SOLICITATION NOTICE
R -- Employee Satisfaction Survey
- Notice Date
- 5/4/2021 10:21:16 AM
- Notice Type
- Combined Synopsis/Solicitation
- NAICS
- 511210
— Software Publishers
- Contracting Office
- 247-NETWORK CONTRACT OFFICE 7 (36C247) AUGUSTA GA 30904 USA
- ZIP Code
- 30904
- Solicitation Number
- 36C24721Q0673
- Response Due
- 5/14/2021 8:00:00 AM
- Archive Date
- 07/13/2021
- Point of Contact
- Darlene Chase, Darlene.Chase@va.gov, Phone: 404-321-6111 x2428
- E-Mail Address
-
darlene.chase@va.gov
(darlene.chase@va.gov)
- Small Business Set-Aside
- SDVOSBC Service-Disabled Veteran-Owned Small Business (SDVOSB) Set-Aside (FAR 19.14)
- Awardee
- null
- Description
- This is a combined synopsis/solicitation for commercial items prepared in accordance with the format in Federal Acquisition Regulation (FAR) Subpart 12.6 ""Streamlined Procedures for Evaluation and Solicitation for Commercial Items"", as supplemented with additional information included on this notice. This announcement constitutes the only solicitation; this is a Request for Quotation (RFQ), and a written solicitation document will not be issued. The solicitation number is 36C24721Q0673. The solicitation document and incorporated provisions and clauses are those in effect through the Federal Acquisition Circular FAC 2021-05 effective March 10, 2021. The associated North American Industrial Classification System (NAICS) code for this procurement is 511210 and the Small Business Size standard is $41.5 Million. This combined/synopsis solicitation is set aside for Service-Disabled Veteran Owned Small Business (SDVOSB s) and Veteran Owned Small Businesses (VOSB s) in accordance with VAAR 852.219-10 and VAAR 852.219-11. Only VA verified SDVOSB s and VOSB s in the VIP at the time of contract award will be considered. All non-VIP verified firms will be considered non-responsive and ineligible for award. The acquisition will be made pursuant to the authority in FAR 13 to use simplified procedures for commercial items. This RFQ is set-aside for 100% Service-Disabled Veteran Owned Small Businesses and Veteran Owned Small Businesses. This statement of work describes the requirements for providing web-based employee satisfaction services to Charlie Norwood VA Medical Center (CNVAMC). The vendor shall provide web-based employee satisfaction survey access for up to 3,000 employees over a 12-month period of performance with three option years to be exercised as the facility sees fit. The enterprise license for the survey shall include unlimited pulses, access for up to three administrators with real time visual heat maps, two dashboards for tracking the changes to the survey for use throughout the medical center and contain exportable data with shareable graphics. Implementation consulting and training shall be included along with question design for the survey. GENERAL INFORMATION Web Based Employee Satisfaction Survey 1. GENERAL: This statement of work describes the requirements for providing web-based employee satisfaction services to Charlie Norwood VA Medical Center (CNVAMC). The vendor shall provide web-based employee satisfaction survey access for up to 3,000 employees over a 12-month period of performance with three option years to be exercised as the facility sees fit. The enterprise license for the survey shall include unlimited pulses, access for up to three administrators with real time visual heat maps, two dashboards for tracking the changes to the survey for use throughout the medical center and contain exportable data with shareable graphics. Implementation consulting and training shall be included along with question design for the survey. 2. BACKGROUND: The Charlie Norwood VA Medical Center (CNVAMC) is a two division multi-bed facility, encompassing acute medical, surgical, psychiatric, and long-term care. The hospital is located in Augusta, Georgia and provides primary, secondary, and some tertiary care. Annually, the medical center serves thousands of patients. Satellite Community Based Outpatient Clinics (CBOC s) are located in Athens, GA, Statesboro, GA and Aiken, SC., additionally the VISN7 Procurement and Accounting functional areas, the Seamless Transition Center and the Veteran Center are serviced by CNVAMC. 3. PERIOD OF PERFORMANCE: One base year with four option years for web-based employee satisfaction survey: Anticipated POP: Base Year: 05/15/2021 05/14/2022 Option Year 1: 05/15/2022 05/14/2023 Option Year 2: 05/15/2023 05/14/2024 Option Year 3: 05/15/2024 05/14/2025 4. PLACE OF PERFORMANCE: a. b. Charlie Norwood VA Medical Center Downtown Division 1 Freedom Way Augusta, GA 30909 Uptown Division 950 15th Street Augusta, GA 30909 5. Hours of Operation: 8:00 a.m. to 4:30 p.m. Monday Friday, excluding federal holidays. New Year s Day January 1st Martin Luther King s Birthday 3rd Monday in January President s Day 3rd Monday in February Memorial Day Last Monday in May Independence Day July 4th Labor Day 1st Monday in September Columbus Day 2nd Monday in October Veteran s Day November 11th Thanksgiving Day Last Thursday in November Christmas Day December 25th 6. Vendor Requirements: 6.1 Vendor shall furnish all requirements and deliver all necessary access and codes for functions related to viewing, setting up, and managing the employee satisfaction surveys on the web-based software. 