Q--Blood Bank \ Transfusion Physician Services

This is a combined synopsis/solicitation for commercial items prepared in accordance with the format in Subpart 12.6, as supplemented with additional information included in this notice. This announcement constitutes the only solicitation; quotes are being requested and a written solicitation will NOT be issued. This solicitation, VA263-12-Q-0074, is being issued as a Request for Quotation (RFQ). Contract is to be awarded for one (1) base year with three (3) one (1) year options. Option years may be exercised at the discretion of the Government. Vendor is to provide .5 FTE Blood Bank Physician Services. Provisions and clauses are incorporated through Federal Acquisition Circular 2005-54. This procurement is full and open competition. This procurement will be solicited and awarded as a commercial item in accordance with procedures prescribed in FAR Parts 12 and 13.5. The Government contemplates an award of a Firm Fixed Priced contract. The North American Industry Classification System Code (NAICS) is 621991, size standard of 10.0 Million Dollars. Offerors must be registered in the Central Contractor Registration (CCR) at http://www.ccr.gov and Online Representations and Certifications Application (ORCA) at https://orca.bpn.gov, in order to be considered for award. 1. DESRICPTION/SPECIFCATIONS/STATEMENT OF WORK: 1. Purpose: The Department of Veterans Affairs (VA) Minneapolis VA Health Care System (MVAHCS) requires a 0.5 FTEE licensed physician who is a board certified/eligible Clinical Pathologist as well as board certified/eligible in Transfusion Medicine to perform duties for the MVAHCS. The Contractor will provide the services of a physician to serve as the Blood Bank and Transfusion Services Medical Director and provide 24/7 on call coverage for the Minneapolis MVAHCS Laboratory Service. All services provided shall be in accordance with the prices, terms and conditions of this contract and will provide specialized medical resources as listed herein. 2. Authority: Services to be provided in this agreement are under the authority of Section 301 of Public Law 104-262, Veterans Health Care Eligibility reform Act of 1996 (VHCERA) and Title 38 U.S.C. 8153 "Enhanced Health Care Resources". 3. Physicians - Requirements/Statement of Work: The Contractor shall provide .5 FTEE licensed physician who is a board certified/eligible Clinical Pathologist as well as board certified/eligible in Transfusion Medicine, to perform duties for the Minneapolis MVAHCS. The contractor physician will report directly to Director, Pathology and Laboratory Medicine Service (PALMS), at the Minneapolis, Minnesota, VA Medical Center. A. Suites include, but may not be limited to, the following, and must be provided 24/7 either on-site or on-call by phone or pager: 1) Provide oversight and direction for MVAHCS Transfusion Services 2) Provide oversight and direction to the MVAHCS Laboratory Blood Bank - Including: (a) Reviewing and approving new and revised procedures and practice of the MVAHCS Blood Bank within 7 days or receipt, and approving and deviations from written producers or policies. (b) Providing direction of the MVAHCS Transfusion Services Quality Management Program and abstract, compile, and report Performance Improvement data as requested by Director, PALMS. (c) Contributing to the Medical Education Program and Staff Continuing Education Program by annually providing at least 4 hours of lectures or small group sessions with lab staff and/or students. (d) Providing in-person onsite lectures for MVAHCS Physicians and clinical staff. (e) Reviewing performance of clinical laboratory staff in MVAHCS Blood Bank. (f) Serving as advisor for the distribution, handing, use and administration of blood and blood products. (g) Providing professional and technical direction for the blood bank to assist Physicians and Laboratory Staff. (h) Assuring compliance of all producers and practices with standards required by all pertinent accrediting agencies, to include FDA, AABB, CAP and Joint Commission. (i) Being available on site and being able to represent the MVAHCS Laboratory services at on-site inspections of the Blood Bank by the national accrediting agencies to include FDA, AABB, CAP and Joint Commission. 3) Provide expert consultation on transfusion utilization practices and producers in the medical center. 4) Provide medical coverage on transfusion issues for clinical procedures performed at the MVAHCS including approving cases that deviate from the standard operating procedures. 5) Participate on the MVAHCS Transfusion Committee including review of transfusion practices, review of physician ordering practices, and monitoring of the safety and adequacy of the blood supply. 6) Conduct investigations of infections complications and other adverse outcomes which may be due to blood or blood products transfusion. 7) Act as a consultant to therapeutic apheresis services by writing orders, seeing patient, recommending frequency of care and writing progress notes. 8) Contracted physician will be required to enter their own progress notes in the electronic medical record. 