The Department of Veterans Affairs (VA) North Indiana Healthcare System (VANIHCS) located at 2121 Lake Avenue, Fort Wayne, IN. 46805 is seeking Board Certified Hematology/Oncology provider Services on site and shall be credentialed and privileged by the VANIHCS in accordance with Medical Center Bylaws, rules, and regulations to beneficiaries of the Department of Veterans Affairs (VA) and the VANIHCS.
Instruction to Offerors Guidance:
This Sources Sought notice is not a Request for Quote (RFQ)/Request for Proposal (RFP) and no solicitation is being issued at this time. This notice shall not be construed as a commitment by the Government to issue a solicitation or to ultimately award a contract, nor does it restrict the government to a specific acquisition approach. Any information provided to the Government as a result of this sources sought notice is strictly voluntary. Responses will not be returned. No entitlement to payment or direct or indirect costs or charges by the Government will arise as a result of contractor submission of responses or the Government’s use of such information.
This Sources Sought Notice is for planning purposes only and is intended to identify eligible contractors in any socioeconomic category who can support this requirement. An eligible contractor is a contractor who possesses the qualifications, capability, and relevant experience to meet/exceed the Government’s requirements.
Instructions for Submission:
Interested contractors shall respond by e-mail only to Brandi Holland, Contract Specialist at Brandi.Holland2@va.gov. Responses are due no later than Tuesday, October 27, 2020 by 12:00 p.m. Eastern Standard Time (EST), Columbus, OH.
Respondents shall include as part of their submission:
Indicate if you can meet/exceed the government’s requirements and provide Board Certified Hematology/Oncology provider Services on site.
Name of your business, Point of contact name, phone number, email address of point of contact, DUNS Number, Socioeconomic Group (large business, small business, veteran-owned business, etc.)
A brief summary of relevant experience, relevant past contracts, and applicable qualifications/capabilities (as it pertains to this requirement) must be included. (It is the government’s expectation that the contractor would be able to provide a detailed, innovative plan and a cost-effective pathway/solution to meet/exceed the objectives that are contained in the document entitled “Performance Work Statement (PWS). See subsequent pages to follow.
Performance Work Statement (PWS)
1. GENERAL:
1.1. Services Provided: The Contractor shall provide Board Certified Hematology/Oncology provider Services on site and shall be credentialed and privileged by the VANIHCS in accordance with Medical Center Bylaws, rules, and regulations to beneficiaries of the Department of Veterans Affairs (VA) and the VANIHCS.
1.1.1. Evaluate and treat patients during a general Hematology Oncology outpatient clinic at the VA. Clinic shall be scheduled for eight (8) hours per day, three (3) days per week, one (1) day seven (7) hours per week plus one (1) hour Tumor Board, and eight hours (8), one day a week for on-call services during operating hours; 52 weeks per year. On-call service requires the contract physician to be available to provide phone consultation for staff or patients. This does not include holidays. Contract Physicians shall be paid 25% of the contracted hourly rate for the entire day for on-call services. This equates to 100 percent patient care duties
1.1.2. Attend and participate at the VA Tumor Board. Meeting shall be held once per week for one (1) hour, every Tuesday from 1‐2pm EST at VANIHCS. This equates to four (2) percent administrative duties.
1.1.3. Become acquainted with and knowledgeable about existing relations with local community oncology/hematology partners for transitional care.
1.2. On-Site Clinics:
1.2.1. On‐Site Clinics shall be conducted at least four (4) days per week. Daily clinic operational management activities shall be under the professional direction of the Chief, Medicine Service.
1.2.2. The contracted physician(s) shall be prepared to perform on a long‐term basis (minimum of one (1) year) to eliminate turnover and learning curve issues that arise with the familiarization of new physicians to the VANIHCS policies, procedures and processes.
1.2.3. The Contractor shall follow the VANIHCS guidelines for clinic processes, emergency notification or clinic unavailability, changes to clinic schedules, sick or late phone notifications, patient scheduling and referrals, and time and attendance requirements. Contractor shall fully participate in all applicable patient survey activities and data collection initiatives.
1.2.4. The contractor shall coordinate the Hematology/ Oncology portion of the interdisciplinary education plan for the patient. Education provided by the contractor shall be interactive with the patient, and shall be aimed at disease management and prevention and quality of life. All education given shall be documented in accordance with VA policies and procedures. Discharge instructions shall be provided to and coordinated with the patient, caregiver, and home or community care provider https://vaww.visn10.portal.va.gov/sites/NorthernIndiana/nihcspolicies
1.2.5. The contractor shall involve the patient in care decisions by keeping him/her fully informed about the diagnosis, plan of care, treatment goals, risks, benefits of proposed treatments and prognosis shared decision making shall be pursued. Care provided shall respect and integrate the patient’s beliefs, values, cultural influences and special needs. The patient population treated at the VANIHCS consists of veterans with varying physician, psychiatric and psychological needs. Their conditions are, in many ways, directly related to the individual’s service to this county. Contract personnel shall provide compassionate care with respect for the special needs of the veteran population serviced. Care shall reflect the VA Medical Center’s mission, vision and values. In addition, the patient’s Advanced Directives shall be reviewed and honored as stated in, “Care delivered will reflect the VAMC’s mission, vision and values” under the General Quality Management Section https://vaww.visn10.portal.va.gov/sites/Northern‐Indiana/Facilities .
1.2.6. VANIHCS is accredited by the Joint Commission (TJC). The contractor shall ensure that medical record documentation that documentation of all patient care is in accordance with TJC hospital standards, HCFA guidelines, and VA Medical Center policies https://vaww.visn10.portal.va.gov/sites/Northern‐Indiana/nihcspolicies .
1.2.7. If Contractor is re‐surveyed by TJC or re‐accredited by their professional accreditation agency, during the contract term, the contractor shall notify the Contracting Officer of survey dates and the outcome of the survey.
1.2.8. If a Professional Accreditation agency other than TJC is used, contractor shall provide a copy of the appropriate standards and scoring guidelines in their proposal.
1.2.9. The VA shall inform the contractor of all applicable Sentinel Events or other Patient Safety Alerts by the VAMC. A Sentinel Event is defined by the Joint Commission (TJC) as any unanticipated event in a healthcare setting resulting in death or serious physical or psychological injury to a patient or patients, not related to the natural course of the patient's illness. Sentinel events specifically include loss of a limb or gross motor function, and any event for which a recurrence would carry a risk of a serious adverse outcome. Sentinel events are identified under TJC accreditation policies to help aid in Root Cause Analysis (RCA) and to assist in development of preventative measures. The TJC tracks events in a database to ensure events are adequately analyzed and undesirable trends or decreases in performance are caught early and mitigated.
