R602--Courier Transport Services Base plus (4) (1) Year Options Total Award $242,802.00

7 SOURCES SOUGHT NOTICE: Firm Fixed Price Contract (FFP) DESCRIPTION: This is a sources sought to determine the availability of potential sources having the skills and capabilities necessary to provide Courier Services for transportation of medical supplies, prescription, medical records, radiology results on cd film, and laboratory specimens and cultures, VA staff when appropriate on a routine or emergency basis, for the William Jennings Bryan Dorn VA Medical Center (WJBDVAMC) in Columbia, SC. The period of performance is for one Base period of 12 months and (4) one- year Options. Please be aware all Federal, State and local labor laws will be applicable to this procurement including, federal minimum wage as provided in Section 6(a)(1) of the Fair Labor Standards Act and the McNamara-O Hara Service Contract Act. If you have specific questions regarding labor laws, you should contact your local Federal Department of Labor representative. All interested vendors are invited to provide information to contribute to this market survey/sources sought including commercial market information. THIS IS NOT A SOLICITATION ANNOUNCEMENT. This is a sources sought synopsis. Questions should be submitted by email to contact@example.gov Provide only the requested information below. The purpose of this synopsis is to gain knowledge of potential qualified sources and their size classifications (Service Disabled/Veteran Owned Small Business (SDVOSB/VOSB), Hub zone, 8(a), small, small disadvantaged, woman-owned small business, FSS/GSA contract schedule holders or large business) relative to NAICS 492210 Local Messengers and Local Delivery (size standard $30.0 M). Responses to this synopsis will be used by the Government to make appropriate acquisition decisions. After review of the responses to the sources sought synopsis, a solicitation announcement may be published on the FBO website. Responses to the sources sought synopsis are not considered adequate responses to the solicitation announcement. All interested offerors will have to respond to the solicitation announcement in addition to responding to the sources sought announcement. REQUESTED INFORMATION: (1) STATEMENT OF CABABILITY: Submit a brief description, two (2) pages or less, that demonstrates how your company can provide the requested services at time of award. Include your company s experience in performing these services to the VA, other Government (Federal or State) agency, or for a private facility. (2) BUSINESS SIZE AND SOCIO-ECONOMIC STATUS: (a) Indicate whether your business is large or small as defined by the NAICS (b) If small, indicate if your firm qualifies as a small, emerging business, or small disadvantaged business (c) If disadvantaged, specify under which disadvantaged group and if your firm is certified under Section 8(a) of the Small Business Act (d) Indicate if your firm is a certified Hub-zone firm (e) Indicate if your firm is a woman-owned or operated business (f) Indicate if your firm is a certified Service-Disabled Veteran Owned Small Business (SDVOSB) or Veteran Owned Small Business (VOSB) (g) Include the DUNS number of your firm. (h) State whether your firm is registered with the System for Award Management (SAM) at https://www.sam.gov/portal/public/SAM/ and/or the Vet-Biz Registry at http://vip.vetbiz.gov/. If not, please (i) NOTE that any future solicitation could only be awarded to a company that is registered in SAM and to receive award based on VOSB or SDVOSB status you must be registered in Vet-Biz Registry. Responses must be emailed to contact@example.gov no later than 12:00NOON EST, Friday, October 11, 2019. Your response should include both the STATEMENT OF CABABILITY and BUSINESS SIZE AND SOCIO- ECONOMIC STATUS information as explained above. Please place "Attention: Courier Services in the subject line of your email. This notice is to assist the VA in determining sources only. A SOLICITATION IS NOT CURRENTLY AVAILABLE. If a solicitation is issued it will be announced later, and all interested parties must respond to that solicitation announcement separately from the responses to this announcement. Statement of Work Courier Services 1. REQUIREMENT: Courier Services for transportation of medical supplies, prescription medication, medical records, radiology results on cd or film, and laboratory specimens and cultures, VA staff when appropriate on a routine or emergency basis 24/7 when necessary for the Dorn VA Medical Center, 6439 Garners Ferry Rd, Columbia, SC 29209. Trips are based on flat rates, approximately 80 trips per month, and approximately 30 trips after hours per month. 2. BACKGROUND: The WJB Dorn VA Medical Center is an in/out patient facility, encompassing acute medical, surgical, psychiatric, and short-term & long-term care. The hospital is in Columbia, South Carolina and provides primary, secondary, and some tertiary care. Community-Based Outpatient Clinics (CBOCs) are located at Anderson, Greenville, Florence, Orangeburg, Rock Hill, Sumter, and Spartanburg, South Carolina. 