SOLICITATION NOTICE
R -- Workers' Compensation Program Legacy Case Management Service
- Notice Date
- 1/12/2012
- Notice Type
- Presolicitation
- NAICS
- 541612
— Human Resources Consulting Services
- Contracting Office
- US Department of Veterans Affairs;Veterans Health Administration;Service Area Organization (SAO) East;323 North Shore Drive, Suite 500;Pittsburgh PA 15212-5319
- ZIP Code
- 15212-5319
- Solicitation Number
- VA24012Q0022
- Response Due
- 1/31/2012
- Archive Date
- 5/9/2012
- Point of Contact
- Evonne Huggins
- E-Mail Address
-
2.3432<br
- Small Business Set-Aside
- Service-Disabled Veteran-Owned Small Business
- Description
- Workers' Compensation Program Legacy Case Management Improvements Statement of Work ? CONTENTS 1DEFINITIONS3 2GENERAL INFORMATION3 2.1.1Project Title:3 2.1.2Purpose:3 2.1.3Background:4 2.1.4Period of Performance:4 2.1.5Type of Contract:4 2.1.6Place of Performance:4 3TECHNICAL REQUIREMENTS4 3.1General4 3.2Schedule of Meetings5 3.3Schedule of Deliverables5 4ASSOCIATED TASKS8 4.1TASK 1: Project Plan and Data Management8 4.2TASK 2: Case File Review & Update Activities8 4.3TASK 3: Case Follow-up Actions8 5CONTRACTOR KEY PERSONNEL QUALIFICATIONS9 5.1Key Personnel (Qualifications, Experience, Certifications (QEC))9 5.1.1The Nurse Case Manager QEC9 5.1.2Medical Director/ Consulting Physician QEC:10 6TRAVEL10 7GOVERNMENT RESPONSIBILITIES10 8DEPARTMENT OF LABOR AGREEMENT LANGUAGE11 ? 1DEFINITIONS ACS- is the DOL OWCP Web Bill Processing Portal (Web Portal) through which medical billing can be reviewed by claim number AQS- Agency Query System Codes CMS- Case Management System CO- Contracting Officer COR- Contracting Officer's Representative DBMS- Database Management System DOL- Department of Labor FECA- Federal Employees Compensation Act HR- Human Resources OSHPSHG- Occupational Health Safety and Prevention Strategic Healthcare Group OWCP- Office of Workers' Compensation Programs PN- Periodic Roll Payments (that have been determined to have no wage earning capacity) PR- Periodic Roll Payment PS- Schedule Award Payment - periodic or lump sum PW- Partial Wage capacity or actual earnings (reduced compensation - employee may be working in a position earning less wages than at time of injury salary. SOW- Statement of Work VA- Department of Veterans' Affairs VHA- Veterans' Health Administration VHACO- Veterans' Health Administration Central Office VISN- Veterans' Integrated Service Network VAOIT- Veterans' Affairs Office of Information & Technology WCP- Workers' Compensation Program 2GENERAL INFORMATION 2.1.1Project Title: Workers' Compensation Program Legacy Case Management Improvements 2.1.2Purpose: The contractor, applying its administrative and clinical case management expertise and resources under Department Of Labor Office of Workers' Compensation Program (DOL OWCP) requirements and the Federal Employees Compensation Act (FECA) will reduce the number of existing cases on Periodic Roles (PR cases) through prioritized case management for VHA. The contractor will: (1)Identify missing or deficient administrative and clinical documents required by OWCP in the PR case file (2)Request case files updates or missing documents through communication with medical providers and DOL OWCP as allowed by OWCP rules (3)Provide an updated case management file for VHA for review (4)Review the updated file and report on medical documentation related to the reported work injury including medical diagnosis, treatment plan, prognosis and work capacity, and evaluate this information based on the injury report and recognized medical disability guides (5)Inform VHA and provide DOL with request for second opinion based on the medical file review (6)Identify claimants with work capacity or who should otherwise be removed from the PR Periodic Role for VHA action (7)Reduce DOL administrative lag time in adjudication of claims through scheduled communication and follow-up 2.1.3Background: Many VHA facilities experience high chargeback costs. A review of VHA's PR cases indicates that the Administration needs to improve on WCP case management practices. Case management issues include the availability of skilled WCP case management staff and deficient case management technology. WCP Specialists at many locations have collateral HR duties, large workloads and may not have the training, experience, knowledge or resources to effectively handle case management tasks: many facilities lack clinical case management support. Moreover, VHA does not have centralized case management technology or processes to collect, store, report or track the case information necessary to effectively manage case activities and processes. While these issues are being improved, case management and closure of PR legacy cases will be sourced to expert WC case management contractors. VHA's review of legacy case files identified issues with DOL claims management. DOL case files were often deficient and sometimes missing required medical reports (diagnosis, treatment plan or work capacity that is inaccurate, inappropriate or nor updated with required timeframes. Due to identified VHA deficiencies, these DOL case files issues are often not attended to by VHA. This contract effort will update PR case files with appropriate documentation; request follow-up activities from the DOL; obtain timely response actions from DOL; and, adjudicate the PR status as the case file warrants. 