1.2.10. Any action plans that result from a Root Cause Analysis that pertain to contractor’s service shall be implemented with dissemination to other staff and residents. Every effort shall be made by the contractor to prevent medication errors, falls, and patient injury caused by acts of commission or omission in the delivery of care. https://vaww.visn10.portal.va.gov/sites/Northern‐Indiana/nihcspolicies/NIHCS Policies/00Q‐07.docx. All events related to patient injury, medication errors, and other breeches of patient safety shall be reported to the COR and the Chief, Medicine Service and the Risk Manager via the VA Incident Report. http://vaww4.va.gov/vaforms/
1.2.11. All new contract employees, prior to providing services, shall complete a formal orientation at the VANIHCS during normal duty hours and will be paid at the agreeable contract hourly rate for up to eight (8) hours. New employee orientation will be conducted at VANIHCS staff members. Minimum orientation requirements shall include the following: VAMC Mission/Vision/Values, all applicable VAMC policies and procedures, Patient Rights, suspected patient abuse reporting, Patient compliment/Complaint process, Safety, Patient Safety, Infection Prevention, Equipment Safety, Confidentiality, Emergency Preparedness, incident and emergency reporting, electronic medical record training, Operative/ Invasive and Noninvasive procedure process, Peer Review process, TORT claim process, and clinic procedures and processes.
1.2.12. A staffing plan, to include back‐up coverage, position descriptions, and competency assessment tools shall be approved by the VANIHCS prior to commencement of patient care activities. The plan shall ensure that non-privileged contracted physician(s) shall demonstrate initial and on‐going continuous qualifications and assessment of competencies, and will be evaluated within VANIHCS timeframes.
1.2.13. The resulting contract shall be a non‐personal services contract under which the personnel rendering services are not subject, either by the contract terms or manner of contract administration, to the supervision and control usually prevailing in relationships between the Government and its employees.
1.3. Place of Performance – VANIHCS 2121 Lake Avenue, Fort Wayne, In. 46805
1.4. Authority: Title 38 USC 8153, Health Care Resources (HCR) sharing Authority.
1.5. Policy/Handbooks:
1.5.1. - VA Directive 1663: Health Care Resources Contracting - Buying http://www1.va.gov/vapubs/viewPublication.asp?Pub_ID=347
1.5.2. VHA Directive 2006-041 “Veterans’ Health Care Service Standards” (expired but still in effect pending revision)
https://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=1443
1.5.3. - VHA Handbook 1100.17: National Practitioner Data Bank Reports - http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=2135
1.5.4. - VHA Handbook 1100.18 Reporting And Responding To State Licensing Boards - http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=1364
1.5.5. - VHA Handbook 1100.19 Credentialing and Privileging - http://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=2910
1.5.6. VHA Handbook 1907.01 Health Information Management and Health Records: http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=2791
1.5.7. - Privacy Act of 1974 (5 U.S.C. 552a) as amended http://www.justice.gov/oip/foia_updates/Vol_XVII_4/page2.htm
1.6. Definitions/Acronyms- Terms used in this contract shall be interpreted as follows unless the context expressly requires a different construction and/or interpretation. In case of a conflict in language between the Definitions and other sections of this contract, the language in this section shall govern.
1.6.1. ASN: American Society of Oncology http://www.asn-online.org/education/training/fellows/educational-resources.aspx#Guidelines
1.6.2. ASH: American Society of Hematology/Oncology
1.6.3. ACGME: Accreditation Council for Graduate Medical Education
1.6.4. ACLS: Advanced Cardiac Life Support
1.6.5. AOD: Admitting Officer of the Day
1.6.6. BLS: Basic Life Support
1.6.7. CCNE: Commission on Collegiate Nursing Education: www.aacn.nche.edu/accreditation
1.6.8. CDC: Centers for Disease Control and Prevention
1.6.9. CDR: Contract Discrepancy Report
1.6.10. CEU: Certified Education Unit
1.6.11. CME: Continuing Medical Education
1.6.12. CMS: Centers for Medicare and Medicaid Services
1.6.13. Contracting Officer (CO) – The person executing this contract on behalf of the Government with the authority to enter into and administer contracts and make related determinations and findings.
1.6.14. Contracting Officer’s Representative (COR) – A person appointed by the CO to take necessary action to ensure the Contractor performs in accordance with and adheres to the specifications contained in the contract and to protect the interest of the Government. The COR shall report to the CO promptly any indication of non-compliance in order that appropriate action can be taken.
1.6.15. COS: Chief of Staff
1.6.16. CPARS: Contractor Performance Assessment Reporting System
1.6.17. CPRS: Computerized Patient Recordkeeping System- electronic health record system used by the VA.
1.6.18. Credentialing: Credentialing is the systematic process of screening and evaluating qualification and other credentials, including licensure, required education, relevant training and experience and current competence and health status.
1.6.19. DEA: Drug Enforcement Agency
1.6.20. ED: Emergency Department
1.6.21. FSMB: Federation of State Medical Boards
1.6.22. Full Time Equivalent (FTE): VA’s definition for full time- working the equivalent of 80 hours every two weeks, 2080 hours per year. In calculating FTE, any hours not worked on national holidays shall not be included.
1.6.23. HHS: Department of Health and Human Services
1.6.24. HIPAA: Health Insurance Portability and Accountability Act
1.6.25. HR: Human Resources
1.6.26. ISO: Information Security Officer
1.6.27. Medical Emergency - a sudden onset of a medical condition manifesting itself by acute symptoms of sufficient severity that the absence of immediate medical attention could reasonably result in: Permanently placing a patient's health in jeopardy, causing other serious medical consequences, causing impairments to body functions, or causing serious or permanent dysfunction of any body-organ or part.
1.6.28. MCM: Medical Center Memorandum
1.6.29. MOD: Medical Officer of the Day
1.6.30. M&M: Morbidity and Mortality Conferences
1.6.31. National Provider Identifier (NPI): NPI is a standard, unique 10-digit numeric identifier required by HIPAA. The Veterans Health Administration must use NPIs in all HIPAA-standard electronic transactions for individual (health care practitioners) and organizational entities (medical centers).
