the user bending, twisting or stooping Must be on wheels, with swivel casters and brakes 2 Refrigerators: Unit size: 26-30 wide, 36-40 deep, 70-80 tall, 30-35 Cubic Foot capacity Electrical requirements: 120 volt, 20 amp breaker, NEMA 5-20R Air curtain Refrigerators with both front (stainless steel) and rear (glass) doors Must have stainless steel interior and exterior Must have at least 4 shelves that tilt by raising the back of the shelf 5-7 from horizontal so that products self face / gravity feed to the front of the shelf Must have back door with minimum of 270* door swing Must have front door that opens to 90* and slides parallel to the body of the unit (remain open during service without obstructing trayline). then slides along the body of the unit so it can remain open without obstructing can be tucked parallel and next to body of unit when opened at 90* Front door must swing to clear minimum 36 height when opened Must be on wheels, with swivel casters and brakes 1 Hot Food Server: Unit size: 83 long, 30-32 deep, 35-37 tall Electrical: 208v/3ph 30 amp breaker Five hot wells to hold full size 12 x20 hotel pan Lower base area open for storage All wells with individual drains that connect to single spigot and hose to route to floor drain Each well individually temperature controlled Must be on wheels, with swivel casters and brakes 1 Hot Food Server: Unit size: 46 long, 30-32 deep, 35-37 tall Electrical: 208v/3ph 30 amp breaker Three hot wells to hold full size 12 x20 hotel pan Lower base area open for storage All wells with individual drains that connect to single spigot and hose to route to floor drain Each well individually temperature controlled Must be on wheels, with swivel casters and brakes 1 Countertop Electric Griddle: Unit size: 48 wide, 24 deep Electrical: 208v/60/3-ph, 67.4 amps ¾ thick composite griddle plate with stainless steel cooking surface Bottom mounted snap action thermostat every 12 Stainless steel front, sides, front top ledge, front grease trough 4 back & tapered side splashes 4 adjustable legs 1 Electric Kettle Cabinet Assembly: Unit size: 50 wide, 24 deep, 51 tall Electrical: 2 units requiring 208v/50/60/3-ph, 22 amps each 2 Tilting, 6 gallon kettles 50 wide stand Full length drain trough Dual temperature Pantry deck mounted faucet, 18 double jointed swivel spout 6 gallon stainless steel cover 1 Countertop Induction Range: Unit size: 24 wide, 30 deep, 14 high Electrical: 2 units requiring 208-240v/50/60/1ph, 24 amps, NEMA 6-30P Induction range, countertop with 4 rotary dial controls 100-400 degree Fahrenheit temperature range 1-180 minute timer function 1 Refrigerated/Freezer Equipment Stand: Unit size: 76 wide, 36 deep, 23 tall Electrical: 2 units requiring 115v/60/1-ph, 1.7 amps, NEMA 5-15P each 6.0 cubic feet flexible refrigerator or freezer chef stand 2 drawers with removable ABS insert Self-contained refrigeration systems with electronic control (-5 to 40 degrees Fahrenheit) Must be on wheels, with swivel casters and brakes R290 hydrocarbon refrigerant 1 Support: In person/onsite Training & Implementation Multiple trainings must be provided on various days and times in order to reach the majority of Food Service staff. Installation: Scope of work: All work must be completed within 14 calendar days (including weekends/nights) of starting Removal of the existing tray-line system. Includes disposal to back dock, and into provided dumpster (vendor to provide the dumpster) Uncrate and set in place new equipment. Includes disposal to back dock, and into provided dumpster (vendor to provide the dumpster) Required site visit to assess existing equipment and total electrical needs. Electrical: All electrical must comply with all applicable electrical standards including National Electric Code. Install new 100 Amp 3 phase 120/208-volt NEMA 3R panel and extend existing panel feed to new location to be determined by others. Install all necessary electrical from new panel to new tray line as needed. Install ten drop cords with wet location boxes, locations to be determined by others. Existing equipment: Trayline: 1x base chargers: 208/240 VAC, 60Hz, 3 phase, minimum circuit ampacity: 30A, load amperage: 24A, wire: 4 (3W+ground) 1x plate warmers 208/220 VAC, 60 Hz, 20 amp power cord with NEMA 6-20P plug, 2 wire + ground 208V, 240V, Single Phase, 15.9 Amps, 60HZ, 3 wire, 6-20P plug 2x toasters 120V, 13.8 Amp Beverage Area: 1x Hot Chocolate Dispenser: 120 VAC, 1 PH, 60 Hz, 7.2A 1x Iced Tea Dispenser: No electrical needed 1x Coffee Dispenser: 230V, 60Hz, 1 Ph, 5.3kW, 23.8A Delivery Location: All Items shall be shipped to the customer at the following location: VA Sierra Nevada Healthcare System 975 Kirman Ave. Reno NV 89502 Delivery Requirements: The Vendor shall notify the COR to plan the delivery date. This notification shall be provided at least one month prior to the vendor-anticipated delivery date. The Vendor shall plan and coordinate with the COR, Nutrition and Food Services Supervisors, Logistics/Warehouse. Contract Award Meeting This will be