9) Contracted physician will comply with appropriate MVAHCS policies, procedures, and regulations. Examples include medical staff by laws, rules, and regulations, narcotic control and use, personnel policies, labor/management relations, infections control, medical records, and required training regarding privacy, security, ethics, and the use of the MVAHCS EMR/computers. 10) Oversee residency training rotation and curriculum at MVAMC; participate in teaching medical students, medical residents and blood bank/transfusion fellows. B. Full Time Equivalent Employees (FTEE): (1) The Contractor shall provide a 0.5 FTEE Physician. A full-time equivalent employee (1.0 FTEE) is defined as a contractor employee working eight (8) hours per day, five (5) days per week or 40 hours per week. Contractor's employees must be present at the Minneapolis VA Medical Center and must be actually performing the required services for the period specified in the contract or the contract cost will be decreased accordingly during each billing cycle. (2) Tour of Duty: Contractor physician shall provide his/her services to the MVAHCS 4 hours each day, five days each week, or provide an equivalent of 20 hours of on-site services (see note below)* In addition, contractor physicians(s) will be available by phone or pager for on-call coverage and consultations 24 hours per day, 7 days per week including all weekends and holidays. *NOTE: The MVAHCS recognizes that there may be times when related duties may take the contract physician off-site when working in his/her capacity as the MVAHCS Blood Bank Physician (All related duties that take the contactor physician off site must be approved by the VAHCS Director of Pathology and Laboratory Medicine to be credited to the contractor physicians' tour of duty). (3) Contractor may provide a partnership through shared physician services to cover the 0.5 FTEE position. The CV(s) of the proposed physicians(s) must be submitted to the MVAHCS Chief of Staff's office for credentialing and privileging and security background checks must be initiated by the VA prior to a physicians commencing work at the MVAHCS. (4) Personnel scheduled to perform services under this contact shall be subject to review and acceptance or rejection by the Director of PALMS and the MVAHCS Chief of Staff. The Contracting Officer must be notified of any change in personnel. C. Qualifications of Contract Physician(s): Physician(s) assigned by the Contractor to perform the services covered by this contract shall be appropriately licensed to perform the services as set forth in the agreement. The license may be from a State, Territory, or Commonwealth of the United States of America, or the District of Columbia. Contractor personnel must meet the professional qualification criteria of VA, as reasonably determined by the VA, prior to commencement of work under this contract. The qualifications of such personnel shall also be subject to review by VA Chief of Staff and approval by VA Facility Director. The personnel assigned by the Contractor will be credentialed and privileged by the VA in accordance with VHA Handbook 1100.19. Contractor's physicians(s) providing services under this contract must also meet the professional qualification listed below: 1) MD degree from recognized medical school 2) He/She shall have completed an approved Clinical Pathology residency training program. 3) Physician must be board certified or board eligible in Clinical Pathology. 4) Must be Board Certified in Blood Bank/Transfusion Medicine or be board eligible by completing a minimum of a one year fellowship in an approved program in Blood Banking/Transfusion Medicine. In addition to professional qualification, all contacted physicians must undergo identity verification, security background check, fingerprinting, and medical clearance. All contracted physicians must also complete the VA Privacy and Security Awareness training and maintain certification in Basic Life Support (BLS). 4. Performance Measures: The following performance measures will be regularly tracked and monitored throughout the effective period of this contact by the Technical Representative and reported to the Contracting Officer. Acceptable performance on these measures, along with other factors, will be primary indices of contractor performance and a key consideration in contract renewal decisions. ACTION MONITOR ACCEPTABLE PERFORMANCE Call back to VAHCS Transfusion Service once phoned/paged Time to return call after phoned or paged 95% of all pages/calls are returned within 15 minutes or less Investigations into possible Transfusion Related infectious Disease Investigations should be initiated ASAP after notification from MVACHS/Blood Supplier 90% of all investigations are initiated within 24 hours of notice by MVHCS/Blood Supplier Review and rejection or approval of new or review Blood Bank policies and procedures Time to review and approve or reject policies and procedures 90% of policies and procedures are approved or rejected within 7 business days Provision of CE/CME to MVAHCS Number of hours of CE/CME provided to staff Each year contractor provides 4 hours of CE/CME to staff Participation on the MVAHCS Attendance at Transfusion Attendance recorded at all Transfusion Committee Committee meetings Transfusion Committee Meetings 5. Compliance with the Joint Commission: All services performed and provided at the VAHCS shall comply with appropriate and applicable policies, procedures and regulations of the VAHCS to ensure compliance with all applicable joint commission guidelines. The contactor shall continuously meet or exceed all of The Joint Commission (TCJ) applicable standards including National Patient Safety Goals, Provisions of Care, Human Resources, Waived Testing and all other applicable standards from the Hospital and Ambulatory Care manuals. 