1.6.32. NLNAC: National League for Nursing Accrediting Commission. www.nlnac.org
1.6.33. Non-Contract Provider - any person, organization, agency, or entity that is not directly or indirectly employed by the Contractor or any of its subcontractors
1.6.34. NP: Nurse Practitioner
1.6.35. NPPES: National Plan and Provider Enumeration System
1.6.36. PA: Physician Assistant
1.6.37. PALS: Pediatric Advanced Life Support
1.6.38. POP: Period of Performance
1.6.39. PPD: Purified Protein Derivative
1.6.40. PWS: Performance Work Statement
1.6.41. Privileging (Clinical Privileging): Privileging is the process by which a practitioner, licensed for 8independent practice; e.g., without supervision, direction, required sponsor, preceptor, mandatory collaboration, etc.; is permitted by law and the facility to practice independently, to provide specific medical or other patient care services within the scope of the individual’s license, based upon the individual’s clinical competence as determined by peer references, professional experience, health status, education, training and licensure. Clinical privileges must be facility-specific and provider-specific.
1.6.42. QA/QI: Quality Assurance/Quality Improvement
1.6.43. QM/PI: Quality Management/Performance Improvement
1.6.44. QASP: Quality Assurance Surveillance Plan
1.6.45. RCA: Root Cause Analysis
1.6.46. TJC: The Joint Commission
1.6.47. VANIHCS: Veterans Affairs Northern Indiana Health Care System
1.6.48. Veterans Health Administration (VHA): The central office for administration of the VA medical centers through throughout the United States. The VHA is located in Washington, D.C.
1.6.49. Veterans Integrated Services Network (VISN): The regional oversight for the VA medical centers in Michigan and Indiana.
1.6.50. VetPro: a federal web-based credentialing program for healthcare providers.
1.6.51. Veterans Affairs Medical Center (VAMC): Unless identified with the name of a different VA medical Center, for purposes of this contract, this term shall mean the VANIHCS Medical Center.
1.6.52. VHA: Veterans Health Administration
1.6.53. VISTA (Veterans Integrated Systems Technology Architecture): A PC based system that will capture and store clinical imagery, scanned documents and other non-textual data files and integrates them into patient’s medical record and with the hospital information system.
1.6.54. VISN: Veterans Integrated Service Network.
2. MEDICAL STAFF QUALIFICATIONS:
2.1. Staff/Facility
2.1.1. License – The Contractor’s physician (s) assigned by the Contractor to perform the services covered by this contract shall have a current license to practice medicine in any State, Territory, or Commonwealth of the United States or the District of Columbia) when services are performed onsite on VA property. The Contractor shall provide services that meet the standards as established by the Joint Commission (TJC) hospital standards, The Department of Veterans Affairs, and any other organization having review authority over operations of Medicine Services of the VA Northern Indiana Health Care System, Fort Wayne, Indiana.
All licenses held by the personnel working on this contract shall be full and unrestricted licenses. Contractor’s physician (s) who have current, full and unrestricted licenses in one or more states, but who have, or ever had, a license restricted, suspended, revoked, voluntarily revoked, voluntarily surrendered pending action or denied upon application will not be considered for the purposes of this contract.
2.1.2. Board Certification - All contract Hematology provider(s)shall be Board Certified by the American Board of Internal Medicine (ABIM) in Hematology and/or Oncology http://www.abim.org/exam/certification/hematology.aspx All continuing education courses required for maintaining certification must be kept up to date at all times. Documentation verifying current certification shall be provided by the Contractor to the VA COR on an annual basis for each year of contract performance.
2.1.3. Credentialing and Privileging –Credentialing and privileging is to be done in accordance with the provisions of VHA Handbook 1100.19. The Contractor is responsible to ensure that proposed provider (s) possesses the requisite credentials enabling the granting of privileges. No services shall be provided by any contract provider (s) prior to obtaining approval by the VANIHCS Professional Standards Board, Medical Executive Board and Medical Center Director. Privileges shall require renewal at least every two (2) years in accordance with the VANIHCS and TJC requirements.
2.1.3.1. The contractor shall submit the documentation listed below for review by the VANIHCS Credentialing Section. The Government reserves the right to limit the number of credentialing packages it will evaluate:
i. Application (VAF 10‐2850)
ii. Acknowledgement of Bylaws.
iii. Current curriculum vitae.
iv. Application for privileges
v. Copies of most recently held privileges at other facilities
vi. Copies of currently held licenses/registration.
vii. Three letters of reference addressing the status and clinical competence.
viii. A summary of continuing medical education credits received over the last year.
ix. A declaration of health status.
2.1.3.2. If a Contractor’s physician(s) is not credentialed and privileged or has credentials/privileges suspended or revoked, the Contractor shall furnish an acceptable substitute without any additional cost to the government.
2.1.4. Technical Proficiency - Contractor’s physician(s) shall be technically proficient in the skills necessary to fulfill the government’s requirements, including the ability to speak, understand, read and write English fluently. Contractor shall provide documents upon request of the CO/COR to verify current and ongoing competency, skills, certification and/or licensure related to the provision of care, treatment and/or services performed. Contractor’s physicians shall have knowledge of professional care theories, principles, practices, and procedures to perform assignments of Hematology/Oncology patient/critically ill patient population. Contractor’s physician shall demonstrate knowledge of growth and development, and pathophysiology of disease processes specific to the critical care/Oncology population. Contractor shall provide verifiable evidence of all educational and training experiences including any gaps in educational history for all contract provider (s)and contractor’s physician(s)shall be responsible for abiding by the Facility's Medical Staff By-Laws, rules, and regulations (referenced herein) that govern behavior. The contract LIP shall practice within a framework that is clinically relevant and scientifically valid. Provision of care shall be based on clinical standards of practice, and scientifically based clinical practice guidelines which have been approved for use by the VHA, Veterans Integrated Service Network (VISN) or facility medical executive staff. Clinical reminders shall be used when available. Contracted physician staff shall sign and agree to adhere to VAMC Medical Staff Bylaws, Rules and Regulations. The contracted physician shall provide input as requested in regards to budget, scope of services provided, and resource allocation. The contractor physicians shall assume the leadership role for improvement activities in the clinic.
2.1.5. Continuing Medical Education (CME)/ Certified Education Unit (CEU) Requirements: Contractor shall provide the COR copies of current CMEs as required or requested by the VAMC. Contractor’s physician(s) registered or certified by national/medical associations shall continue to meet the minimum standards for CME to remain current. Contractor shall report CME hours to the credentials office for tracking. These documents are required for both privileging and re-privileging. Failure to provide shall result in loss of privileges for contract physician(s).