determined as needed by the Project/Program Manager and COR. Confidentiality and Nondisclosure It is agreed that: a. The preliminary and final deliverables, and all associated working papers, application source code, and other material deemed relevant by VA which have been generated by the contractor in the performance of this task order, are the exclusive property of the U.S. Government and shall be submitted to the CO at the conclusion of the task order. b. The CO will be the sole authorized official to release, verbally or in writing, any data, draft deliverables, final deliverables, or any other written or printed materials pertaining to this task order. No information shall be released by the contractor. Any request for information relating to this task order, presented to the contractor, shall be submitted to the CO for response. c. Press releases, marketing material, or any other printed or electronic documentation related to this project, shall not be publicized without the written approval of the CO. Contractor Personnel Security Requirements Equipment is for food service production. VA information is not collected or stored. The contractor employees shall not have access to VA sensitive or computer information and will not require routine access to VA Facilities. The contractor employees shall require intermittent access only and will be escorted by VA employees while at VA Facilities. No background investigation is required. 10. Government Furnished Property and Other Resources a. The Government will provide only the property which is required to configure a suitable workstation and office environment for assigned personnel to include but not limited to office furniture, telephone, computer, and communications/dispatch devices as applicable. b. Supervisory Controls: The day-to-day supervision and direct control over the work performed by on-site contractor personnel will be the sole responsibility of the Prime contractor. All tasks are provided by the Government for the contractor for execution. The contractor works independently and keeps the COR informed of all actions assigned. All assignments will be completed in a timely fashion. Work will be reviewed for compliance with policy, overall objectives and effectiveness in achieving results by the COR. 11. Security Requirements for Unclassified Information Technology Security Resources a. The contractor and their personnel shall be subject to the same Federal laws, regulations, standards and VA polices as VA personnel, regarding information and information system security. These include but are not limited to Federal Information Security Management Act (FISMA), Appendix III of OMB Circular A-130, and guidance and standards, available from the Department of Commerce s National Institute of Standards and Technology (NIST). This also includes the use of common security configuration available from NIST s Web site at: http://checklists.nist.gov. b. To ensure that appropriate security controls are in place, contractors must follow the procedures set forth in VA Information and Information System Security/Privacy Requirements for IT Contractors located at the following site: http://www.iprm.oit.va.gov. c. These provisions shall apply to all contracts in which VA sensitive information is stored, generated, transmitted, or exchanged by VA, a contractor, subcontractor or a third-party, or on behalf of any of these entities regardless of format or whether it resides on a VA system or contractor/subcontractor s electronic information system(s) operating for or on the VA behalf. Access to VA Information and VA Information Systems a . A contractor/subcontractor shall request logical (technical) or physical access to VA information and VA information systems for their employees, subcontractors, and affiliates only to the extent necessary to perform the services specified in the contract, agreement, or task order. b. All contractors, subcontractors, and third-party servicers and associates working with VA information are subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations, Security, and Preparedness is responsible for these policies and procedures. c. The contractor or subcontractor must notify the COR immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the contractor or subcontractor s employ. The COR must also be notified immediately by the contractor or subcontractor prior to an unfriendly termination. 