6. Term of Contact/Agreement: Contact term shall be from January 1, 2012 to December 31, 2015. Contact term consists of a Base Year with options to extend the contract for three (3) additional one (1) year periods. Total contract term will not exceed four (4) years. The contract is subject to the availability of VA funds as appropriated by Congress. No service shall be performed by the Contractor after September 30 of any year, unless authorized by the Contracting Officer in writing. 7. Termination: Either party may terminate this contract upon at least a ninety (90) days written notification. Such an action may be taken in the event of a breach of contract, or an ethnical or legal conflict of interest. Termination notice will be provided to the other party's contracting official. 8. Changes: Changes in the terms and conditions of this contract may be made only by written agreement of both parties. Contactor must submit requests for changes in writing to the VA Contracting Office. Any and all modifications to this contact will be prepared by the VA Contracting Officer for signature. 9: Insurance: Contractor shall maintain commercial general liability and professional liability insurance of at least one million dollars ($1,000,000.00) applicable to its blood banking activities. Contractor's employed physician(s) shall be covered by Contractor's professional liability/medical malpractice insurance within the terms and conditions of the actual policy. Contractor shall also maintain workers compensation insurance for its employees in accordance with all statutory requirements. Contractor will provide a certificate of insurance evidencing its commercial general liability, professional liability, and workers compensation insurance prior to on-site work. Such certificate shall provide for not less than thirty days written notice to the Government of cancellation. 10. Limitation of Liability: The Contractor and/or his employee will not be held responsible for any loss or damage arising out of the following, as applicable: (a) The services proved unless directly attributable to the Contractor/or his employee's negligence or willful misconduct. (b) Patient care provided by the MVAHCS, an unknown condition of any VA patient, or the underlying condition of any VA patient. 11. Nondiscrimination in Services Provided to VA Beneficiaries: The contractor agrees to provide all services specified in this contract for any person determined eligible by the Chief Medical Director, or designee, regardless of race, color, religion, gender, or national origin of the person for whom such services are ordered. The contractor further warrants that he/she will not resort to subcontracting as means of circumventing this provision. 12. Policy Applicable to Contractor Employees Working on VA Site: Contractor employees shall adhere to all policies and procedures specific to contractor employees as outlined in VA Policy MA-08-Vendros. Contractor ID badges will be issued by VA Police. SCHEDULE OF SUPPLIES/SERVICES 2. PRICING: Line Items: Contractor shall provide all costs into their Unit Price. Line item 1A (Base Year): 0.5 FTEE Blood Bank Physician services for the MVAHCS (4hours/days; 5 days/weeks) Unit Est Qty Unit Price Total Price Months 12 $ $ Line item 1B (Option Year 1): 0.5 FTEE Blood Bank Physician services for the MVAHCS (4hours/days; 5days/weeks) Unit Est Qty Unit Price Total Price Months 12 $ $ Line item 1C (Option Year 2): 0.5 FTEE Blood Bank Physician services for the MVAHCS (4hours/days; 5days/weeks) Unit Est Qty Unit Price Total Price Months 12 $ $ Line item 1D (Option Year 3): 0.5 FTEE Blood Bank Physician services for the MVAHCS (4hours/days; 5days/weeks) Unit Est Qty Unit Price Total Price Months 12 $ $ Note***Unit Price includes all cost, i.e., salary, fringe benefits, malpractice insurance, etc. No additional compensation will be paid for vacation leave, sick leave or holidays. 3. PLACE/PERIOD OF PERFORMANCE: 0.5 FTEE Blood Bank Physician Services shall be provided at the MVAHCS. Period of performance shall be January 1, 2012 through December 31, 2012 with three (3) one (1) year options. 