2.1.6. Training (CPRS and VA MANDATORY): Contractor shall meet all VA educational requirements and mandatory course requirements defined herein; all training must be completed by the Contractor’s physician(s) as required by the VA.
All training required, frequency and associated time
Training Frequency (once a year, etc) Annual Hours
VA Information Security Awareness and Rules of Behavior Once a year – end of fiscal year
VHA Privacy and Policy Once a year – end of fiscal year
2.1.7. Standard Personnel Testing (PPD, etc.): Contractor shall provide proof of the following tests for physicians within five (5) calendar days after contract award and prior to the first duty shift to the COR and Contracting Officer. Tests shall be current within the past year.
2.1.7.1. TUBERCULOSIS TESTING: Contractor shall provide proof of a negative reaction to PPD testing for all contract physician (s). A negative chest radiographic report for active tuberculosis shall be provided in cases of positive PPD results. The PPD test shall be repeated annually.
2.1.7.2. RUBELLA TESTING: Contractor shall provide proof of immunization for all Contractors’ physician(s) for measles, mumps, rubella or a rubella titer of 1.8 or greater. If the titer is less than 1.8, a rubella immunization shall be administered with follow-up documentation to the COR.
2.1.7.3. OSHA REGULATION CONCERNING OCCUPATIONAL EXPOSURE TO BLOODBORNE PATHOGENS: Contractor shall provide generic self-study training for all contract physician(s); provide their own Hepatitis B vaccination series at no cost to the VA if they elect to receive it; maintain an exposure determination and control plan; maintain required records; and ensure that proper follow-up evaluation is provided following an exposure incident. The VAMC shall notify the Contractor of any significant communicable disease exposures as appropriate. Contractor shall adhere to current CDC/HICPAC Guideline for Infection Control in health care personnel ( as published in American Journal for Infection Control- AJIC 1998; 26:289-354 http://www.cdc.gov/hicpac/pdf/InfectControl98.pdf) for disease control. Contractor shall provide follow up documentation of clearance to return to the workplace prior to their return.
2.1.8. National Provider Identifier (NPI): NPI is a standard, unique 10-digit numeric identifier required by HIPAA. The Veterans Health Administration must use NPIs in all HIPAA-standard electronic transactions for individual (health care practitioners) and organizational entities (medical centers). The Contractor shall have or obtain appropriate NPI and if pertinent the Taxonomy Code confirmation notice issued by the Centers for Medicare and Medicaid Services (CMS) National Plan and Provider Enumeration System (NPPES) be provided to the Contracting Officer with the proposal.
2.1.9. DEA (as required) - Contractor shall provide copy of current DEA certificate.
2.1.10. Conflict of Interest: The Contractor and all Contractors’ physician(s) are responsible for identifying and communicating to the CO and COR conflicts of interest at the time of proposal and during the entirety of contract performance. At the time of proposal, the Contractor shall provide a statement which describes, in a concise manner, all relevant facts concerning any past, present, or currently planned interest (financial, contractual, organizational, or otherwise) or actual or potential organizational conflicts of interest relating to the services to be provided. The Contractor shall also provide statements containing the same information for any identified consultants or subcontractors who shall provide services. The Contractor must also provide relevant facts that show how it’s organizational and/or management system or other actions would avoid or mitigate any actual or potential organizational conflicts of interest. These statements shall be in response to the VAAR provision 852.209-70 Organizational Conflicts of Interest (Jan 2008) and fully outlined in response to the subject attachment in Section D of the solicitation document.
2.1.11. Citizenship related Requirements:
2.1.11.1. The Contractor certifies that the Contractor shall comply with any and all legal provisions contained in the Immigration and Nationality Act of 1952, As Amended; its related laws and regulations that are enforced by Homeland Security, Immigration and Customs Enforcement and the U.S Department of Labor as these may relate to non-immigrant foreign nationals working under contract or subcontract for the Contractor while providing services to Department of Veterans Affairs patient referrals;
2.1.11.2. While performing services for the Department of Veterans Affairs, the Contractor shall not knowingly employ, contract or subcontract with an illegal alien; foreign national non-immigrant who is in violation their status, as a result of their failure to maintain or comply with the terms and conditions of their admission into the United States. Additionally, the Contractor is required to comply with all “E-Verify” requirements consistent with “Executive Order 12989” and any related pertinent Amendments, as well as applicable Federal Acquisition Regulations.
2.1.11.3. If the Contractor fails to comply with any requirements outlined in the preceding paragraphs or its Agency regulations, the Department of Veterans Affairs may, at its discretion, require that the foreign national who failed to maintain their legal status in the United States or otherwise failed to comply with the requirements of the laws administered by Homeland Security, Immigration and Customs Enforcement and the U.S Department of Labor, shall be prohibited from working at the Contractor’s place of business that services Department of Veterans Affairs patient referrals; or other place where the Contractor provides services to veterans who have been referred by the Department of Veterans Affairs; and shall form the basis for termination of this contract for breach.
2.1.11.4. This certification concerns a matter within the jurisdiction of an agency of the United States and the making of a false, fictitious, or fraudulent certification may render the maker subject to prosecution under 18 U.S.C. 1001.
2.1.11.5. The Contractor agrees to obtain a similar certification from its subcontractors. The certification shall be made as part of the offerors response to the RFP using the subject attachment in Section D of the solicitation document.
2.1.12. Annual Office of Inspector General (OIG) Statement: In accordance with HIPAA and the Balanced Budget Act (BBA) of 1977, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) has established a list of parties and entities excluded from Federal health care programs. Specifically, the listed parties and entities may not receive Federal Health Care program payments due to fraud and/or abuse of the Medicare and Medicaid programs.
2.1.12.1. Therefore, Contractor shall review the HHS OIG List of Excluded Individuals/Entities on the HHS OIG web site at http://oig.hhs.gov/exclusions/index.asp to ensure that the proposed Contractor’s physician(s) are not listed. Contractor should note that any excluded individual or entity that submits a claim for reimbursement to a Federal health care program, or causes such a claim to be submitted, may be subject to a Civil Monetary Penalty (CMP) for each item or service furnished during a period that the person was excluded and may also be subject to treble damages for the amount claimed for each item or service. CMP’s may also be imposed against the Contractor that employ or enter into contracts with excluded individuals to provide items or services to Federal program beneficiaries.