3. PERIOD OF PERFORMANCE: Period of Performance: One (1) Base year, with four (4) one-year option periods. Base Year: 01 December 2019 30 November 2020 1st Option Period 01 December 2020 30 November 2021 2nd Option Period 01 December 2021 30 November 2022 3rd Option Period 01 December 2022 30 November 2023 4th Option Period 01 December 2023 30 November 2024 4. PLACE OF PERFORMANCE: WJB Dorn VA Medical Center 6439 Garners Ferry Road Columbia, SC 29209 5. PERFORMANCE REQUIREMENTS: The contractor shall provide courier services to transport medical supplies, prescription medications, medical records, radiology results on cd or film, laboratory specimens and cultures, and VA staff when appropriate on a routine or emergency basis when necessary for the Dorn Medical Center. Twenty-four (24) hour and seven (7) days a week, Monday thru Sunday, coverage is required to include holidays and weekends. Federal Holidays are defined as: New Year s Day, Martin Luther King Jr. Birthday, Washington s Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veteran s Day, Thanksgiving Day and Christmas Day. When a holiday falls on a Sunday, the following Monday will be observed as a legal holiday. When a holiday falls on a Saturday, the preceding Friday is observed by U.S. Government agencies. All travel is within 50 miles of the city Columbia, SC -The contractor shall provide pick-up and delivery services seven days per week, 24 hours a day, including Holidays and weekends. Trips are based off flat rates. -The contractor shall deliver medical supplies, prescription medication, medical records, radiology results on cd or film, laboratory specimens and cultures, and VA staff when appropriate, on a routine or emergency basis when necessary. Pick up and/or delivery will be made within 30 minutes of the requested time. -The contractor is NOT responsible for any special supplies or equipment needed to deliver packages to other facilities. This shall be provided by the VA staff. -The contractor IS responsible for ensuring safe delivery of specimen, supplies and accompanied staff member. -The contractor is required to be certified to transport hazardous material due to the possibility of transporting laboratory specimens. Work shall be performed by the awarded contractor only. -Drop off/pickup locations and POC numbers include, but not limited to: a. Emergency Department, Building 100, extension 7200/7466. b. After-hours pick-up and delivery (after 5:00 PM daily, weekends and holidays) will be to the Administrative Officer of the Day (AOD) office, building 100 located at the Emergency Department, extension 7200 or 7201. c. Travel Office (8:00 am-4:00pm Monday thru Friday, excluding federal holidays) Building 100, extension 7156 or 7181. d. Pharmacy Service, Building 100, extension 6730 and 7215 (8:00am-4:00pm), and 7219 (4:00pm-8:00am). Dorn VAMC reserves the right to adjust the hours and locations as needed. The COR will notify the contractor within two days if there are any additions or changes. Contractor is responsible for training transport personnel in appropriate safety and transporting procedures suitable for hazardous material transports. QUALITY CONTROL: The contractor shall develop and maintain a quality control program that ensures courier services are performed in accordance with these specifications. The contractor shall develop and implement procedures to track, identify, prevent, and remedy and ensure non-recurrence of unsatisfactory services. The contractor shall provide a method to accept and resolve customer complaints and notify the COR of the complaint and resolution. The contractor shall immediately notify the COR upon receipt of a customer complaint in order that joint validation may be accomplished. The contractor is responsible for quality control and specification compliance. CONTRACTOR COURIER/DRIVERS The contractor shall be responsible for furnishing all vehicles, personnel, equipment and supplies, vehicle fuel, uniforms, name tags, and/or badges for performance of services under this contract. As a Non-Personal Services contract, contractor personnel are not to be considered VA employees for any purpose. Contractor retains all control over personnel and responsibility for direct supervision. The vehicle used in the performance of this contract must be licensed and meet the minimum requirements by the states and cities operated therein. Contractor will ensure that all drivers utilized under this contract will be licensed in accordance with the laws of the State of South Carolina, for the transportation purposes for which this contract is intended. Contractor personnel shall wear visible identification always while on the premises of any Federal property. A record of each driver as to character and physical capabilities for performing as a courier must be maintained and made available to the Department of Veterans Affairs Medical Center upon request for inspection. The contractor personnel performing services to the Government shall always conduct themselves in a professional manner, present a neat appearance and be easily recognized as a