This is a SOURCES SOUGHT announcement only. It is neither a solicitation announcement nor a request for proposal or quote and does not obligate the Government to award a contract. Responses to this Sources Sought must be in writing. The purpose of this Sources Sought Announcement is for market research, to make appropriate acquisition decisions, and to gain knowledge of potential qualified businesses capable of providing the following: Pharmacy Benefit Service *** See Statement of Requirement below for details *** If this is within your capability, please respond with the information below: Company Name Address Point of Contact Phone, Fax, and Email DUNS number GSA Contract (as applicable) Interested firms are reminded that in accordance with FAR 4.12, prospective contractors shall complete electronic annual representations and certifications to be considered for award. In addition, FAR 4.11 states that prospective contractors shall be registered in the System for Award Management (www.SAM.gov) database. All Service-Disabled Veteran Owned Small Businesses (SDVOSB) and Veteran Owned Small Businesses (VOSB) shall be verified in Vet Cert at veterans.certify.sba.gov. Point of Contact for this Sources Sought is: ronald.castle@va.gov (913) 946 - 1166 Department of Veterans Affairs Network Contracting Office -15 3450 S. 4th Street Trafficway Leavenworth, KS. 66048. Statement of Work (SOW) FOR First Fill Prescription Voucher Program VETERANS HEALTH ADMINISTRATION 23 October 2023 REQUIREMENT The Contractor shall provide third-party pharmacy benefit services to perform first or urgent fill pharmacy services. This service is needed to provide Veterans with their first or urgent fill of drugs prescribed by the Robert J. Dole VA Medical Center (RJDVA) when RJDVA pharmacies are either incapable of doing so or it is impractical for RJDVA pharmacies to do so, such as in the case of after-hours emergency room visits, time sensitive medications needed from Community Based Outreach Clinics (CBOCs), or telehealth appointments. PHARMACY NETWORK Contractor s network pharmacies network must be capable of servicing the entire Network area. The network shall include compounding pharmacies. LICENSING AND QUALIFICATION REQUIREMENTS Pharmacies utilized shall be in good standing with their respective State Board of Pharmacy (or equivalent state agency). The pharmacies shall have a current Drug Enforcement Administration (DEA) license, controlled substance license, and license from the respective State Board of Pharmacy. Pharmacist Requirements: a. Be a graduate of an Accreditation Council for Pharmacy Education (ACPE) College of Pharmacy. b. Be licensed in the relevant state and in good standing with the State Board of Pharmacy. Pharmacy Requirements: a. Be licensed pharmacy in the relevant state. b. Hold a current DEA license, controlled substance license. SCOPE OF WORK This process is only for new, one-time prescriptions. No refills will be authorized. Contract pharmacy will fill and dispense original prescriptions that are written by VA providers assigned to VA facilities. Contractor s pharmacies will compound prescriptions if necessary. Contract pharmacy must be able to support eligible patients of the Robert J Dole VA Medical Center, its community-based outpatient clinics (CBOCs), and its Home-Based Primary Care (HBPC) program, including any new future CBOC locations. The contract pharmacy network must include pharmacies that will dispense after-hours, over the weekend, and on federal holidays. DESCRIPTION OF WORK A. Prescriptions filled will be in written form provided by a RJDVA provider, a CBOC provider, or a HBPC VA provider. Dispensing pharmacies must be able to accept the written prescription. The Contractor will accept a phone call or an electronic e-mail from the Facility POC advising him/her of any new VA providers by providing the National Provider Identifier (NPI) number. B. Urgent prescriptions will be filled and dispensed only for medications listed in formulary list as authorized by the RJDVA. The formulary list shall be e-mailed to the contractor after each update by the Chief of Pharmacy or his/her designee. There shall be a mechanism in place, provided by the contractor, to provide real-time messaging and hard edits to the pharmacies to limit dispensed medications to the formulary list to prevent non-formulary or prior authorization medications from being dispensed without specific prior approval by the Chief of Pharmacy or his/her designee. In addition, there must be a mechanism in place to update the formulary list as needed. C. Prescriptions shall be filled and limited to a maximum of a ten (10) day supply except for antibiotics and antibacterial agents which shall be limited to a maximum of a fourteen (14) day supply. No prescription refills will be authorized. All prescriptions must have proper auxiliary labels attached and appropriate counseling and drug interaction sheets provided. D. In the event of a pandemic or natural disaster resulting in the loss of pharmacy services, prescriptions may be filled and limited to a maximum of thirty (30) day supply with no refills. E. Prescriptions shall be filled with