4. PROVISIONS/CLAUSES: Offeror shall submit a complete copy of provision FAR 52.212-3, Offeror Representation and Certification- Commercial Items (NOV 2011). The full text of clauses identified herein may be accessed electronically at these addresses: http://www.arnet.gov/far and http://www.va.gov/oa&mm/vaar. The following Federal Acquisition Regulation (FAR) Clauses and Provisions also apply to the acquisition:, 52.212-1, Instruction to Offerors - Commercial Items (JUNE 2008); 52.212-4, Contract Terms and Conditions - Commercial Items (JUNE 2010); 52.228-5, Insurance - Work on a Government Installation (JAN 1997), 52.216-8 Option to Extend Services (NOV 1999), 52.217-9, Option to Extend the Term of the Contract (MAR 2000), VAAR 852.203-70, Commercial Advertising (JAN 2008), VAAR 852.237-7, Indemnification and Medical Liability Insurance (JAN 2008), VAAR 852.237-70, Nondiscrimination in Services Provided to Beneficiaries (JAN 2008), VAAR 852.237-70, Contactor Responsibilities (APR 1984), VAAR 852.273-75, Security Requirement for Unclassified Information Technology Resources (Interim - October 2008), VAAR 852.273-76 Electronic Invoice Submission (Interim- October 2008), 52.252-2, Clauses Incorporated by Reference (FEB 1998), 52.212-5, Contract Terms and Conditions Required to Implement Statues or Executive Orders - Commercial Items (APR 2011), 52.216-1, Type of Contract (APR 1984), 52.217-5, Evaluation of Options (Jul 1990), VAAR 852.273-74 Award without Exchanges (JAN 2003), 52.252-1 Solicitation provisions incorporated by Reference (FEB 1998), VAAR 852.273-73 Evaluation Health- Care Resources (JAN 2003). Proposals/quotes will only be accepted electronically and can be sent to contact@example.gov. MARCH 12, 2010 VA HANDBOOK 6500.6 APPENDIX C C-1 VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE FOR INCLUSION INTO CONTRACTS, AS APPROPRIATE 1. GENERAL Contractors, contractor personnel, subcontractors, and subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security. 2. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS a. 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. Contract personnel who require access to national security programs must have a valid security clearance. National Industrial Security Program (NISP) was established by Executive Order 12829 to ensure that cleared U.S. defense industry contract personnel safeguard the classified information in their possession while performing work on contracts, programs, bids, or research and development efforts. The Department of Veterans Affairs does not have a Memorandum of Agreement with Defense Security Service (DSS). Verification of a Security Clearance must be processed through the Special Security Officer located in the Planning and National Security Service within the Office of Operations, Security, and Preparedness. d. Custom software development and outsourced operations must be located in the U.S. to the maximum extent practical. If such services are proposed to be performed abroad and are not disallowed by other VA policy or mandates, the contractor/subcontractor must state where all non-U.S. services are provided and detail a security plan, deemed to be acceptable by VA, specifically to address mitigation of the resulting problems of communication, control, data protection, and so forth. Location within the U.S. may be an evaluation factor. e. The contractor or subcontractor must notify the Contracting Officer immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the contractor or subcontractor's employ. The Contracting Officer must also be notified immediately by the contractor or subcontractor prior to an unfriendly termination. 3. VA INFORMATION CUSTODIAL LANGUAGE a. Information made available to the contractor or subcontractor by VA for the performance or administration of this contract or information developed by the contractor/subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of the VA. This clause expressly limits the contractor/subcontractor's rights to use data as described in Rights in Data - General, FAR 52.227-14(d) (1). 6. SECURITY INCIDENT INVESTIGATION a. The term "security incident" means an event that has, or could have, resulted in unauthorized access to, loss or damage to VA assets, or sensitive information, or an action that breaches VA security procedures. The contractor/subcontractor shall immediately notify the COTR and simultaneously, the designated ISO and Privacy Officer for the contract of any known or suspected security/privacy incidents, or any unauthorized disclosure of sensitive information, including that contained in system(s) to which the contractor/subcontractor has access. 