contract employee by having the company name affixed to the clothing uniform. CONTRACTOR VEHICLES: Contractor will maintain registration, licensing and insurance as required by the State of South Carolina on all vehicles utilized under this contract, for the transportation purposes for which his contract is intended. Contractor will ensure that all vehicles are designed and sized appropriately to provide services descried in this contract. All vehicles must be maintained in accordance with Manufacturers recommendations and Title 56 Chapter 5 Article 35 of South Carolina law. It is the responsibility of the Contractor to park in the appropriate designated parking areas in accordance with State and Federal laws. SECURITY REQUIREMENTS: The contractor and their personnel shall be subject to the same Federal laws, regulations, standards, and VA policies as VA personnel, regarding information and information system security. These include but are not limited to Federal Information Security Management Act (FISM), 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 configurations available from NIST s Web site at: https://www.nist.org/ 6. INVOICES: a. Payment will be made upon receipt of a properly prepared detailed invoice, prepared by the Contractor and submitted through Tungsten Network (formerly known as OB10) http://www.tungsten-network.com/us/en/. A properly prepared invoice shall contain: Invoice Number and Date Contractor s Name and Address Accurate Purchase Order Number Supply or Service provided Period Supply or Service Provided Total Amount Due b. Please begin submitting your electronic invoices through the Tungsten Network for payment processing, free of charge. c. If you have questions about the e-invoicing program or Tungsten Network, contact information is as follows: - - - - Tungsten e-Invoice Setup Information: +1 (555) 000-0000 Tungsten e-Invoice email: contact@example.gov FSC e-Invoice Contact Information: +1 (555) 000-0000 FSC e-invoice email: contact@example.gov Web Address: HTTP://WWW.FSC.VA.GOV/EINVOICE.ASP 7. TERMINATION FOR CONVENIENCE: In accordance with FAR 52.212-4 (l) The Government reserves the right to terminate this contract, or any part hereof, for its sole convenience. 8. RECORDS MANAGEMENT LANGUAGE FOR CONTRACTS: The following standard items relate to records generated in executing the contract and should be included in a typical Electronic Information Systems (EIS) procurement contract: Citations to pertinent laws, codes and regulations such as 44 U.S.C chapters 21, 29, 31 and 33; Freedom of Information Act (5 U.S.C. 552); Privacy Act (5 U.S.C. 552a); 36 CFR Part 1222 and Part 1228. Contractor shall treat all deliverables under the contract as the property of the U.S. Government for which the Government Agency shall have unlimited rights to use, dispose of, or disclose such data contained therein as it determines to be in the public interest. Contractor shall not create or maintain any records that are not specifically tied to or authorized by the contract using Government IT equipment and/or Government records. Contractor shall not retain, use, sell, or disseminate copies of any deliverable that contains information covered by the Privacy Act of 1974 or that which is generally protected by the Freedom of Information Act. Contractor shall not create or maintain any records containing any Government Agency records that are not specifically tied to or authorized by the contract. The Government Agency owns the rights to all data/records produced as part of this contract. The Government Agency owns the rights to all electronic information (electronic data, electronic information systems, electronic databases, etc.) and all supporting documentation created as part of this contract. Contractor must deliver enough technical documentation with all data deliverables to permit the agency to use the data. Contractor agrees to comply with Federal and Agency records management policies, including those policies associated with the safeguarding of records covered by the Privacy Act of 1974. These policies include the preservation of all records created or received regardless of format [paper, electronic, etc.] or mode of transmission [e-mail, fax, etc.] or state of completion [draft, final, etc.]. No disposition of documents will be allowed without the prior written consent of the Contracting Officer. The Agency and its contractors are responsible for preventing the alienation or unauthorized destruction of records, including all forms of mutilation. Willful and unlawful destruction, damage or alienation of Federal records is subject to the fines and penalties imposed by 18 U.S.C. 2701. Records may not be removed from the legal custody of the Agency or destroyed without regard to the provisions of the agency records schedules. VA INFORMATION AND INFORMATION SYSTEM SECURITY/ PRIVACY Requirements 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. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS 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. 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. 