generic drugs to the extent permitted by law, and the least expensive drug product the pharmacy has in stock will be dispensed. Generic drugs shall be dispensed if, in the professional judgement of the pharmacist, the substitute product is available, safe, and effective, and to the greatest extent possible, contains the same chemical ingredients of the same strength, quantity, and dosage of the brand name. All generic products used must be AB rated per the Orange Book. All generic products used must follow Federal and State requirements. F. VA beneficiaries or their designees will pick up their prescriptions at the dispensing pharmacy. No prescriptions will be mailed or delivered to patients. G. Contract pharmacies shall maintain an electronic record of VA prescriptions filled and require the patient to sign next to each prescription number for each prescription received. H. The contractor and his/her contract pharmacies shall keep all information concerning VA beneficiaries confidential and shall not release or disclose information to any person, except as authorized in writing and according to all applicable laws. The Privacy Act of 1974, Public Law 93-579, December 31, 1974 (5 U.S.C. 552a) applies to this procurement. The contractor and its employees shall ensure strict compliance to the release of Protected Health Information in accordance with the Code of Federal Regulation, Title 45, Public Welfare, Subtitle A, Department of Health and Human Services, Part 164, Security and Privacy (45 CFR 164), paragraph 2.2.3, Health Insurance Portability and Accountability Act (HIPAA)" and paragraph 2.3, "General Guidelines on Releasing Medical Information". I. The contractor shall report in writing all adverse drug events and medication errors to the Chief, Pharmacy Service, RJDVA, Wichita, Kansas, and to the prescribing CBOC or HBPC physician. The report should describe the date and nature of the adverse event or medication error and corrective actions taken. J. Contractor will provide electronic monthly, quarterly, and annual reports to the Facility POC. The reports will show the total number of prescriptions filled and the total dollar amount per location. The reports shall be delivered electronically via e-mail for both sensitive and non-sensitive information. Sensitive information sent via e-mail would be required to be encrypted and/or password protected. Reports shall be due by the 15th day following the end of the month, quarter, or year. Monthly reports shall also reflect expenditures to the Facility POC, and shall be organized to include but not limited to the following columns: a. Patient name b. Patient SSN c. Provider name d. Drug name e. Drug strength f. Quantity g. Date drug dispensed h. Dispensing pharmacy i. Drug AWP j. Dispensing fee K. The Pharmacy Service at the Robert J Dole VAMC shall review the monthly statements provided by the contractor regarding fills at the local emergent fill pharmacies. Should the Robert J Dole VAMC Pharmacy find discrepancies in the billing, a request will be made by the Contracting Officer s Representative (COR) to the contractor to provide a copy of the consult in question. If the consult in question is not able to be produced within 10 calendar days, the contractor will adjust the statement by the amount in question. This review process will only be available for 90 days after the date of the prescription fill in question. Thus, the contract pharmacies will only be required to keep the hard copies available for 90 days. L. The Contractor shall designate a program manager (Primary & Alternate) under this contract delivery order and shall provide his/her name, title, address, phone number, fax number, and e- mail address to the CO & Facility POC. The program manager shall work closely with the Facility POC regarding all services covered by the contract delivery order and/or any issues arising under the contract delivery order. M. The Contractor shall provide a list of pharmacies within its network that are geographically accessible to RJDVA and each CBOC, that are handicapped-accessible, and have the most accessible day and evening operation hours, inclusive of weekdays and weekends. The contractor shall provide this list for RJDVA and each CBOC to the Contracting Officer and the Contracting Officer s Representative within five (5) days of contract award and provide updates to this list each quarter. The list shall include the following information: RJDVA and/or CBOC - name and address Pharmacy name, address, phone number, and fax number Pharmacists names Pharmacists license numbers and expiration dates Handicapped accessibility yes, or no? Distance from RJDVA and/or CBOC (i.e., miles) Availability of drive-up window Hours and days of operation. Normal waiting time from receipt of prescription to final delivery to patient. N. Contractor will offer counseling by a pharmacist to ensure appropriate and optimal outcomes from drug therapy. Counseling should include the following: Name, description, and use of medications Dose, dosage form, and route Special directions and precautions Common side effects and action required if they occur. Techniques for self-monitoring drug