7. LIQUIDATED DAMAGES FOR DATA BREACH a. Consistent with the requirements of 38 U.S.C. §5725, a contract may require access to sensitive personal information. If so, the contractor is liable to VA for liquidated damages in the event of a data breach or privacy incident involving any SPI the contractor/subcontractor processes or maintains under this contract. b. The contractor/subcontractor shall provide notice to VA of a "security incident" as set forth in the Security Incident Investigation section above. Upon such notification, VA must secure from a non-Department entity or the VA Office of Inspector General an independent risk analysis of the data breach to determine the level of risk associated with the data breach for the potential misuse of any sensitive personal information involved in the data breach. The term 'data breach' means the loss, theft, or other unauthorized access, or any access other than that incidental to the scope of employment, to data containing sensitive personal information, in electronic or printed form, that results in the potential compromise of the confidentiality or integrity of the data. Contractor shall fully cooperate with the entity performing the risk analysis. Failure to cooperate may be deemed a material breach and grounds for contract termination. c. Each risk analysis shall address all relevant information concerning the data breach, including the following: (1) Nature of the event (loss, theft, unauthorized access); (2) Description of the event, including: (a) date of occurrence; (b) data elements involved, including any PII, such as full name, social security number, date of birth, home address, account number, disability code; (3) Number of individuals affected or potentially affected; (4) Names of individuals or groups affected or potentially affected; (5) Ease of logical data access to the lost, stolen or improperly accessed data in light of the degree of protection for the data, e.g., unencrypted, plain text; (6) Amount of time the data has been out of VA control; (7) The likelihood that the sensitive personal information will or has been compromised (made accessible to and usable by unauthorized persons); (8) Known misuses of data containing sensitive personal information, if any; (9) Assessment of the potential harm to the affected individuals; (10) Data breach analysis as outlined in 6500.2 Handbook, Management of Security and Privacy Incidents, as appropriate; and (11) Whether credit protection services may assist record subjects in avoiding or mitigating the results of identity theft based on the sensitive personal information that may have been compromised. 9. TRAINING a. All contractor employees and subcontractor employees requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and its systems: (1) Sign and acknowledge (either manually or electronically) understanding of and responsibilities for compliance with the Contractor Rules of Behavior, Appendix E relating to access to VA information and information systems; (2) Successfully complete the VA Cyber Security Awareness and Rules of Behavior training and annually complete required security training; (3) Successfully complete the appropriate VA privacy training and annually complete required privacy training; and (4) Successfully complete any additional cyber security or privacy training, as required for VA personnel with equivalent information system access [to be defined by the VA program official and provided to the contracting officer for inclusion in the solicitation document - e.g., any role-based information security training required in accordance with NIST Special Publication 800-16, Information Technology Security Training Requirements.] b. The contractor shall provide to the contracting officer and/or the COTR a copy of the training certificates and certification of signing the Contractor Rules of Behavior for each applicable employee within 1 week of the initiation of the contract and annually thereafter, as required. c. Failure to complete the mandatory annual training and sign the Rules of Behavior annually, within the timeframe required, is grounds for suspension or termination of all physical or electronic access privileges and removal from work on the contract until such time as the training and documents are complete. MARCH 12, 2010 VA HANDBOOK 6500.6 APPENDIX D CONTRACTOR RULES OF BEHAVIOR This User Agreement contains rights and authorizations regarding my access to and use of any information assets or resources associated with my performance of services under the contract terms with the Department of Veterans Affairs (VA). This User Agreement covers my access to all VA data whether electronic or hard copy ("Data"), VA information systems and resources ("Systems"), and VA sites ("Sites"). This User Agreement incorporates Rules of Behavior for using VA, and other information systems and resources under the contract. 1. GENERAL TERMS AND CONDITIONS FOR ALL ACTIONS AND ACTIVITIES UNDER THE CONTRACT: a. I understand and agree that I have no reasonable expectation of privacy in accessing or using any VA, or other Federal Government information systems. b. I consent to reviews and actions by the Office of Information & Technology (OI&T) staff designated and authorized by the VA Chief Information Officer (CIO) and to the VA OIG regarding my access to and use of any information assets or resources associated with my performance of services under the contract terms with the VA. These actions may include monitoring, recording, copying, inspecting, restricting access, blocking, tracking, and disclosing to all authorized OI&T, VA, and law enforcement personnel as directed by the VA CIO without my prior consent or notification. c. I consent to reviews and actions by authorized VA systems administrators and Information Security