2.1.4Period of Performance: The ordering period will be up to five years consisting of one base year with four, one-year option periods. 2.1.5Type of Contract: The government anticipates a Firm Fixed Price (FFP) Indefinite Delivery Requirements Contract. The firm fixed prices shall be priced on a per case basis. All actual purchase requirements for this activity will be satisfied by placing orders with the awardee. Only one contract is anticipated to be awarded in response to this solicitation. The each order shall be no fewer than 50 cases. The maximum limit of the contractor's obligation to perform these services is realistically estimated at 2,500 cases. This estimate is not a representation to an offeror or contractor that the estimated quantity will be required or ordered, or that the conditions affecting requirements will be stable or normal. 2.1.6Place of Performance: The Contractor shall provide all personnel, equipment, tools, materials, technology, supervision, other items, and non-personnel services necessary to perform Workers' Compensation Case Management file review and follow-up as defined in this Statement of Work at the Contractor's place of business. The Contractor shall support this effort for the Department of Veterans Affairs at approved contractor facilities and as otherwise directed by the COR and mutually agreed to by the Contractor in accordance with contract requirements. The contractor shall perform to the standards in this contract. 3TECHNICAL REQUIREMENTS 3.1General All written deliverables developed by the contractor will be done in English and phrased in layperson language (12th grade level). Statistical and other technical terminology will not be used without providing a glossary of terms. References to requirements and recognized practice standards will be clear and concise. All presentations, reports, documents and other deliverables will be prepared in MS PowerPoint 2003 or 2007 versions. Electronic file copies will be provided for all deliverables in the native format as well as Adobe PDF format (version 8 or later). Electronic copies of Plans, Reports and Presentations developed by the contractor must be complaint with Section 508 of the Rehabilitation Act of 1973 as Amended. Electronic data/database information containing employee WCP case files will be delivered upon completion of contract work coded and in formats readable by the most common database programs. The contractor will purge all electronically VHA employee data and destroy all hard copy employee information within 90 days of completing this contract. The contract will submit a certification to the Contracting Officer identifying the dates and methods of destruction within 30 days of contract completion. To the maximum extent feasible, the Contractor and any sub-Contractors will comply with the following VA's socio-economic goals: Service Disabled Veteran Owned Small Business Veteran Owned Small Business s8a Procedure Small Disadvantaged Business Women Owned Small Business Certified HUBZone Small Business Small Business Small Disadvantaged Business + s8a Procedure 10.00%12.00%0.00%5.00%5.00%3.00%33.50%5.00% 3.2Schedule of Meetings All meetings will commence as scheduled below regardless of the number of orders placed or when. All meetings will be scheduled with the COR. ASSOCIATED TASKMEETING TYPECOMMENCEMENT DATE (In relation to base contract) TASK 1Kick Off Briefing - Conference Call (Face to Face Optional)10 days after award TASK 1Quarterly Progress Review- Conference Call3 months after award, every 3 months thereafter TASK 1Semi-Annual Review- Conference Call or Face to Face meeting as determined by the VA National WCP Manager (only 1 face-to-face/yr)6 months after award, every 6 months thereafter 3.3Schedule of Deliverables All deliverables will be given to COR. ASSOCIATED TASKITEMDUE DATE TASK 1 Case File Information Request10 days after award Quarterly Progress Report90 days after award and every 90 days thereafter Semi-Annual Review Report-16 months after award of base contract and options if exercised Semi-Annual Review Report-211 months after award of base contract and every 12months thereafter VA WCP Specialist Read Access to CMSWhen CMS is populated CM database file transferOne copy at VA's discretion and one copy 30 days after contract completion Complete all VA, VAOIT, HR and DOL data security, privacy and contract requirements for privacy and security including background investigationsSubmit contractor staff information to VA for background investigation within 15 days of award. Complete VA privacy training in 10 days of being provided access to the VA TMS. Business Associate AgreementComplete 5 days after receiving from VA TASK 2 Monthly Task 2 Case Management Report5th day of each month TASK 3 Monthly Task 3 Case Management Report5th day of each month "A quarterly progress report to the COR to identify schedule status, issues and successes, as well as percent of the plan accomplished. "Provide semi-annual Plan reviews (one meeting by telephone and 1 meeting face to face) with advance written report (PowerPoint presentation) to