therapy Action to be taken if a dose is missed. Proper storage O. The contractor shall develop and maintain a quality control program to ensure services are performed in accordance with commonly accepted commercial practices, The Joint Commission, this contract, VA handbooks and directives and all applicable federal, state, and local laws and regulations. Shall develop quality control procedures addressing the areas identified in the Service Summary. The contractor shall develop and implement procedures to identify, prevent, correct, and ensure no recurrence of defective services. The contractor shall provide a copy of the quality control plan to the contracting officer no later than the orientation date, and updated copies as changes occur. Records of all inspections conducted by the contractor and corrective action taken shall be made available to the government upon request. The contractor shall participate in the VA s performance improvement programs when requested to do so. P. Reimbursements shall be determined by the Average Wholesale Price (AWP) discounted by the applicable percentage plus the applicable dispensing fee. The total price charged to the RJDVA shall not exceed that charged to the public and shall not exceed the price charged by the Contractor s lowest third-party reimbursement plan. Average Wholesale Price (AWP) will be based on the current Pharmacy Fundamental Reference Redbook and Redbook Updates published by Medical Economics Data, Inc. Contractor shall be required to provide RJDVA with a current copy of the REDBOOK and updates throughout the contract term. If a contractor offers to use any other means of providing pricing, they shall provide appropriate documentation similar to that of the REDBOOK and its updates. Award of a contract will not be made to any offeror who does not provide sufficient evidence to substantiate the fairness/reasonableness of pricing. Q. The contactor shall not fill preauthorized prescriptions for longer than a maximum of ten (10) days. The contractor shall not fill an antibiotic prescription for longer than a maximum of fourteen (14) days. GOVERNMENT RESPONSIBILITIES A. The Chief, Pharmacy Service, RJDVA, will recommend the assignment of a Contracting Officer s Representative to the Contracting Officer within five (5) days of contract award. B. The Contracting Officer s Representative will monitor the day-to-day performance of the Contractor to verify compliance with the contract using any of the following methods: observing actual performance, inspecting the services to determine whether the performance meets the performance standards; and review of any appropriate records. C. Any incident of contractor non-compliance as evidenced by his/her monitoring shall be forwarded immediately to the Contracting Officer by the Contracting Officer s Representative. The Contracting Officer s Representative will document all correspondence with the Contracting Officer in the COR file. Any documented discrepancies may become a part of the supporting documentation for any contractual action deemed necessary by the Contracting Officer. D. RJVA staff will establish and maintain a record keeping system that will record the services provided under this contract and ensure correct reimbursement of prescriptions/services provided are paid. E. The VA shall randomly audit all prescription fills. The Department of Veterans Affairs shall have free access during regular business hours and upon reasonable notice to such books, records, invoices, and prescription files as deemed necessary to verify claim information, prescription volume, and the usual and customary charges to the general public for covered prescriptions. The contractor shall make all prescription records and invoices available at the time of the audit. F. If any of the services do not conform to contract requirements, the Government may require the contractor to perform the services again in conformity with contract requirements, at no increase in contract amount. When the defects in services cannot be corrected by re-performance, the Government may require the Contractor to take necessary action to ensure that future performance conforms to contract requirements at no additional cost to the Government. G. If a new CBOC is to be opened, the Contracting Officer (CO) will notify the contractor in advance of the opening. At that time, the contractor shall submit a listing of proposed pharmacies for that area to the CO. The Contracting Officer s Representative (COR) shall approve additional pharmacies for that area to the CO. Additional facilities or pharmacies shall be added to the contract via an amendment/modification to the contract. Only the contracting officer has authority to amend or modify the contract. SECURITY A. The contractor, their personnel, and their subcontractors shall be subject to the Federal laws, regulations, standards, and VA Directives and Handbooks regarding information and information system security as delineated in this contract. B. The C&A requirements do not apply, and a Security Accreditation Package is not required. VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE FOR INCLUSION INTO CONTRACTS, AS APPROPRIATE 1. GENERAL Contractors, contractor personnel, subcontractors, and subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security. 2. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS a. A contractor/subcontractor shall request logical (technical) or physical access to VA information and VA information systems for their employees, subcontractors, and affiliates only to the extent necessary to perform the services specified in the contract, agreement, or task order. b. All contractors, subcontractors, and third-party servicers and associates working with VA information are subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations, Security, and Preparedness is responsible for these policies and procedures. e. The contractor or subcontractor must notify the Contracting Officer immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the contractor or subcontractor s employ. The Contracting Officer must also be notified immediately by the contractor or subcontractor prior to an unfriendly termination. 3. VA INFORMATION CUSTODIAL LANGUAGE a. Information made available to the contractor or subcontractor by VA for the performance or administration of this contract or information developed by the contractor/subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of the VA. This clause expressly limits the contractor/subcontractor's rights to use data as described in Rights in Data- General, FAR 52.227-14(d) (1). b. VA information should not be co-mingled, if possible, with any other data on the contractors/subcontractor s information systems or media storage systems in order to ensure VA requirements related to data protection and media sanitization can be met. If co-mingling must be allowed to meet the requirements of the business need, the contractor must ensure that VA s information is returned to the VA or destroyed in accordance with VA s sanitization requirements. VA reserves the right to conduct onsite inspections of contractor and subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures are in compliance with VA directive requirements. c. Prior to termination or completion of this contract, contractor/subcontractor must not destroy information received from VA, or gathered/created by the contractor in the course of performing this contract without prior written approval by the VA. Any data destruction done on behalf of VA by a contractor/subcontractor must be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management and its Handbook 6300.1 Records Management Procedures, applicable VA Records Control Schedules, and VA Handbook 6500.1, Electronic Media Sanitization. Self-certification by the contractor that the data destruction requirements above have been met must be sent to the VA Contracting Officer within 30 days of termination of the contract. d. The contractor/subcontractor must receive, gather, store, back up, maintain, use, disclose and dispose of VA information only in compliance with the terms of the contract and applicable Federal and VA information confidentiality and security laws, regulations and policies. If Federal or VA information confidentiality and security laws, regulations and policies become applicable to the VA information or information systems after execution of the contract, or if NIST issues or updates applicable FIPS or Special Publications (SP) after execution of this contract, the parties agree to negotiate in good faith to implement the information confidentiality and security laws, regulations and policies in this contract. e. The contractor/subcontractor shall not make copies of VA information except as authorized and necessary to perform the terms of the agreement or to preserve electronic information stored on contractor/subcontractor electronic storage media for restoration in case any electronic equipment or data used by the contractor/subcontractor needs to be restored to an operating state. If copies are made for restoration purposes, after the restoration is complete, the copies must be appropriately destroyed. f. If VA determines that the contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be sufficient grounds for VA to withhold payment to the contractor or third party or terminate the contract for default or terminate for cause under Federal Acquisition Regulation (FAR) part 12. g. 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. h. The contractor/subcontractor must store, transport, or transmit VA sensitive information in an encrypted form, using VA-approved encryption tools that are, at a minimum, FIPS 140-2 validated. i. The contractor/subcontractor s firewall and Web services security controls, if applicable, shall meet or exceed VA s minimum requirements. VA Configuration Guidelines are available upon request. j. 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. k. 