6.2 The vendor will ensure the proper installation of software necessary for administrator access and abide by medical center privacy measures. 6.3 The vendor will provide technical support and training to users as necessary. Technical support shall be provided within 24 hours of request. 6.4 The online employee satisfaction surveys will be accessible at all times and in proper working condition. The vendor will need to give sufficient prior notice to CNVAMC in the case that access to and functions of the surveys and dashboards are affected by any necessary maintenance, software updates, or servicing of hardware. 6.5 All data/information pertaining to CNVAMC employee surveys that are stored on vendor servers is property of VA, which shall retain and migrate that proprietary data free of charge. VA shall freely migrate its data/information to other entities or its own servers as needed. 7. Medical Center Requirements: 7.1 The medical center shall provide the computers and software necessary to access the web-based software, surveys and dashboards. 8. Data Security Information Gathered or Created in Performance of Services 8.1. Information, including, but not limited to, veteran individually-identifiable information (iii) and personal healthcare information (PHI), gathered or created by the Contractor in the performance of this contract is the exclusive property of VA and must be received, gathered, stored, backed up, maintained, used, disclosed and disposed of in accordance with the terms of this contract and applicable federal and VA information confidentiality and security laws, regulations and policies, including VA Directive and Handbook number 6500. 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. 8.2 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. 8.3 ALL VA III AND PHI INFORMATION STORED ON BOTH VA AND NON-VA EQUIPAMENT MUST BE ENCRYPTED IN ACCORDANCE WITH THE FEDERAL INFORMATION SECURITY MANAGEMENT ACT (FISMA). Federal standards established by U.S. Department of Commerce apply, including Federal Information Processing Standard 200 (FIPS200), and National Institute of Standards and Technology Special Publication 800-37, Guide for the Security, Certification and Accreditation. Contractors and subcontractors shall document compliance and make the document available upon request of the Contracting Officer or COTR. Contractor and subcontractors shall allow physical inspection by VA personnel to assess its physical and environmental security controls. 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). 8.4 Contractor and its subcontractors must ensure that VA III and PHI is secure at all times and will ensure proper security is used on contractor or subcontractor computers with VA III or PHI information is stored. To avoid risk of loss or theft, VA III and PHI shall NOT be transferred by contractor or its subcontractors to paper, diskettes, CDs, DVDs, USB flash drives, external computer drives, computer notebooks, home computers or any other medium, and shall NOT be removed from the contractor for subcontractor site under any circumstances without specific written authorization of the VA Information Security Officer. The authorized VA III or PHI recipient shall back up files to protect their loss. Back-ups shall be locked and secured. VA III and PHI shall NOT be transferred between contractor or subcontractor computer unless permission is granted by VA for such transfer of data and secure encrypted transmission methods approved by the VA Information Security Officer are utilized. Contractor employees shall be required to sign VA National Rules of Behavior before they can be authorized access to VA information systems. 8.5 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 (on the date of discovery of the incident) 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. 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. 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; (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. 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. 8.6 HIPPA Compliance. The Contractor must adhere to the provisions of Public Law 104-191, Health Insurance Portability and Accountability Act (HIPAA) of 1996 and the National Standards to Protect the Privacy and Security of Protected Health Information (PHI) 8.7 Contractor Access to Federal Facilities: The medical providers working under this task order shall be issued an employee badge titled as Contractor which will be worn during duty hours. The contracted employee will receive additional security information during the credentialing process. 8.8 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. 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. 