2.1.12.2. By submitting their proposal, the Contractor certifies that the HHS OIG List of Excluded Individuals/Entities has been reviewed and that the Contractors are and/or firm is not listed as of the date the offer/bid was signed.
2.2. Clinical/Professional Performance: The qualifications of Contractor personnel are subject to review by VA Medical Center COS or his/her clinical designee and approval by the Medical Center Director as provided in VHA Handbook 1100.19. Clinical/Professional performance monitoring and review of all clinical personnel covered by this contract, for quality purposes, will be provided by the VAMC COS and/or the Chief of the Service or his designee. A clinical COR may be appointed, however, only the CO is authorized to consider any contract modification request and/or make changes to the contract during the administration of the resultant contract.
2.3. Non Personal Healthcare Services: The parties agree that the Contractor and all Contractors’ physician(s) shall not be considered VA employees for any purpose.
2.4. Indemnification: The Contractor shall be liable for, and shall indemnify and hold harmless the Government against, all actions or claims for loss of or damage to property or the injury or death of persons, arising out of or resulting from the fault, negligence, or act or omission of the Contractor, its agents, or employees.
2.5. Prohibition against Self-Referral: Contractor’s physicians are prohibited from referring VA patients to contractor’s or their own practice(s).
2.6. Inherent Government Functions: Contractor and Contractor’s physician(s) shall not perform inherently governmental functions. This includes, but is not limited to, determination of agency policy, determination of Federal program priorities for budget requests, direction and control of government employees (outside a clinical context), selection or non-selection of individuals for Federal Government employment including the interviewing of individuals for employment, approval of position descriptions and performance standards for Federal employees, approving any contractual documents, approval of Federal licensing actions and inspections, and/or determination of budget policy, guidance, and strategy.
2.7. No Employee status: The Contractor shall be responsible for protecting Contractor’s physician(s) furnishing services. To carry out this responsibility, the Contractor shall provide or certify that the following is provided for all their staff providing services under the resultant contract:
2.7.1. Workers’ compensation
2.7.2. Professional liability insurance
2.7.3. Health examinations
2.7.4. Income tax withholding, and
2.7.5. Social security payments.
2.8. Tort Liability: The Federal Tort Claims Act does not cover Contractor or contract provider(s). When a Contractor or contract provider (s) has been identified as a provider in a tort claim, the Contractor shall be responsible for notifying their legal counsel and/or insurance carrier. Any settlement or judgment arising from a Contractor’s (or contract physician(s)) action or non-action shall be the responsibility of the Contractor and/or insurance carrier.
2.9. Key Personnel:
2.9.1. The VA Full Time Equivalency (FTE) for the services required is 1.0 FTE.
2.9.2. The number of Board Certified Hematology/Oncology providers required to be on site four (4) days a week is 0.8 as defined in paragraph Hours of Operation in this section.
2.9.3. The VANIHCS reserves the right to refuse key personnel under this contract or require dismissal from contract work of any contractor employee who, by reason of previous unsatisfactory performance at the VANIHCS or for any other reasonable reason, is considered by the Contracting Officer to be objectionable, as long as 30 days written notification of unsatisfactory performance has been provided to the contractor and the problem has not been cured in the 30-day period.
2.9.4. The Contractor shall be responsible for providing coverage to the VA during periods of vacancies of the Contractor’s personnel due to sick leave, personal leave, vacations and additional coverage as required. In the event a scheduled physician is unable to complete an assigned shift, the contractor shall provide replacement physician coverage within 2 hours and notify the Contracting Office Representative (COR) at the (VANIHCS) immediately of the schedule change.
2.9.5. Contractor shall be required to wear the Government furnished picture ID badge during the entire time he/she is on VA grounds. Special clothing, i.e. surgical scrubs, provided by the VANIHCS shall be left at the workstations upon completion of surgical procedures or clinics.
2.9.6. Personnel Substitutions: During the first ninety (90) calendar days of performance, the Contractor shall make NO substitutions of key personnel unless the substitution is necessitated by illness, death or termination of employment. The Contractor shall notify the CO, in writing, within 1 (one) calendar day (s) after the occurrence of any of these events and provide the information required below. After 90 days, the Contractor shall submit the information required below to the CO at least 14 calendar days prior to making any permanent substitutions.
2.9.6.1. The Contractor shall provide a detailed explanation of the circumstances necessitating the proposed substitutions, complete resumes for the proposed substitutes, and any additional information requested by the CO. Proposed substitutes shall have comparable qualifications to those of the persons being replaced. The CO will notify the Contractor within 14 calendar days after receipt of all required information of the decision on the proposed substitutes. The contract will be modified to reflect any approved changes of key personnel.
2.9.6.2. The contractor shall provide a telephone number to provide point of contact for VANIHCS staff. The contractor staff assigned to answer this telephone shall act as the initial point of contact for inquiries from appropriate VANIHCS personnel.
2.9.6.3. For temporary substitutions where the key person shall not be reporting to work for three, 3, consecutive work days or more, the Contractor shall provide a qualified replacement for the key person. The substitute shall have comparable qualifications to the key person. Any period exceeding two weeks will require the procedure as stated above.
2.9.6.4. The Government reserves the right to refuse acceptance of any Contractor personnel at any time after performance begins, if personal or professional conduct jeopardizes patient care or interferes with the regular and ordinary operation of the facility. Breaches of conduct include intoxication or debilitation resulting from drug use, theft, patient abuse, dereliction or negligence in performing directed tasks, or other conduct resulting in formal complaints by patient or other staff members to designated Government representatives. Standards for conduct shall mirror those prescribed by current federal personnel regulations. Should the VA COS or designee show documented clinical problems or continual unprofessional behavior/actions with any Contractor’s physician (s), s/he may request, without cause, immediate replacement of said Contractor’s physician (s). The CO and COR shall deal with issues raised concerning Contractor’s physician (s) conduct. The final arbiter on questions of acceptability is the CO.
2.9.6.5. Contingency Plan: Because continuity of care is an essential part of VAMC’s medical services, The Contractor shall have a contingency plan in place to be utilized if the Contractor’s physician (s) leaves Contractor’s employment or is unable to continue performance in accordance with the terms and conditions of the resulting contract.
2.9.6.6. In the event violations of VA policies, procedures, bylaws or TJC standards are found on the part of the Contractor’s key personnel performing work under this contract, the VA reserves the right to direct the Contractor to discontinue the services of the key personnel. The Contractor shall provide for continuous coverage with approved key personnel at all times.