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. l. For service that involves the storage, generating, transmitting, or exchanging of VA sensitive information but does not require C&A or an MOU-ISA for system interconnection, the contractor/subcontractor must complete a Contractor Security Control Assessment (CSCA) on a yearly basis and provide it to the COTR. 5. INFORMATION SYSTEM HOSTING, OPERATION, MAINTENANCE, OR USE a. For information systems that are hosted, operated, maintained, or used on behalf of VA at non-VA facilities, contractors/subcontractors are fully responsible and accountable for ensuring compliance with all HIPAA, Privacy Act, FISMA, NIST, FIPS, and VA security and privacy directives and handbooks. This includes conducting compliant risk assessments, routine vulnerability scanning, system patching and change management procedures, and the completion of an acceptable contingency plan for each system. The contractor s security control procedures must be equivalent to those procedures used to secure VA systems. A Privacy Impact Assessment (PIA) must also be provided to the COTR and approved by VA Privacy Service prior to operational approval. All external Internet connections to VA s network involving VA information must be reviewed and approved by VA prior to implementation. b. Adequate security controls for collecting, processing, transmitting, and storing of Personally Identifiable Information (PII), as determined by the VA Privacy Service, must be in place, tested, and approved by VA prior to hosting, operation, maintenance, or use of the information system, or systems by or on behalf of VA. These security controls are to be assessed and stated within the PIA and if these controls are determined not to be in place, or inadequate, a Plan of Action and Milestones (POA&M) must be submitted and approved prior to the collection of PII. e. The contractor/subcontractor must conduct an annual self-assessment on all systems and outsourced services as required. Both hard copy and electronic copies of the assessment must be provided to the COTR. The government reserves the right to conduct such an assessment using government personnel or another contractor/subcontractor. The contractor/subcontractor must take appropriate and timely action (this can be specified in the contract) to correct or mitigate any weaknesses discovered during such testing, generally at no additional cost. f. VA prohibits the installation and use of personally-owned or contractor/subcontractor owned equipment or software on VA s network. If non-VA owned equipment must be used to fulfill the requirements of a contract, it must be stated in the service agreement, SOW or contract. All of the security controls required for government furnished equipment (GFE) must be utilized in approved other equipment (OE) and must be funded by the owner of the equipment. All remote systems must be equipped with, and use, a VA-approved antivirus (AV) software and a personal (host-based or enclave based) firewall that is configured with a VA approved configuration. Software must be kept current, including all critical updates and patches. Owners of approved OE are responsible for providing and maintaining the anti-viral software and the firewall on the non-VA owned OE. g. All electronic storage media used on non-VA leased or non-VA owned IT equipment that is used to store, process, or access VA information must be handled in adherence with VA Handbook 6500.1, Electronic Media Sanitization upon: (i) completion or termination of the contract or (ii) disposal or return of the IT equipment by the contractor/subcontractor or any person acting on behalf of the contractor/subcontractor, whichever is earlier. Media (hard drives, optical disks, CDs, back-up tapes, etc.) used by the contractors/subcontractors that contain VA information must be returned to the VA for sanitization or destruction or the contractor/subcontractor must self-certify that the media has been disposed of per 6500.1 requirements. This must be completed within 30 days of termination of the contract. 6. SECURITY INCIDENT INVESTIGATION a. The term security incident means an event that has, or could have, resulted in unauthorized access to, loss or damage to VA assets, or sensitive information, or an action that breaches VA security procedures. The contractor/subcontractor shall immediately notify the COTR and simultaneously, the designated ISO and Privacy Officer for the contract of any known or suspected security/privacy incidents, or any unauthorized disclosure of sensitive information, including that contained in system(s) to which the contractor/subcontractor has access. b. To the extent known by the contractor/subcontractor, the contractor/subcontractor s notice to VA shall identify the information involved, the circumstances surrounding the incident (including to whom, how, when, and where the VA information or assets were placed at risk or compromised), and any other information that the contractor/subcontractor considers relevant. c. With respect to unsecured protected health information, the business associate is deemed to have discovered a data breach when the business associate knew or should have known of a breach of such information. Upon discovery, the business associate must notify the covered entity of the breach. Notifications need to be made in accordance with the executed business associate agreement. d. In instances of theft or break-in or other criminal activity, the contractor/subcontractor must concurrently report the incident to the appropriate law enforcement entity (or entities) of jurisdiction, including the VA OIG and Security and Law Enforcement. The contractor, its employees, and its subcontractors and their employees shall cooperate with VA and any law enforcement authority responsible for the investigation and prosecution of any possible criminal law violation(s) associated with any incident. The contractor/subcontractor shall cooperate with VA in any civil litigation to recover VA information, obtain monetary or other compensation from a third party for damages arising from any incident, or obtain injunctive relief against any third party arising from, or related to, the incident. 