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These general requirements apply to the contractor and all subcontractors.

For BHRD Service Providers

  1. The Contractor shall, prior to a public announcement, notify the County in writing at least:
    1. 30 days prior to entering into or terminating any subcontracts or closing a Contractor site that is providing services under this Exhibit, and
    2. 90 days prior to terminating this Exhibit with the County.
  2. If the Contractor terminates a subcontract in less than 30 days, or a site closure occurs in less than 30 days, the Contractor shall notify the County as soon as possible and prior to a public announcement.
  3. The Contractor shall notify the County of any other changes in capacity that results in the Contractor being unable to meet any of the access standards required in this Exhibit. Events that affect capacity include decrease in the number, frequency, or type of a required service, employee strike or other work stoppage related to union activities, or any changes that result in the Contractor being unable to provide timely, medically necessary services.
  4. If any of the above events occur, the Contractor shall submit a plan to the County that includes at least:
    1. Notification to Ombuds services;
    2. Crisis services plan;
    3. Client notification plan;
    4. Plan for provision of uninterrupted services; and
    5. Any information released to the media.


  1. The Contractor shall comply with any applicable federal and state laws that pertain to client rights and ensure that staff take those rights into account when providing services to clients.
  2. Notification of all relevant rights shall be made at the beginning of each authorized outpatient benefit and in accordance with WAC, RCW, and KCBHO P&P.
  3. The Contractor shall provide services in an environment that protects the privacy rights of clients.
  4. Clients shall have the right to choose their Behavioral Health Care Provider per WAC. The Contractor shall outline the process whereby the client is guaranteed a genuine choice that is well informed.
  5. The Contractor shall assign clients to clinicians who are anticipated to provide services to the client throughout the authorization period.
  6. The Contractor shall establish mechanisms for the purpose of monitoring performance regarding rights and protections.

The Contractor shall provide services under this Contract as described in state requirements as determined by the Department of Social and Health Services (DSHS) and in compliance with:

  1. Title 45 Code of Federal Regulations (CFR) Health Insurance Portability and Accountability Act (HIPAA), Parts 160 and 164, or any successors, as described in the DCHS contract boilerplate, including, but not limited to the following requirements:
    1. The Contractor shall notify the County in writing of any breach of unsecured protected health information within two business days of discovery as defined in 45 CFR § 164.402.
    2. The Contractor agrees to make available protected health information in accordance with 45 CFR § 164.524.
  2. Chapter 388-877 Washington Administrative Code (WAC), or any successors.
  3. King County Ordinance 15949, extended by Ordinance 18333 (authorizes sales and use tax of one-tenth of one percent for the delivery of mental health and chemical dependency services, and therapeutic courts; expires January 1, 2026).
  4. King County Code 4.33.050, Binding Partnership Agreements – required – commitments.
  1. Annually, the Contractor shall ensure all community behavioral health employees who work directly with clients are provided with training on safety and violence-prevention topics described in RCW 49.19.030.
  2. In accordance with RCW 71.05.390(17), the Contractor shall respond in a full and timely manner to law enforcement inquiries regarding an individual’s eligibility to possess a firearm under RCW 9.41.040(2)(a)(ii).
  3. Upon request of the County, the Contractor shall participate with the County in:
    1. System development initiatives;
    2. Performance Improvement Projects;
    3. Prevention/early intervention activities;
    4. State and federal disaster planning efforts intended to define the coordinated response to a disaster in King County, and disaster response commitments;
    5. Providing timely data, information, and documentation as required by the state, the Metropolitan King County Council, the King County Executive, DSHS, Centers for Medicare and Medicaid Services (CMS), the Legislature, and other parties;
    6. DSHS and External Quality Review Organization review activities;
    7. Intra- and inter-system planning meetings related to quality, utilization, and other system performance issues or concerns;
    8. The County’s process for providing formal notices to clients; and
    9. Training when requested by DSHS. Requests to allow an exception to participation in required training must be in writing and include a plan for how the required information shall be provided to targeted Contractor staff.