the COR reporting progress to date, identifying deliverable completions, successful (examples) and lagging efforts and any recommendations. "Case file information: Due at the Kickoff/Briefing meeting, the Contractor will provide the COR with a specific list of documents/items needed (a data collection tool/WCP case file data request checklist) for VHA to provide case file information. The contractor must provide contact information for VHA to securely forward PPI information (email, phone, street address, POC). "Provide a Project startup Kickoff/Briefing to the VHACO Team discussing implementation of IT security and privacy requirements & identifying POCs. (telephonic meeting) "Provide semi-annual Plan reviews. An advance written report and PowerPoint presentation need to be submitted to the COR one week prior to the conference call, reporting progress to date and identifying deliverable completions, successful and lagging efforts and any recommendations. (One meeting at VHA, the other telephonic). "Provide secure web based read access to VHA case files for twenty five (25) VHA users. The contractor's users will provide web-based training/information on how to navigate the contractor's CMS. Access will be provided when the contractor begins to populate the CMS. VHA Users will have reader access, with the ability to observe case file information and print documents. "Electronic Data File: Once per year, VHA may request that case management data be exported to a data file for VHA use. It is not known at this time what DBMS would be employed by VHA. The vendor should have Database Conversion / Migration Tools that would allow the data file to be read by the common DBMS in use today. VHA would note the file structured desired in the annual and final data request. Within 30 days after contract completion a finalized electronic data file must be submitted by the vendor. "Monthly Case Management Report 'MCM Task 2 Report' (It's expected that the CMS (when populated) should be able to deliver these monthly reports). The MCM Task 2 Report is one of the two key routine project progress documents and includes the performance measure 'Initial Case Review Complete'. Within 5 calendar days of the end of a month, the MCM Task 2 Report will be issued electronically to the WCP National Program manager, COR, CO and the VISN WCP POC (8 in number). The WCP National Manager has 10 calendar days to review and approve any proposed Task 3 activities. The MCM Report will include: oNumber of VHA case files received (PR & PN) from VHA (monthly and running totals) oNumber of VHA case files completing DOL case look-up (AQS and ACS) (monthly and running totals from Task 2) oNumber of case files populated in the CMS (monthly and running totals) with deficiency report oMonthly communications with DOL or Office Visits completed (identifying cases and information requested, obtained and case status) oNumber of requests for medical documentation sent to and received from medical providers (status of requests) oNumber of requests for medical record updates sent to DOL/ number of DOL responses received (status for requests) oStatus Report including number case reviews complete and recommendations (cases ready) for Task 3 action (clinical review or DOL action request) and other information/issues regarding progress. "The Case Management Project Table below provides 5-phases of the Project. The Contractor will complete the administrative case file review (1 through 2 below); move cases to follow-up actions (3 through 4 below); and, follow the phase 5 through VHA/DOL until the case closed. The contractor will move assigned PR Cases to a phase 5 milestone (see Table below) for VHA or DOL response. "Milestone measures occur when the contractor provides VHA with sufficient information to make a job-offer or the contractor/VHA submits an adjudication request for DOL action. Identify DOL/OWCP case file deficiencies and request updates from OWCP on missing and deficient information; provide appropriate communications on essential claim-related information to VHA and DOL. Case Management Project Phases 1.Collect case information and documents to populate in a case management electronic file system database that can be viewed by VHA WCP specialists. 2.Identify the current medical status of claimants as appropriate by reviewing information available from VHA, DOL and medical providers, communicating with DOL and medical providers and requesting medical updates as needed for a complete file review. 3.Following DOL/OWCP procedures through clinical record review to: 1)Identify workers capable of return to work oRequesting second opinions from DOL as justified (notify VHA first) oIdentifying cases that have reached maximum medical improvement (MMI) that would place work restrictions in perform the job held when injured, likely requiring a job modification for employment. oThe contractor will report to VHA on claimants with work capacity for return to the job held when injured. (Report to VHA for job offers). oProviding information to VHA to support job offers (actual job offer will be from VHA). 