3. VA HOURS OF OPERATION/SCHEDULING:
3.1. VA Business Hours: 8am to 4:30pm / Monday thru Friday
Clinic/Schedule: Four (4) days a week (to be determined)
3.1.1. Patients must be seen by a Contractor’s physician(s) on-site at VANIHCS in a timely manner in accordance with VA Rules and Regulations on clinic wait times and consult completion. Contractor shall notify the COR at least monthly about any obstacles to meeting this performance measure.
3.1.2. Contractor’s physician(s) shall arrival and present in clinic during normal VANIHCS clinic hours, which will be established, and may be revised, as deemed appropriate for patient care by the Chief of Staff. Currently, normal clinic hours are 8am to 4:30pm. The contractors’ physicians shall remain at the VANIHCS until all clinics, schedules procedures, inpatient rounds, and administrative rounds are completed.
3.1.3. Hours for Call Coverage:
3.1.3.1. 8:00am to 4:30pm, Monday thru Friday, one (1) day a week. The Contractor personnel shall be available to provide emergency services and have VA privileges during normal business hours exclusive of federal holidays listed in paragraph 3.2
3.2. Federal Holidays: The following holidays are observed by the Department of Veterans Affairs:
• New Year’s Day
• President’s Day
• Martin Luther King’s Birthday
• Memorial Day
• Independence Day
• Labor Day
• Columbus Day
• Veterans Day
• Thanksgiving
• Christmas
• Any day specifically declared by the President of the United States to be a national holiday.
3.2.1. If, during the course of the contract, it becomes evident VA clinical and administrative workloads do not consistently warrant services throughout normal work hours, the contractor shall notify the COR so scheduling can be adjusted to ensure the services of key personnel are properly and effectively utilized.
3.2.2. Unless a state of emergency has been declared, the Contractor shall be responsible for providing services.
4. CONTRACTOR RESPONSIBILITIES
4.1. Contractor and Personnel Security Requirements: Contractor’s physicians who require access to the Department of Veterans Affairs’ computer systems shall be the subject of a security investigation and shall receive a favorable adjudication from the VHA Service Center (VSC). In all cases, access (physical and computer) cannot be granted until officially notified by the VSC in Independence, Ohio. Access can be granted prior to receiving favorable special agreement check (SAC) adjudication results (e.g. fingerprints). If the investigation is not completed prior to the start date of the contract, the contractor shall be responsible for the action(s) of those individuals they provide to perform work under the contract at and for the RLR VAMC (Computer Access Medical Center Memorandum OI&T-41).
4.1.1. Position Sensitivity: Position sensitivity for each contractor’s physicians’ position is determined by the VA through the automated Position Designation of National Security and Public Trust (PDAT). Each position will be designated at the high, moderate, or low risk level, depending on the position’s potential for adverse impact to the integrity and efficiency of the services (CFR 731.106). Multiple positions may be documented on a single form. Risk levels determine what level of investigation is required.
4.1.2. Personal Identification Verification (PIV): The contractor’s physicians shall maintain active computer access by logging into a VA computer no less than once every 30 days. To assist contractor’s physicians with maintaining compliance, VPN may be approved on a case-by-case basis.
4.1.3. Security Investigation: The level of background investigation commensurate with the required level of access may be either a Special Agreement Check (SAC), National Agency Check with Written Inquiries (NACI) (low risk), Moderate Background Investigation (MBI) (moderate risk), or Background Investigation (high risk). Non-citizen contractor’s physicians appointed to low risk positions shall be subject to a National Agency Check with Law Enforcement and Credit Check (NACLC). The risk level associated with contractor’s physicians under this contract is: LOW RISK/NACI.
4.1.4. Contractor Responsibilities: The contractor shall prescreen all contractor’s physicians requiring access to the computer systems to ensure they are able to read, write, speak, and understand the English language.
4.1.4.1. Contractor’s physicians shall receive an automated e-QIP invitation, which shall be completed and scanned or faxed to the appropriate individual identified within the automated email request. The two (2) e-QIP signature pages shall be completed and returned within seven (7) days of the request; otherwise, the security investigation shall be terminated and contractor’s physician shall begin the process all over, if the CO warrants this. Contractor’s physicians shall receive e-mail notifications from the VSC explaining specific instructions once an investigation has been received.
4.1.4.2. The contractor shall submit all security investigation requests to the COR and CO, who will review, sign, and submit the forms to the VSC at the following email mail group: VSCSecurity@va.gov. The security investigation(s) will be assigned to a specific VSC Security Assistant. Once the investigation(s) is assigned for the specific contract number, the VSC Security Assistant handling the investigation will be the responsible individual during the duration of the task order (including all option years associated with it). Then, all new contractor’s physicians will be directly submitted to the VSC Security Assistant.
4.1.4.3. The different level of investigation required forms are as follows:
• Low Risk/NACI – VSC Security Request Packet, OF 306 and Fingerprints
• Moderate Risk/MBI – VSC Security Request Packet, SF 85 and Fingerprints
• High Risk/BI – VSC Security Request Packet, SF85P and Fingerprints
All forms shall be completed entirely and properly. The continuation form shall only be used if the contractor employee requires extra space.
4.1.4.4. The contractor’s physicians shall be fingerprinted as part of an investigation. Electronic fingerprinting can be performed at the RLR VAMC VA HR Offices. These stations use electronic fingerprint machines, which require the contractor’s physicians to fill out Form #2 of the VSC Security Request Packet. This form needs to be taken with the contractor’s physicians when getting fingerprinted at the RLR VAMC. Once fingerprinting is complete, VA HR will return the form, which the contractor’s physician needs to submit with the other documentation in the VSC Security Packet and submit to the VSC for review and verification purposes.
4.1.4.5. Once the contractor’s physician’s security investigation is in a “scheduled” status, the VSC Security Assistant will obtain the va.gov address established for the contractor’s physician and sponsor him/her for a PIV badge. NOTE: PIV Badging for contractor’s physicians shall only be handled and coordinated through Contracting and the VSC.
4.1.4.6. The Contractor shall, when notified of an unfavorable determination by the Government, withdraw the contractor’s physician from consideration from performing services under the contract. Final adjudication results may take up to six (6) months but are normally received within 90 days after submission.
4.1.4.7. Failure to comply with the contractor personnel security requirements shall result in termination of the contract for cause.