13. VA Information Custodial Language a. Information made available to the contractor or subcontractor by VA for the performance or administration of this contract or information developed by the contractor/subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of the VA. This clause expressly limits the contractor/subcontractor's rights to use data as described in Rights in Data - General, FAR 52.227-14(d) (1). b. VA information should not be co-mingled, if possible, with any other data on the contractors/subcontractor s information systems or media storage systems in order to ensure VA requirements related to data protection and media sanitization can be met. If co-mingling must be allowed to meet the requirements of the business need, the contractor must ensure that VA s information is returned to the VA or destroyed in accordance with VA s sanitization requirements. VA reserves the right to conduct on-site inspections of contractor and subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures are in compliance with VA directive requirements. c. Prior to termination or completion of this contract, contractor/subcontractor must not destroy information received from VA, or gathered/created by the contractor in the course of performing this contract without prior written approval by the VA. Any data destruction done on behalf of VA by a contractor/subcontractor must be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management and its Handbook 6300.1 Records Management Procedures, applicable VA Records Control Schedules, and VA Handbook 6500.1, Electronic Media Sanitization. Self-certification by the contractor that the data destruction requirements above have been met must be sent to the COR within 30 days of termination of the contract. d. The contractor/subcontractor must receive, gather, store, back up, maintain, use, disclose and dispose of VA information only in compliance with the terms of the contract and applicable Federal and VA information confidentiality and security laws, regulations and policies. If Federal or VA information confidentiality and security laws, regulations and policies become applicable to the VA information or information systems after execution of the contract, or if NIST issues or updates applicable FIPS or Special Publications (SP) after execution of this contract, the parties agree to negotiate in good faith to implement the information confidentiality and security laws, regulations and policies in this contract. e. The contractor/subcontractor shall not make copies of VA information except as authorized and necessary to perform the terms of the agreement or to preserve electronic information stored on contractor/subcontractor electronic storage media for restoration in case any electronic equipment or data used by the contractor/ subcontractor needs to be restored to an operating state. If copies are made for restoration purposes, after the restoration is complete, the copies must be appropriately destroyed. f. If VA determines that the contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be sufficient grounds for VA to withhold payment to the contractor or third party or terminate the contract for default or terminate for cause under Federal Acquisition Regulation (FAR) part 12. g. In accordance with 45 CFR 164.502(e), the Privacy Rule includes exceptions to the Business Associate Standard. This requirement meets the exception and does not require a Business Associate agreement in order for Covered Entity to disclose Protected Healthcare Information to the contractor for treatment. h. The contractor/subcontractor must store, transport, or transmit VA sensitive information in an encrypted form, using VA-approved encryption tools that are, at a minimum, FIPS 140-2 validated. i. The contractor/subcontractor s firewall and Web services security controls, if applicable, shall meet or exceed VA s minimum requirements. VA Configuration Guidelines are available upon request. j. The records created in accordance with this contract belong to the VASNHS and should be returned to the VASNHS and/or destroyed in accordance with VHA RCS 10-1. Destruction should only occur with advance notice and guidance from the Records Management Officer at the VASNHS. Records shall be safeguarded in accordance with the Privacy Act, Health Insurance Portability and Accountability Act (HIPAA) and the VASNHS Release of Information Unit. Patient Medical information is considered privileged and shall not be disclosed or revealed in any way without prior written permission from the VA Chief, Health Information Management Section. k. The Contractor shall only release medical information obtained during the course of this contract to those VA staff members involved in the necessary management and treatment of that individual patient. Patient list and name of patients are considered privileged information and shall not be disclosed or revealed in any way for use outside the Contractor without prior written permission from the referring VA Chief of Staff. Veterans requesting copies of medical information generated by the contractor will be referred to the VASNHS Release of Information Unit. l. Except for uses and disclosures of VA information authorized by this contract for performance of the contract, the contractor/subcontractor may use and disclose VA information only in two other situations: (i) in response to a qualifying order of a court of competent jurisdiction, or (ii) with VA s prior written approval. The contractor/ subcontractor must refer all requests for, demands for production of, or inquiries about, VA information and information systems to the