2)Identify and report to VHA cases where termination of benefits is appropriate: the worker should not qualify for DOL benefits based on administrative or clinical case review - for example: oThe claimant is deceased oThe claimant is capable of working or is working oThe claimant's injury is not the reason for reduced work capacity to perform the job oThe claimant is retired or should be retired oOther reason for termination of benefits 4.Continue case support, follow-up with VHA to generate a job offers and other action requests and case follow-up actions on requests to DOL for actions: oNotification to VHA that job offers or other DOL action items requests from VHA to DOL are outstanding 5.Follow-up on submitted case action requests with DOL (job offers, SECOPs and other adjudication issues) until closed, escalating action requests as needed. The Contractor's effort will be staffed by professionals having expert knowledge and experience working with the OWCP on administrative and clinical case management. The Contractor's case management staff and technology will provide best practices in prioritized case management to identify cases with missing/or inadequate OWCP required information. The Contractor will ensure that case information requests and updates are communicated to the appropriate DOL staff and provide routine (at least monthly) follow up on requests to minimize DOL administrative lag time in reviewing requests and documentation provided. The participating VHA facilities have approximately 1500 PR cases (PR: entitled to payment on the OWCP Periodic Roll) to review for actions/deliverables. Approximately 250 new PR cases are added each year. The contractor's review will focus upon cases with the highest value return to VHA first, which includes high cost cases and those cases most easily re-classified from PR status. Again, this SOW defines resolving as completing the case file review and completing follow-up actions, including requesting DOL action (second opinion request, termination of benefits request, status re-classification, job offer, etc.) and identifying to VHA cases having work capacity for job offers. VHA understands that DOL actions or VHA job offers may not occur even with diligent contractor efforts within a contract year, so we have defined resolve on circumstance that the contractor should be able to accomplish. Nevertheless, the contractor will continue to monitor resolved cases with VHA and DOL to move cases along. The contractor should have standard processes for follow-up with OWCP regarding case management actions within the CMS. The participating VHA facilities have more than 800 PN case files. The contractor will provide VHA with criteria for red flag inspection of these files and identify information needed from VHA to review red flag cases. The contractor will then be provided 25 PN red flagged files/year for further review. The 25 PN files will be populated in the contractor's CMS and updated with AQS and ACS information. The contractor will request/obtain additional documentation from DOL as needed to complete the record and medical providers to update the record. The contractor will recommend DOL and VHA follow-up actions on these cases when the file is administratively complete. Action on the 25 PN cases will determined by the VHA National WCP Manager and depend on the VHA's available budget. All cases provided to the contractor by VHA will identify the current cost of each case. Cases provided to the contractor will be populated in the contractor's case management System 'CMS' (note that VHA does not have a CMS and information may be hard copy). At the closure of this contract or when requested by VHA, the contractor will provide information entered into their CMS in electronic format suitable for reading by common database applications (The CMS must have data output utilities providing multiple electronic output options including text file, Excel file and common database file formats). A number of tasks are identified in this SOW. The work flow should be an iterative process and it is not intended that the contractor complete Task 2 for all cases prior to moving on to Task 3. The contractor should move individual cases through the Task/Delivery process as quickly as possible to reach the 'resolved' status. 4ASSOCIATED TASKS 4.1TASK 1: Project Plan and Data Management 1.Complete all VA, VAOIT, HR and DOL data security, privacy and contract requirements for privacy and security including background investigations (BI). 2.Complete all DOL security requirements for contractor staff access to WCP data including VA required training to access, transmit and store protected information under HIPPA and Federal privacy rules. The VA will request DOL approval for contractor staff access to DOL WCP information of VHA employees. The contractor will notify the VHA when the Contractor has completed all security requirements and is able to receive VHA employee privacy protected information (PPI). VHA will then provide case information to contractor within 2 weeks of receipt of contractor's ability to securely accept PPI. The Contractor should notify the COR when case information delivery is not on schedule. 