7. LIQUIDATED DAMAGES FOR DATA BREACH a. Consistent with the requirements of 38 U.S.C. §5725, a contract may require access to sensitive personal information. If so, the contractor is liable to VA for liquidated damages in the event of a data breach or privacy incident involving any SPI the contractor/subcontractor processes or maintains under this contract. b. The contractor/subcontractor shall provide notice to VA of a security incident as set forth in the Security Incident Investigation section above. Upon such notification, VA must secure from a non-Department entity or the VA Office of Inspector General an independent risk analysis of the data breach to determine the level of risk associated with the data breach for the potential misuse of any sensitive personal information involved in the data breach. The term 'data breach' means the loss, theft, or other unauthorized access, or any access other than that incidental to the scope of employment, to data containing sensitive personal information, in electronic or printed form, that results in the potential compromise of the confidentiality or integrity of the data. Contractor shall fully cooperate with the entity performing the risk analysis. Failure to cooperate may be deemed a material breach and grounds for contract termination. c. Each risk analysis shall address all relevant information concerning the data breach, including the following: (1) Nature of the event (loss, theft, unauthorized access); (2) Description of the event, including: (a) date of occurrence; (b) data elements involved, including any PII, such as full name, social security number, date of birth, home address, account number, disability code; (3) Number of individuals affected or potentially affected; (4) Names of individuals or groups affected or potentially affected; (5) Ease of logical data access to the lost, stolen or improperly accessed data in light of the degree of protection for the data, e.g., unencrypted, plain text; (6) Amount of time the data has been out of VA control; (7) The likelihood that the sensitive personal information will or has been compromised (made accessible to and usable by unauthorized persons); (8) Known misuses of data containing sensitive personal information, if any; (9) Assessment of the potential harm to the affected individuals; (10) Data breach analysis as outlined in 6500.2 Handbook, Management of Security and Privacy Incidents, as appropriate; and (11) Whether credit protection services may assist record subjects in avoiding or mitigating the results of identity theft based on the sensitive personal information that may have been compromised. 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 $______ 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. SECURITY CONTROLS COMPLIANCE TESTING On a periodic basis, VA, including the Office of Inspector General, reserves the right to evaluate any or all of the security controls and privacy practices implemented by the contractor under the clauses contained within the contract. With 10 working-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. 9. TRAINING a. All contractor employees and subcontractor employees requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and its systems: (1) Sign and acknowledge (either manually or electronically) understanding of and responsibilities for compliance with the Contractor Rules of Behavior, Appendix E relating to access to VA information and information systems; (2) Successfully complete the VA Cyber Security Awareness and Rules of Behavior training and annually complete required security training; (3) Successfully complete the appropriate VA privacy training and annually complete required privacy training; and (4) Successfully complete any additional cyber security or privacy training, as required for VA personnel with equivalent information system access. b. The contractor shall provide to the contracting officer and/or the COTR a copy of the training certificates and certification of signing the Contractor Rules of Behavior for each applicable employee within 1 week of the initiation of the contract and annually thereafter, as required. c. Failure to complete the mandatory annual training and sign the Rules of Behavior annually, within the timeframe required, is grounds for suspension or termination of all physical or electronic access privileges and removal from work on the contract until such time as the training and documents are complete.