9. Access Automated Data Processing Files: In performance of official duties, the Contractor s employee(s) have regular access to printed and electronic files containing sensitive data, which must be protected under the provisions of the Privacy Act of 1974 (5 USC 552a), and other applicable laws, Federal Regulations, Veterans Affairs statutes and policies. The Contractor s employee(s) are responsible for (1) protecting that data from unauthorized release or from loss, alteration, or unauthorized deletion and (2) following all applicable regulations and instructions regarding access to computerized files, release of access codes, etc., as set out in a computer access agreement which the Contractor s employee(s) sign. 10. Contract Administration Data: The contracting officer is the only person authorized to approve changes or modify any of the requirements under this contract. The Contractor shall communicate with the Contracting Officer on all matters pertaining to contract administration. Only the Contracting Officer is authorized to make commitments or issue changes, which will affect price, quantity, or quality of performance of this contract. In the event the contractor effects any such change at the direction of any person other than the contracting officer, the change shall be considered to have been made without authority and no adjustment will be made in the contract price to cover any increase in costs incurred as a result thereof. 11. Designation of Contracting Officer s Representative: A VA Medical center representative of the Contracting Officer shall be designated to represent the Contracting Officer in furnishing technical guidance and advice regarding the work being performed under this contract. The foregoing is not to be construed as authorization to interpret or furnish advice or information to the Contractor relative to the financial or legal aspects of the contract. Enforcement of these segments is vested and is the sole responsibility of the CNVAMC Contracting Officer. Quality Assurance Surveillance Plan (QASP) Required Service Performance Standard Monitoring Method Disincentives for Meeting Performance Standards Provide and maintain access to online surveys, dashboards and demographic info All parties are able to access surveys to view or modify. Reported to COR by exception Not meeting standards will affect vendor s ability to do further business with the medical center. Vendor shall provide necessary training or technical support as needed Provides reliable and accurate tech support and training within 24 hours of request. Technical support issues should be reported to COR Not meeting standards will affect vendor s ability to do further business with the medical center. Vendor shall maintain functionality of online databases without interruption (including during maintenance or updates) Maintains uninterrupted access to survey information and dashboards. Reported to COR by exception Not meeting standards will affect vendor s ability to do further business with the medical center. 12.1. Contract Security Clauses The following contract security clauses are required for this non-medical services contract. 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. 12.1.1. Access to VA Information and VA Information Systems 12.1.2. 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. 12.1.3. 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). 12.1.4. 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 comply with VA directive requirements. 12.1.5. 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 VA Contracting Officer within 30 days of termination of the contract. 12.1.6. 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 12.1.7. 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. 12.1.8. 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. 12.1.9. 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. 12.1.10. 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. 12.1.11. 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. 12.1.12. 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. 12.1.13. 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. 12.1.14. 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. 12.1.15. 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 COR. 13.2 Security Incident Investigation: 13.2.1. 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. 13.2.2. 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. 13.2.3. 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. 13.2.4. 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. 14.3 Liquidated Damages for Data Breach: 14.3.1. 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. 14.3.2. 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. 14.3.3. 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. 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. 15.4. Security Control Compliance Testing 15.4.1. 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-days 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. 16. Training 16.1. 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: 16.1.1. Sign and acknowl...
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