4.2TASK 2: Case File Review & Update Activities The following are Task 2 Efforts. The contractor will follow DOL/OWCP requirements in requesting information. Task 2 efforts will result in a complete case file including all DOL/OWCP forms and documentation for PR classification. (1)DOL case look-up including AQS and ACS on select cases (2)Assigned cases populated in the CMS with all documentation input (3)Case File Monthly Status Report identifying deficiencies/issues (4)Contractor prioritizes cases for review with DOL (5)Travel to DOL Offices to update files, communication with DOL representatives (6)DOL medical report updates requests (7)Medical documentation requests (written) sent to medical providers (obtain HIPPA release from VHA) (8)Monthly recommendations for Task 3 action (clinical review) 4.3TASK 3: Case Follow-up Actions Task 3 implements approved activities from Task 2 and new Task 3 activities to resolve medical documentation issues or request DOL case action beyond a medical record update. As appropriate under FECA and OWCP requirements, the Contractor will act on behalf of VHA in communications with DOL and treatment providers. As approved activities by the National WCP Manager, the Contractor on behalf of VHA may engage in the following (note that these activities are recommended in the MCM Task 2 Report): Communications with: "Injured worker "Additional communication with treating physician and treatment providers "DOL OWCP (case action requests and follow-up) "VHA WCP Specialist Case Medical Review and Update Tasks: (1)Nurse Case Manager (NCM) Clinical Review: The technical proposal will identify case criteria for which the NCM (only) provides the DOL action requests based upon clinical review. (2)Medical Director Referrals: Medical Case Review Report- The technical proposal will identify case criteria for case referral to the MD for a MD Report. (3)Reports to VHA identifying claimant's work capacity based on either NCM or Medical Director Reports, identifying cases suitable for job offers (original job or modified duty) or case reclassification. (Note: VHA will handle job offers review internally. The contractor will notify the VHA WCP Program Manager and VISN WCP Coordinator at least monthly on outstanding cases submitted to VHA for job offers). 5CONTRACTOR KEY PERSONNEL QUALIFICATIONS The Contractor shall, at a minimum, provide two (2) fully qualified professional/clinical staff to perform the specialized tasks identified in required services, and shall be responsible for certifying that they meet the personnel qualifications listed below. Also, the Contractor shall have additional fully qualified personnel with a high level of experience as backup to perform services under this contract in the event of absence due to sickness or emergency. Each member of the Contractor's staff must have knowledge and experience in FECA workers' compensation programs with knowledge in WCP case management or clinical occupational medicine as applicable. Resumes of all Key Personnel and certifications must be provided in the proposal. It is expected that the Contractor's identified Key Personnel will staff the project. Key Staff replacements must meet the qualifications and experience of the staff being replaced, and their resumes and certifications shall be provided to VHA for review/approval prior to commencing work on the project. 5.1Key Personnel (Qualifications, Experience, Certifications (QEC)) 5.1.1The Nurse Case Manager QEC (Proposed staff must include one backup meeting the QEC): A Registered Nurse that has VA Nurse III qualifications, which includes a R.N. license, BSN with a minimum of 5 years experience in worker compensation claims, and has one of the following certifications: Certified Occupational Health Nurse (COHN-ABOHN) or Certified Case Manager (CCM-CCMC). The Nurse Case Manager must also have extensive experience in the following work: oOWCP Claims Review and Supervision oFive years case management experience in the Federal Worker Compensation Program (DOL/OWCP) oReviewing and interpreting medical documentation on an accepted or reported injury/workers' compensation diagnosis or fitness for duty issue oCorresponding with the treating physician to obtain additional information about the employee's medical condition or capability to perform work (prognosis) and/or treatment plans oReferring cases with potential work capacity, clinical treatment and prognosis questions to the contractor Medical Director for review oProviding written request to DOL for second medical opinions under circumstances including: (1) evaluation of employee's medical condition, (2) evaluation of the original medical diagnosis and current prognosis oReporting to the Federal employer (e.g. VHA) about cases with possible work capacity for job offers and coordinating job offers from the employer to DOL oReviewing appropriate job assignments for the employee oPreparing letters to OWCP requesting DOL actions (e.g. second opinion, job offers, case termination, reclassification), advising DOL about the clinical issues, including treatment plans and prognosis for recovery identified by the Medical Director oAdvising the treating physician on Federal Agency offers for light/limited duty oReviewing proposed transitional assignments for consistency with duty restrictions oDiscussing issues and strategizing options for resolution(s) with Federal Agency (employer/VHA) workers' compensation teams. 