4.1.4.8. Upon contract award, the contractor shall furnish the ISO and the CO with a list of contractor’s physicians performing work under the contract. The list shall include a brief description of the work to be performed and degree of access to information management systems required. The description of the required degree of access shall address if remote access is required. The contractor shall update and submit the list of contractor’s physicians performing work on the contract to the ISO every year, throughout the contract period. Furthermore, it shall be the contractor’s responsibility to notify the ISO when contractor’s physicians performing work under this contract no longer require access to information management systems.
5. GOVERNMENT RESPONSIBILITIES
5.1 Upon receipt, the VSC will review the completed forms for accuracy, forward the forms to the SIC for processing and issue to OPM to initiate the security investigation.
5.1.1 The VA facility will pay for investigations conducted by OPM in advance. In these instances, the contractor shall reimburse the VA facility within 30 days of receiving the BoC.
5.1.2. The VSC and/or the SIC will notify the CO and contractor after adjudicating the results of the security investigations received from OPM, which can take up to six (6) months.
5.1.3. The CO will ensure the contractor provides evidence the investigation(s) have been completed or are in the process of being requested.
5.1.4. Contractor’s physicians performing work under this contract shall satisfy all requirements for appropriate security eligibility in dealing with access to sensitive information and information systems belonging to or being used on behalf of the Department of Veterans Affairs. The contractor shall be responsible for the actions of those individuals they provide to perform work for the VA under this contract. In the event damages arise from work performed by contractor providing contractor’s physicians, under the auspices of this contract, the contractor shall be responsible for all resources necessary to remedy the incident. Printed output containing sensitive VHA data shall be stored in a secured area, and disposed of properly by shredding using a NIST-compliant shredder or other VA approved method. Under the provisions of the Privacy Act of 1974 as amended, personnel performing work under this contract have an obligation to protect VA information indefinitely. Furthermore, it is the Contractor’s responsibility to notify the Information Management staff when access to Information Management systems is no longer needed by contractor’s physicians performing work under this contract.
5.1.5. If deemed required under this contract, the contractor shall be considered part of the VA for purposes of 38 U.S.C. §§ 5701 and 7332. Its employees may have access to patient medical records to the extent necessary to perform this contract. Notwithstanding any other provision of this contract, the contractor and contractor’s physicians may disclose patient records and individually-identified patient information, including information and records generated by the contractor in performance of this contract, only pursuant to explicit disclosure authority from VA.
5.1.6. The VA may provide contractor and contractor’s physicians with access to VA automated patient records maintained on VA computer systems only to the extent and under the same conditions and requirements as VA provides access to these records to its own employees.
5.1.7. All contractor’s physicians the VISTA system shall be required to sign and abide by all VA security policies, and applicable VA confidentiality statutes, 38 U.S.C. §5701, 38 U.S.C. §7332, and the Privacy Act, 5 U.S.C. §552a, as well as 45 C.F.R. Parts 160, 162 and 164 (HIPAA). The VA will provide access applications and security agreements. Contractor shall ensure the confidentiality of all patient information and shall be held liable in the event of the breach of confidentiality. Due to the confidential nature of medical reports, all transcription shall be completed in areas that provide reasonable security. All documents are confidential and are protected under the Privacy Act of 1974, as amended. All contractor’s physicians shall be required to observe the requirements imposed on sensitive data by law, federal regulations, VA statutes and policy, DM&S policy and the associated requirements to insure appropriate screening of personnel.
5.1.8. If deemed required under this contract the database utilized by the contractor, the adverse drug event reports provided to the contractor by VA, and documents created from analyzing this database, the adverse drug event reports, and patient medical records are medical QA records protected by 38 U.S.C. § 5705, its implementing regulations at 38 U.S.C. §§ 17.500-.511 and VHA Directive 2002-043, Quality Management (QM) And Patient Safety Activities That Can Generate Confidential Documents. These records may be disclosed only as authorized by § 5705 and the VA regulations. Disclosure of these records in violation of § 5705 is a criminal offense under 38 U.S.C. § 5705(e).
5.1.9. If deemed required under this contract, the treatment and administrative patient records created by, or provided to, the contractor under this contract are covered by the VA system of records entitled "Patient Medical Records” - VA (24VA136).
5.1.10. All quality data maintained by the Contractor and/or the contractor’s physicians shall be shared with designated Service Line Staff.
5.1.11. No VA data is permitted to be stored on portable media, including flash drives, CDs/DVDs, external hard drives, without obtaining a waiver. Waiver request forms can be obtained from the VA ISO. Any portable media that is granted approval to be utilized by the contractor under this contract shall be encrypted in accordance with the security requirements identified in FIPS 140-2. Only flash drives and encryption software explicitly approved by the VA may be used if granted a waiver.
5.1.12. No VA data is permitted to be stored on a desktop or laptop computer hard drive. Use of any portable computer under this contract shall be approved by the ISO, and the computer’s hard drive shall be encrypted in accordance with FIPS 140-2.
5.1.13. Non-VA equipment is not permitted to be connected to the VA network without prior approval. If a laptop or desktop computer must be connected, a security check shall be completed by the VA IT Staff. If unapproved equipment is detected, it shall be immediately disconnected from the network.
5.1.14. If remote access is required in order to perform the work in this contract, a Virtual Private Network (VPN) request form shall be completed and approved by the COR, the VA CIO, and submitted to the ISO. The account shall be given access only to the IP addresses required by this contract.
5.1.15. Contractor’s physicians shall not be permitted to have administrative rights on a VA server without an approved waiver. Contractor’s physicians shall work with the local VA IT staff to perform administrative functions. A waiver shall only be granted in cases in which this is not possible or not feasible. The waiver shall be approved by the VA Chief Information Officer (CIO) and submitted to the ISO.
6. SPECIAL CONTRACT REQUIREMENTS:
6.1 Due to the increased emphasis on privacy and information security, compliance with 38 U.S.C. 5701, 38 U.S.C. 5705, 38 U.S.C. 7332 shall be required and the following special contract requirements are established and hereby made part of the contract entered into with the Department of Veterans Affairs.
6.1.1. Privacy Training: Contractor and their sub‐contractors assigned work under this contract shall be required to receive annual training on patient privacy as established by HIPAA statutes. Training shall meet VHA’s and the Department of Health and Human Services Standards for Privacy of Individually‐identifiable health information. Contractor shall provide documented proof to the contracting officer that all employees assigned work and/or having access to Protected Health Information have received annual training. Proof of training shall be forwarded to the Contracting Officer. VHA will pay for eight (8) hours of training.