VASNHS Release of Information Unit for response. m. Notwithstanding the provision above, the contractor/subcontractor shall not release VA records protected by Title 38 U.S.C. 5705, confidentiality of medical quality assurance records and/or Title 38 U.S.C. 7332, confidentiality of certain health records pertaining to drug addiction, sickle cell anemia, alcoholism or alcohol abuse, or infection with human immunodeficiency virus. If the contractor/subcontractor is in receipt of a court order or other requests for the above mentioned information, that contractor/ subcontractor shall immediately refer such court orders or other requests to the VASNHS Release of Information Unit for response. n. All electronic storage media used on non-VA leased or non-VA owned IT equipment that is used to store, process, or access VA information must be handled in adherence with VA Handbook 6500.1, Electronic Media Sanitization upon: (i) completion or termination of the contract or (ii) disposal or return of the IT equipment by the contractor/subcontractor or any person acting on behalf of the contractor/subcontractor, whichever is earlier. Media (hard drives, optical disks, CDs, back-up tapes, etc.) used by the contractors/subcontractors that contain VA information must be returned to the VA for sanitization or destruction or the contractor/subcontractor must self-certify that the media has been disposed of per 6500.1 requirements. This must be completed within 30 days of termination of the contract. o. The C&A requirements do not apply, and that a Security Accreditation Package is not required. p. Ensure that a Contractor Security Control Assessment (CSCA) is completed within 30 days of contract approval and yearly on the renewal date of the contract. q. Ensure that the CSCA is sent to the ISO and the OCS Certification Program Office for review to ensure that appropriate security controls are being implemented in service contracts. r. Ensure a copy of the CSCA is maintained in the Security Management and Reporting Tool (SMART) database. COR will provide a copy of the completed CSCA to ISO for uploading into SMART database. 14. Health Insurance Portability and Accountability Act (HIPAA) Contractor shall take reasonable measures to ensure patient privacy and confidentiality. The contractor agrees to take all reasonable precautions to safeguard patient information from unauthorized access or modification, in both electronic and hard-copy formats. This includes not only electronic security measures such as strong user passwords on computer systems, but also physical barriers to prevent unauthorized use of computer work-stations; that hard copy patient files are in secured lockable areas, that files are in lockable cabinets, that the cabinets can in fact be locked, i.e., keys are available, and the locking mechanisms work properly. This precaution also includes the proper transfer of patient information via electronic means, such as faxing or system to system transmission. That only the minimum necessary patient information is used to provide appropriate service to the correct patient. That the undersigned understands that all parties are bound by the requirements of the Health Insurance Portability and Accountability Act of 1996 which provide guidance on the protection of patient privacy and confidentiality. This Act mandates that all government agencies, and those bodies with whom they contract, must be in compliance with the directives of the Act. 15. Security Incident Investigation a. The term security incident means an event that has, or could have, resulted in unauthorized access to, loss or damage to VA assets, or sensitive information, or an action that breaches VA security procedures. The contractor/subcontractor shall immediately notify the COR and simultaneously, the designated ISO and Privacy Officer for the contract of any known or suspected security/privacy incidents, or any unauthorized disclosure of sensitive information, including that contained in system(s) to which the contractor/subcontractor has access. b. To the extent known by the contractor/subcontractor, the contractor/subcontractor s notice to VA shall identify the information involved, the circumstances surrounding the incident (including to whom, how, when, and where the VA information or assets were placed at risk or compromised), and any other information that the contractor/ subcontractor considers relevant. c. With respect to unsecured protected health information, the business associate is deemed to have discovered a data breach when the business associate knew or should have known of a breach of such information. Upon discovery, the business associate must notify the covered entity of the breach. Notifications need to be made in accordance with the executed business associate agreement. d. In instances of theft or break-in or other criminal activity, the contractor/subcontractor must concurrently report the incident to the appropriate law enforcement entity (or entities) of jurisdiction, including the VA OIG and Security and Law Enforcement. The contractor, its employees, and its subcontractors and their employees shall cooperate with VA and any law enforcement authority responsible for the investigation and prosecution of any possible criminal law violation(s) associated with any incident. The contractor/subcontractor shall cooperate with VA in any civil litigation to recover VA information, obtain monetary or other compensation from a third party for damages arising from any incident, or obtain injunctive relief against any third party arising from, or related to, the incident. 