5.1.2Medical Director/ Consulting Physician QEC: (Proposed staff that must include at least one backup meeting the QEC): Will serve as the Medical Director (MD) for review of claimant diagnosis, medical treatment plans, prognosis, work capacity and other medical documentation when the case is referred by the Nurse Case Manager for clinical review. The MD will review the case under applicable OWCP criteria and recognized medical disability guides, and provide a MD report noting the appropriateness of diagnosis, medical treatment plans, prognoses and work capacity. The MD will provide written reviews that may be shared with OWCP and will correspond as needed with the claimant treating physician. The Consulting Physician must maintain a Board Certification in Occupational Medicine to offer a MD Report under this contact. o5 years practice in specialty oAt least 1 year of demonstrated knowledge and experience in Federal Employees' Compensation Act (FECA) and the DOL OWCP claims processes. 6TRAVEL Only one face-to-face meeting is planned with the Contractor/per year at VHACO. This will be a performance meeting to review project progress, successes and issues (if any). The meeting will be scheduled either as the semi-annual or annual case progress review based on the recommendations received from the Contractor, case progress, and WCP National Manager. The Contractor should communicate with the VHA WCP Manager 120 days after award to determine if the 6 month or 12 month review will be the face-to-face meeting. Additionally, other trips to DOL district offices will most likely be required throughout the period of performance of this contract. Travel LocationNumber of Trips Washington, D.C. (VHACO)1 Boston, MA, District Office 12 New York, NY, District Office 22 Philadelphia, PA, District Office 32 Jacksonville, FL, District Office 62 Cleveland, OH, District Office 92 Chicago, IL, District Office 102 Kansas City, MO, District Office 112 Washington, D.C., District Office 252 District Office 12 - Denver0* District Office 13 - San Francisco0* District Office 14 - Seattle0* District Office 16 - Dallas0* *No visits are planned to these offices during the bases year. Email, telephone and mail should be used to the maximum extent feasible to obtain OWCP case information. 7GOVERNMENT RESPONSIBILITIES The VA shall provide the Contractor with access to VHA WCP case management data as soon as the Contractor has satisfied all security and privacy requirements. This access shall be no later than 2 weeks from Contractor's request. 8DEPARTMENT OF LABOR AGREEMENT LANGUAGE The awardee will be required to sign an agreement that will closely mirror the following: Contract No. xxxxxxxxx; Order No. xxxxxxxxxxxx, VENDOR Agreement between The Department of Veterans Affairs (also referenced as 'DVA') and VENDOR Under FECA and USDOL OWCP requirements. As agreed to herein by signature, The DVA and VENDOR incorporate the following language as part of referenced Contract No. xxxxxxxxxxxx. Access to information in the system of records maintained by the U.S. Department of Labor under the Federal Employees' Compensation Act, entitled DOL/GOVT-1, "Office of Workers' Compensation Programs, Federal Employees' Compensation Act File," is provided pursuant to a routine use promulgated by the Department of Labor and published in the system notice in the Federal Register. VENDOR recognizes and acknowledges that any duplicate copies of these records that are maintained by the DVA and provided to VENDOR belong to DOL, and do not constitute records of the DVA, and will abide by DOL's rules governing access and disclosure of these records. (See 20 C.F.R. § 10.10-10.13.) The DVA (Veterans Health Administration (VHA)) and VENDOR also agree that the following language from Chapter 9 of the Employing Agency Handbook, "Injury Compensation for Federal Employees," paragraph 9-2 "Inspection and Protection of Records," governs use of information from OWCP case files by VENDOR in the course of performing its contractual responsibilities to the DVA Claims staffs are instructed to provide agency personnel with copies of all significant correspondence to employees, even when the employeesare no longer on the agency's rolls. Under the routine use provisions of the regulations governing release of information under the Privacy Act, agencies are entitled to obtain copies of other materials in their employees' compensation files as well. The use of these copies must, however, be consistent with the reason the information was collected. In practice, this means that the use must be connected in some way with the compensation claim. Agencies may not use copies of information from claim files in connection with EEO complaints, disciplinary actions, or other administrative actions without the employee's consent. Any questions concerning use or release of records should be directed to the OWCP district office servicing the case. To the extent that the VENDOR believes that a court order requires disclosure of information from a FECA record maintained by DOL under DOL/GOVT-1, VENDOR and the DVA will not disclose any such information from a FECA record without clearing such anticipated disclosure with DOL.
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