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. Custom software development and outsourced operations must be 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. 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. VA INFORMATION CUSTODIAL LANGUAGE 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). VA information should not be co-mingled, if possible, with any other data on the contractors/subcontractor s information systems or media storage systems 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 onsite inspections of contractor and subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures follow VA directive requirements. Prior to termination or completion of this contract, contractor/subcontractor must not destroy information received from VA, or gathered/created by the contractor during 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 VA Contracting Officer within 30 days of termination of the contract. 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. 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. If VA determines that the contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be enough 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. If a VHA contract is terminated for cause, the associated BAA must also be terminated, and appropriate actions taken in accordance with VHA Handbook 1600.01, Business Associate Agreements. Absent an agreement to use or disclose protected health information, there is no business associate relationship. 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. 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. 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 VA contracting officer for response. 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 VA contracting officer for response. For service that involves the storage, generating, transmitting, or exchanging of VA sensitive information but does not require C&A or an MOU-ISA for system interconnection, the contractor/subcontractor must complete a Contractor Security Control Assessment (CSCA) on a yearly basis and provide it to the COTR. INFORMATION SYSTEM DESIGN AND DEVELOPMENT Information systems that are designed or developed for or on behalf of VA at non-VA facilities shall comply with all VA directives developed in accordance with FISMA, HIPAA, NIST, and related VA security and privacy control requirements for Federal information systems. This includes standards for the protection of electronic PHI, outlined in 45 C.F.R. Part 164, Subpart C, information and system security categorization level designations in accordance with FIPS 199 and FIPS 200 with implementation of all baseline security controls commensurate with the FIPS 199 system security categorization (reference Appendix D of VA Handbook 6500, VA Information Security Program). During the development cycle a Privacy Impact Assessment (PIA) must be completed, provided to the COTR, and approved by the VA Privacy Service in accordance with Directive 6507, VA Privacy Impact Assessment. The contractor/subcontractor shall certify to the COTR that applications are fully functional and operate correctly as intended on systems using the VA Federal Desktop Core Configuration (FDCC), and the common security configuration guidelines provided by NIST or the VA. This includes Internet Explorer 7 configured to operate on Windows XP and Vista (in Protected Mode on Vista) and future versions, as required. The standard installation, operation, maintenance, updating, and patching of software shall not alter the configuration settings from the VA approved and FDCC configuration. Information technology staff must also use the Windows Installer Service for installation to the default program files directory and silently install and uninstall. Applications designed for normal end users shall run in the standard user context without elevated system administration privileges. The security controls must be designed, developed, approved by VA, and implemented in accordance with the provisions of VA security system development life cycle as outlined in NIST Special Publication 800-37, Guide for Applying the Risk Management Framework to Federal Information Systems, VA Handbook 6500, Information Security Program and VA Handbook 6500.5, Incorporating Security and Privacy in System Development Lifecycle. The contractor/subcontractor is required to design, develop, or operate a System of Records Notice (SOR) on individuals to accomplish an agency function subject to the Privacy Act of 1974, (as amended), Public Law 93-579, December 31, 1974 (5 U.S.C. 552a) and applicable agency regulations. Violation of the Privacy Act may involve the imposition of criminal and civil penalties. The contractor/subcontractor agrees to: Comply with the Privacy Act of 1974 (the Act) and the agency rules and regulations issued under the Act in the design, development, or operation of any system of records on individuals to accomplish an agency function when the contract specifically identifies: (a) The Systems of Records (SOR); and (b) The design, development, or operation work that the contractor/subcontractor is to