Officers solely for protection of the VA infrastructure, including, but not limited to monitoring, recording, auditing, inspecting, investigating, restricting access, blocking, tracking, disclosing to authorized personnel, or any other authorized actions by all authorized OI&T, VA, and law enforcement personnel. d. I understand and accept that unauthorized attempts or acts to access, upload, change, or delete information on Federal Government systems; modify Federal government systems; deny access to Federal government systems; accrue resources for unauthorized use on Federal government systems; or otherwise misuse Federal government systems or resources are prohibited. e. I understand that such unauthorized attempts or acts are subject to action that may result in criminal, civil, or administrative penalties. This includes penalties for violations of Federal laws including, but not limited to, 18 U.S.C. §1030 (fraud and related activity in connection with computers) and 18 U.S.C. §2701 (unlawful access to stored communications). f. I agree that OI&T staff, in the course of obtaining access to information or systems on my behalf for performance under the contract, may provide information about me including, but not limited to, appropriate unique personal identifiers such as date of birth and social security number to other system administrators, Information Security Officers (ISOs), or other authorized staff without further notifying me or obtaining additional written or verbal permission from me. g. I understand I must comply with VA's security and data privacy directives and handbooks. I understand that copies of those directives and handbooks can be obtained from the Contracting Officer's Technical Representative (COTR). If the contractor believes the policies and guidance provided by the COTR is a material unilateral change to the contract, the contractor must elevate such concerns to the Contracting Officer for resolution. h. I will report suspected or identified information security/privacy incidents to the COTR and to the local ISO or Privacy Officer as appropriate. 2. GENERAL RULES OF BEHAVIOR a. Rules of Behavior are part of a comprehensive program to provide complete information security. These rules establish standards of behavior in recognition of the fact that knowledgeable users are the foundation of a successful security program. Users must understand that taking personal responsibility for the security of their computer and the information it contains is an essential part of their job. b. The following rules apply to all VA contractors. I agree to: (1) Follow established procedures for requesting, accessing, and closing user accounts and access. I will not request or obtain access beyond what is normally granted to users or by what is outlined in the contract. (2) Use only systems, software, databases, and data which I am authorized to use, including any copyright restrictions. (3) I will not use other equipment (OE) (non-contractor owned) for the storage, transfer, or processing of VA sensitive information without a VA CIO approved waiver, unless it has been reviewed and approved by local management and is included in the language of the contract. If authorized to use OE IT equipment, I must ensure that the system meets all applicable 6500 Handbook requirements for OE. (4) Not use my position of trust and access rights to exploit system controls or access information for any reason other than in the performance of the contract. (5) Not attempt to override or disable security, technical, or management controls unless expressly permitted to do so as an explicit requirement under the contract or at the direction of the COTR or ISO. If I am allowed or required to have a local administrator account on a government-owned computer, that local administrative account does not confer me unrestricted access or use, nor the authority to bypass security or other controls except as expressly permitted by the VA CIO or CIO's designee. (6) Contractors' use of systems, information, or sites is strictly limited to fulfill the terms of the contract. I understand no personal use is authorized. I will only use other Federal government information systems as expressly authorized by the terms of those systems. I accept that the restrictions under ethics regulations and criminal law still apply. (7) Grant access to systems and information only to those who have an official need to know. (8) Protect passwords from access by other individuals. (9) Create and change passwords in accordance with VA Handbook 6500 on systems and any devices protecting VA information as well as the rules of behavior and security settings for the particular system in question. (10) Protect information and systems from unauthorized disclosure, use, modification, or destruction. I will only use encryption that is FIPS 140-2 validated to safeguard VA sensitive information, both safeguarding VA sensitive information in storage and in transit regarding my access to and use of any information assets or resources associated with my performance of services under the contract terms with the VA...