16. Liquidated Damages For Data Breach a. Consistent with the requirements of 38 U.S.C. §5725, a contract may require access to sensitive personal information. If so, the contractor is liable to VA for liquidated damages in the event of a data breach or privacy incident involving any SPI the contractor/subcontractor processes or maintains under this contract. b. The contractor/subcontractor shall provide notice to VA of a security incident as set forth in the Security Incident Investigation section above. Upon such notification, VA must secure from a non-Department entity or the VA Office of Inspector General an independent risk analysis of the data breach to determine the level of risk associated with the data breach for the potential misuse of any sensitive personal information involved in the data breach. The term 'data breach' means the loss, theft, or other unauthorized access, or any access other than that incidental to the scope of employment, to data containing sensitive personal information, in electronic or printed form, that results in the potential compromise of the confidentiality or integrity of the data. Contractor shall fully cooperate with the entity performing the risk analysis. Failure to cooperate may be deemed a material breach and grounds for contract termination. c. Each risk analysis shall address all relevant information concerning the data breach, including the following: Nature of the event (loss, theft, unauthorized access); Description of the event, including: (a) date of occurrence; (b) data elements involved, including any PII, such as full name, social security number, date of birth, home address, account number, disability code; (c) Number of individuals affected or potentially affected; (d) Names of individuals or groups affected or potentially affected; (e) Ease of logical data access to the lost, stolen or improperly accessed data in light of the degree of protection for the data, e.g., unencrypted, plain text; (f) Amount of time the data has been out of VA control; (g) The likelihood that the sensitive personal information will or has been compromised (made accessible to and usable by unauthorized persons); (h) Known misuses of data containing sensitive personal information, if any; (i) Assessment of the potential harm to the affected individuals; (j) Data breach analysis as outlined in 6500.2 Handbook, Management of Security and Privacy Incidents, as appropriate: and (k) Whether credit protection services may assist record subjects in avoiding or mitigating the results of identity theft based on the sensitive personal information that may have been compromised. d. Based on the determinations of the independent risk analysis, the contractor shall be responsible for paying to the VA liquidated damages in the amount of $37.50 per affected individual to cover the cost of providing credit protection services to affected individuals consisting of the following: (1) Notification; (2) One year of credit monitoring services consisting of automatic daily monitoring of at least 3 relevant credit bureau reports; (3). Data breach analysis; (4). Fraud resolution services, including writing dispute letters, initiating fraud alerts and credit freezes, to assist affected individuals to bring matters to resolution; (5). One year of identity theft insurance with $20,000.00 coverage at $0 deductible; and (6) . Necessary legal expenses the subjects may incur to repair falsified or damaged credit records, histories, or financial affairs; 17. Security Controls Compliance Testing On a periodic basis, VA, including the Office of Inspector General, reserves the right to evaluate any or all of the security controls and privacy practices implemented by the contractor under the clauses contained within the contract. With 10 working-day s notice, at the request of the government, the contractor must fully cooperate and assist in a government-sponsored security controls assessment at each location wherein VA information is processed or stored, or information systems are developed, operated, maintained, or used on behalf of VA, including those initiated by the Office of Inspector General. The government may conduct a security control assessment on shorter notice (to include unannounced assessments) as determined by VA in the event of a security incident or at any other time. 18. Training Contractor/subcontractor employees requiring access to VA information shall complete privacy training...