The Contractor shall:

  1. Retain complete responsibility for and control of its practice and the practice of clinicians under its employ or contract;
  2. Be responsible for all acts and decisions;
  3. Conduct its practice in accordance with its own best clinical judgment and discretion; and
  4. Not deny services that are medically necessary according to the King County Behavioral Health Organization (KCBHO P&P).
The contractor shall:
  1. Meet the Credentialing Minimum Requirements for Providers and Subcontractors in the KCBHO P&P; and
  2. Provide evidence that the Contractor has a credentialing process for all subcontractors that includes:
    1. A process to determine which subcontractors are to be subject to licensure and/or accreditation requirements, ensure that subcontractors meet those requirements, and maintain documentation that reflects requirements;
    2. A report to the County of any changes in licensure status of subcontractors;
    3. A process to ensure that all subcontractors meet the BHRD basic credentialing criteria;
    4. A process for documented annual evaluation of subcontractor performance, including a good faith effort to involve clients and family members in subcontractor evaluation is expected;
    5. A process for determining the competency of non-traditional providers for whom licensure or accreditation may not apply; and
    6. Regularly documented evaluations of the subcontractors’ clinical staff competency and delivery of services that meet the standards required by the KCBHO.

Data Use, Security and Confidentiality Policy (PDF)

  1. The Contractor shall not store data on portable devices or media unless specifically authorized within the KCBHO P & P Security of Information Systems Data and Client Records Including HIPAA. If so authorized, the data shall be given the following protections:
    1. Encrypt the data with a key length of at least 128 bits;
    2. Control access to devices with a unique user ID and password or stronger authentication method such as a physical token or biometrics; and
    3. Manually lock devices whenever they are left unattended and set devices to lock automatically after a period of inactivity, if this feature is available (maximum period of inactivity is 20 minutes);
  2. The Contractor shall ensure that portable device(s) and/or media is physically protected by:
    1. Keeping portable device(s) and/or media in locked storage when not in use;
    2. Using check-in/check-out procedures when portable device(s) and/or media are shared; and
    3. Taking frequent inventories.
  3. The Contractor shall ensure that when being transported outside of a secure area, portable devices and media with confidential DSHS data are under the physical control of contractor staff with authorization to access the data;
  4. Portable Devices include, but are not limited to:  smart phones, tablets, flash memory devices (e.g. USB flash drives, personal media players), portable hard disks and laptop/notebook/netbook computers if those computers may be transported outside of a secured area.
  5. Portable Media includes, but is not limited to, optical media (e.g., Compact Discs (CDs), Digital Versatile Disc or Digital Video Disc (DVDs), magnetic media (e.g., floppy disks, tape, Zip or Jaz disk drives), or flash media (e.g., CompactFlash, Secure Digital (SD), Multimedia Card (MMC).
  1. The Contractor must participate and cooperate with BHRD efforts to promote the National Standards for Culturally and Linguistically Appropriate Services (CLAS) in Health and Health Care.
  2. The Contractor will provide effective, equitable, understandable and respectful quality care and services that are responsive to diverse cultural health beliefs and practices, preferred languages, health literacy and other communication needs (42 CFR 438.206(c)(2).
  3. The Contractor shall provide services in accordance with the following values:
    1. Culturally responsive care that includes awareness of racial and ethnic factors impacting treatment and informed by the cultural context of the individual;
    2. Linguistically appropriate;
    3. Responsive to the needs of persons with disabilities;
    4. Appropriate to the chronological age and developmental needs of the individual;
    5. Trauma-informed; and
    6. Promoting recovery and resiliency. 

The Contractor shall report all extraordinary occurrences to BHRD and cooperate with any BHRD Safety and Incident Management Committee, and Client Services Quality Assurance reviews as outlined in the KCBHO P&P.

  1. The Contractor shall have a written policy that complies with provisions of BHRD’s contract with DSHS that explains the process in place to pursue, in accordance with reasonable collection practices, third-party payments for clients who are covered by other benefit plans and private pay. The Contractor shall document its collections of third-party payments and report such payments quarterly to the County.
  2. The Contractor shall aggressively work to convert non-Medicaid clients to Medicaid status, including helping families to access health insurance coverage for their children under the provisions of the Children's Health Insurance Program.
  3. The Contractor shall abide by the requirements of Section 1128 (b) of the Social Security Act, which prohibits making payments directly or indirectly to physicians or other providers as an inducement to reduce or limit services provided to recipients.
  4. The Contractor shall not bill, demand, collect or accept payment or deposit for missed, cancelled, or late appointments from any client receiving certification for medical assistance according to 42 CFR 435.914(a) and defined in WAC, including Title XIX and Medical Care Services.
The Contractor shall use the Global Appraisal of Individual Needs – Short Screener (GAIN-SS). Staff using the tool shall attend trainings on the use and implementation of the tool. Implementation of this process will be reviewed by BHRD staff and corrective action will be required if the process is not implemented and maintained throughout the contract period.