6.1.2. VA Information Security Awareness Training: In order for contractor personnel to engage in work at the VA, contractor personnel shall be required to complete a mandatory training program titled VA Privacy and Information Security Awareness Training and Rules of Behavior. This training is offered through the VA Talent Management System (TMS), a system offering web‐based training to VA employees and its partners (https://www.tms.va.gov/learning/user/login.jsp). Each contractor assigned work under this contract shall be required to receive and document completion of VA training. Proof of training shall be forwarded to the Contracting Officer.
6.1.3. Rules of Behavior for Automated Information Systems: Contractor personnel having access to VA Information Systems shall be required to read and sign a Rules of Behavior statement, which outlines rules of behavior related to VA Automated Information Systems. The COR shall provide, through the facility Information Security Officer, the VISN 10 Rules of Behavior to all Contractor employees performing under this contract. A copy of this document shall be forwarded to the Contracting Officer upon completion.
6.2. 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.
6.3. Reports/Deliverables: The Contractor shall be responsible for complying with all reporting requirements established by the Contract. Contractor shall be responsible for assuring the accuracy and completeness of all reports and other documents as well as the timely submission of each. Contractor shall comply with contract requirements regarding the appropriate reporting formats, instructions, submission timetables, and technical assistance as required.
6.3.1. The following are brief descriptions of required documents that must be submitted by Contractor: upon award; weekly; monthly; quarterly’; annually, etc. identified throughout the PWS and is provided here as a guide for Contractor convenience. If an item is within the PWS and not listed here, the Contractor remains responsible for the delivery of the item.
What Submit as noted Submit To
Copies of any and all licenses, board certifications, NPI, to include primary source verification of all licensed and certified staff Upon proposal and upon renewal of licenses and upon renewal of option periods or change of key personnel. Contracting Officer with proposal
Certification that staff list have been compared to OIG list Upon proposal and upon new hires. Contracting Officer
Proof of Indemnification and Medical Liability Insurance Upon proposal and upon renewals. Contracting Officer
Certificates of Completion for Cyber Security and Patient Privacy Training Courses Before receiving an account on VA Network and annual training and new hires. Contracting Officer
ACLS/BLS Certification Upon award and every two years after award. COR
Contingency plan for replacing key personnel to maintain services as required under the terms of the contract Upon proposal and as updated COR
6.4. Billing:
6.4.1. Invoice requirements and supporting documentation: The Contractor shall submit an original monthly invoice and supporting documentation for the previous month’s services Invoices no later than the 20th workday of the month. Invoices without proper documentation shall be returned and no advance payments shall be authorized.
6.4.2. Subsequent changes or corrections shall be submitted by separate invoice. In addition to information required for submission of a “proper” invoice in accordance with FAR 52.212-4 (g), all invoices must include:
6.4.2.1. Name and Address of Contractor
6.4.2.2. Invoice Date and Invoice Number
6.4.2.3. Contract Number and Purchase/Task Order Number
6.4.2.4. Date of Service
6.4.2.5. Contractor’s physician(s)
6.4.2.6. Hourly Rate
6.4.2.7. Quantity of hours worked
6.4.2.8. Total price
6.4.3. The Contractor shall not invoice until all required documentation is complete ( i.e., completed clinic attendance sheets, pre‐procedures notes, progress notes, operation report dictated and signed by the contracted physician(s).
6.4.4. If the supporting documentation is not received before the invoice is processed, the invoice shall be considered incomplete and returned.
6.4.5. The invoice may be resubmitted after completion of all required documentation. However, for the purpose of computing interest under the prompt payment act, invoice receipt date shall be the date the resubmitted invoice is received at VANIHCS.
6.4.6. Payment shall be made in arrears upon submission of a properly prepared invoice. Invoices shall be fully itemized, listing dates and hours worked, contracted physician(s) unit and total dollar amounts. The total hours worked shall match with the total hours worked on the report provided by the COR officer. The contract number shall also appear on all invoices and correspondence.
6.5. Vendor Electronic Invoice Submission Methods
Facsimile, e-mail, and scanned documents are not acceptable forms of submission for payment requests. Electronic form means an automated system transmitting information electronically according to the accepted electronic data transmission methods below:
6.5.1. VA’s Electronic Invoice Presentment and Payment System – Payments under this contract shall be made in accordance FAR 52.232‐34. The FSC uses a third-party contractor, OB10, to transition vendors from paper to electronic invoice submission. Please go to this website: http://ob10.com/us/en/veterans-affairs-us/ to begin submitting electronic invoices, free of charge.
6.5.2. A system that conforms to the X12 electronic data interchange (EDI) formats established by the Accredited Standards Center (ASC) chartered by the American National Standards Institute (ANSI).
The X12 EDI Web site (http://www.x12.org).
6.5.3. The Contract may contact FSC at the phone number or email address listed below with any questions about the e-invoicing program or OB10:
6.5.3.1. OB10 e-Invoice Setup Information: 1-877-489-6135
6.5.3.2. OB10 e-Invoice email: VA.Registration@ob10.com
6.5.3.3. FSC e-Invoice Contact Information: 1-877-353-9791
6.5.3.4. FSC e-invoice email: vafsccshd@va.gov
6.6. Payment Adjustments/Performance Related Payment Deductions:
6.6.1. Invoices will be for hours worked. The contractor shall be paid only for actual work performed onsite. Contract providers shall be responsible for reporting time worked accurately. The Contract shall be paid for actual hours performed.
6.7. Payments in full/no billing VA beneficiaries: The Contractor shall accept payment for services rendered under this contract as payment in full. VA beneficiaries shall not under any circumstances be charged nor their insurance companies charged for services rendered by the Contractor, even if VA does not pay for those services. This provision shall survive the termination or ending of the contract.
6.7.1. To the extent that the Veteran desires services which are not a VA benefit or covered under the terms of this contract, the Contractor must notify the Veteran that there will be a charge for such service and that the VA will not be responsible for payment.
6.7.2. The Contractor shall not bill, charge, collect a deposit from, seek compensation, remuneration, or reimbursement from, or have any recourse against, any person or entity other than VA for services provided pursuant to this contract. It shall be considered fraudulent for the Contractor to bill other third party insurance sources (including Medicare) for services rendered to Veteran enrollees under this contract.