perform; Include the Privacy Act notification contained in this contract in every solicitation and resulting subcontract and in every subcontract awarded without a solicitation, when the work statement in the proposed subcontract requires the redesign, development, or operation of a SOR on individuals that is subject to the Privacy Act; and Include this Privacy Act clause, including this subparagraph (3), in all subcontracts awarded under this contract which requires the design, development, or operation of such a SOR. In the event of violations of the Act, a civil action may be brought against the agency involved when the violation concerns the design, development, or operation of a SOR on individuals to accomplish an agency function, and criminal penalties may be imposed upon the officers or employees of the agency when the violation concerns the operation of a SOR on individuals to accomplish an agency function. For purposes of the Act, when the contract is for the operation of a SOR on individuals to accomplish an agency function, the contractor/subcontractor is an employee of the agency. Operation of a System of Records means performance of any of the activities associated with maintaining the SOR, including the collection, use, maintenance, and dissemination of records. Record means any item, collection, or grouping of information about an individual that is maintained by an agency, including, but not limited to, education, financial transactions, medical history, and criminal or employment history and contains the person s name, or identifying number, symbol, or any other identifying particular assigned to the individual, such as a fingerprint or voiceprint, or a photograph. System of Records means a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some identifying number, symbol, or other identifying assigned to the individual. The vendor shall ensure the security of all procured or developed systems and technologies, including their subcomponents (hereinafter referred to as Systems ), throughout the life of this contract and any extension, warranty, or maintenance periods. This includes, but is not limited to workarounds, patches, hotfixes, upgrades, and any physical components (hereafter referred to as Security Fixes) which may be necessary to fix all security vulnerabilities published or known to the vendor anywhere in the Systems, including Operating Systems and firmware. The vendor shall ensure that Security Fixes shall not negatively impact the Systems. The vendor shall notify VA within 24 hours of the discovery or disclosure of successful exploits of the vulnerability which can compromise the security of the Systems (including the confidentiality or integrity of its data and operations, or the availability of the system). Such issues shall be remediated as quickly as is practical, but in no event longer than ____ days. When the Security Fixes involve installing third party patches (such as Microsoft OS patches or Adobe Acrobat), the vendor will provide written notice to the VA that the patch has been validated as not affecting the Systems within 10 working days. When the vendor is responsible for operations or maintenance of the Systems, they shall apply the Security Fixes within ____ days. All other vulnerabilities shall be remediated as specified in this paragraph in a timely manner based on risk, but within 60 days of discovery or disclosure. Exceptions to this paragraph (e.g. for the convenience of VA) shall only be granted with approval of the contracting officer and the VA Assistant Secretary for Office of Information and Technology. INFORMATION SYSTEM HOSTING, OPERATION, MAINTENANCE, OR USE For information systems that are hosted, operated, maintained, or used on behalf of VA at non-VA facilities, contractors/subcontractors are fully responsible and accountable for ensuring compliance with all HIPAA, Privacy Act, FISMA, NIST, FIPS, and VA security and privacy directives and handbooks. This includes conducting compliant risk assessments, routine vulnerability scanning, system patching and change management procedures, and the completion of an acceptable contingency plan for each system. The contractor s security control procedures must be equivalent, to those procedures used to secure VA systems. A Privacy Impact Assessment (PIA) must also be provided to the COTR and approved by VA Privacy Service prior to operational approval. All external Internet connections to VA s network involving VA information must be reviewed and approved by VA prior to implementation. Adequate security controls for collecting, processing, transmitting, and storing of Personally Identifiable Information (PII), as determined by the VA Privacy Service, must be in place, tested, and approved by VA prior to hosting, operation, maintenance, or use of the information system, or systems by or on behalf of VA. These security controls are to be assessed and stated within the PIA and if these controls are determined not to be in place, or inadequate, a Plan of Action and Milestones (POA&M) must be submitted and approved prior to the collection of PII...