The King County Behavioral Health Organization (KCBHO) Grievance System includes a Grievance Process, an Appeal Process, and access to the State Fair Hearing process. An individual applying for, eligible for, or receiving behavioral health services authorized by KCBHO, or the individual’s representative may access the KCBHO grievance system to express dissatisfaction about their rights, services, or treatment.

The Contractor shall:
  1. Establish an internal grievance process as outlined in the KCBHO P & P in accordance with the requirements of 42 Code of Federal Regulations (CFR) 438 § Subpart F and Washington Administrative Code (WAC) 388-877A-0410-0460 and
  2. Incorporate a tracking and review process for grievances and submit quarterly reports to the BHO using the template provided.
  3. Offer individuals any reasonable assistance necessary to complete forms and other procedural steps for Grievances and Appeals, including referral to the independent Ombuds services. 


The Contractor shall:
  1. Hold all necessary licenses, certifications, and/or permits as required by law for the performance of the services to be provided under each Exhibit;
  2. Ensure availability of services for each of the service populations for which it is licensed and/or certified by the Washington State DSHS;
  3. Report to the County any changes in status of any required license or certification;
  4. Be solely responsible for the compliance with generally accepted professional and ethical standards and for the quality of the services performed;
  5. Be consistent, for all duties performed by the Contractor, with the applicable requirements of all formal bodies, governmental or otherwise, to which the Contractor and its clinicians are subject with respect to accreditation, licensing, certification, registration, and/or permits as required by law; and
  6. Require a criminal history background check, in compliance with Chapter 43.43 RCW and in accordance with Chapter 388.06 WAC, through the Washington State Patrol, for employees and volunteers of the Contractor who may have unsupervised access to children, people with developmental disabilities, or vulnerable adults; if there is a finding that is not a disqualifying conviction, the Contractor shall document the finding and rationale for continued employment.
  1. The Contractor shall:
    1. Have a health Information System (IS) that complies with the requirements of 42 CFR Part 438.242 and can report complete and accurate data to BHRD as specified in the KCBHO P&P and the Division of Behavioral Health and Recovery (DBHR) Consumer Information System (CIS) Data Dictionary;
    2. Remedy all data errors within 30 days of receipt of an error report from the BHRD IS;
    3. Be able to provide evidence to the County, upon request, that error reports have been addressed;
    4. Maintain up to date client contact information in the IS; and
    5. Maintain a written business continuity and disaster recovery plan with an identified update process (at least annually) that insures timely restoration of the IS following total loss of the primary system or a substantial loss of functionality; a copy of the plan submitted by the Contractor through the credentialing process shall be made available upon request for review and audit by DSHS or External Quality Review Organization.
  2. All data obtained from clients, employees, or services supported by County funds shall be the property of the County.
The Contractor shall comply with KCBHO P&P related to:
  1. Excluded providers; and
  2. Fraud, waste, and abuse.
The Contractor shall:
  1. Be responsible for its performance on a variety of system accountability measures, as determined by County monthly and quarterly system reports;
  2. Ensure that it works toward outcomes associated with client recovery and resiliency;
  3. On an annual basis, monitor its performance on recovery and resiliency and other system outcomes (if the Contractor determines that a subcontractor is not making good faith efforts to achieve the outcomes, the Contractor shall require a corrective action plan); and
  4. Include achievement of system outcome measures in its Quality Management Plan.
Unless otherwise provided in this Exhibit, the Contractor shall ensure that any adult client receiving services from the Contractor under this Exhibit has unrestricted access to their personal property. The Contractor shall not interfere with any adult client’s ownership, possession, or use of their property. The Contractor shall provide clients under age 18 with reasonable access to their personal property that is appropriate to the client’s age, development, and needs. Upon termination or completion of this Exhibit, the Contractor shall promptly release to the client and/or the client’s guardian or custodian all of the client’s personal property. This requirement does not prohibit the Contractor from implementing such lawful and reasonable policies, procedures, and practices as the Contractor deems necessary for safe, appropriate, and effective service delivery (e.g., appropriately restricting client access to, or possession or use of, lawful or unlawful weapons and/or drugs).

The Contractor shall comply with the following tobacco cessation requirements as applicable to their program:

  1. Ask all clients seeking services about their tobacco use history;
  2. Advise clients on the benefits of quitting and cessation resources available;
  3. Assess clients identified as tobacco users for nicotine dependence at the time of their initial appointment and/or assessment using a screening tool listed below or any other screening tool:
    1. GAIN Nicotine Use and Dependency Screening Tool;
    2. GAIN-Initial (GAIN-I);
    3. GAIN-Quick (GAIN-Q); or
    4. Fagerström Test for Nicotine Dependence;
  4. Provide treatment as prescribed below for those clients interested in quitting and will periodically reassess clients not receiving tobacco treatment;
  5. Assist and arrange for tobacco cessation assistance for clients interested in quitting through coordination/linkage to cessation services that includes, but is not limited to:
    1. Referral to the Quit Line at 1-800-QUIT-NOW, for eligible clients;
    2. Assistance with access to Nicotine Replacement Therapy (e.g., patches, gum or lozenges);
    3. Referral to a tobacco cessation treatment/support group; and/or
    4. The inclusion of tobacco cessation support in the client’s individual sessions;
  6. Offer a tobacco cessation and/or wellness curriculum for use with those clients who choose to address their nicotine dependence or risk of becoming nicotine dependent;
  7. Integrate the use of the carbon monoxide monitor provided by the County into clinical practice and maintain the monitor as indicated by the manufacturer;
  8. Provide and promote tobacco-free buildings and grounds;
  9. Support the provision and promotion of nicotine dependence treatment for employees; and
  10. Attend any County-required trainings about tobacco use and cessation.
  1. The Contractor shall develop and implement a quality management plan in accordance with requirements outlined in the KCBHO P & P
  2. The Contractor shall review the components of the quality management plan at least annually. The review will include submitting a report to KCBHO on any Quality Assurance activity or changes to the Quality Management Plan.  
The Contractor shall participate in the WATrac Resource Management System to facilitate ongoing communications related to system capacities and to provide up-to-date information on the Contractor’s status during a disaster or unexpected closure.

  1. At least one staff person shall be identified and named to the King County BHRD as a point person for the WATrac Resource Management System and registered in WATrac as a Command Center Specialist.
  2. All three staff identified in the BHRD credentialing packet as Three-Deep Contractor Disaster Planners shall be registered as Command Center Specialists and capable of using WATrac to provide current information during or immediately following a disaster regarding the Contractor’s readiness to provide services.
  3. In the case of staff turnover or significant role changes involving the Contractor’s Three-Deep Contractor Disaster Planners or the identified WATrac point person, the Contractor will register and internally train replacement staff to use WATrac within 30 calendar days of the previous registered user’s resignation, termination or reassignment.
  4. In the case of a disaster or other unexpected closure, the Contractor shall use WATrac to provide current information regarding the Contractor’s readiness to provide services.
  5. The Contractor’s registered staff shall participate in all WATrac exercises required by the County.

For Mental Health Treatment Providers

  1. Title 42 CFR Part 438 Managed Care, Subpart 422.208 Physician Incentive Plans, Subpart 438.608(a) Program Integrity Requirements, Subpart 455 Program Integrity Medicaid, and Subpart 1000 through 1008 Office of Inspector General Authorities, or any successors;
  2. Federal 1915(b) Mental Health Waiver;
  3. Title XIX of the Social Security Act (SSA);
  4. SSA Section 1902(a)(68) and 31 United States Code Sections 3729-3733 (the federal False Claims Act);
  5. Chapters 70.02, 71.05, 71.24, and 71.34, Revised Code of Washington (RCW) or any successors;
  6. Chapter 388-877A WAC, or any successors;
  7. The King County Behavioral Health Organization Policies and Procedures (KCBHO P&P) and its revisions (The KCBHO P&P specifies the County’s requirements for the provision of the array of outpatient services to be provided. Unless otherwise specified, the KCBHO P&P shall be regarded as the source document for the guidelines for compliance with the program requirements for this Exhibit.); and
  8. The Western State Hospital/BHO Working Agreement or any successors.
  1. The Contractor shall ensure that no crisis intervention worker is required to respond to a private home or other private location to stabilize or treat a person in crisis unless a second trained individual accompanies them.
  2. The Contractor shall ensure that the determination of the need for a second individual to accompany the crisis intervention worker is made by the clinical team supervisor, on-call supervisor, or the individual professional acting alone based on a risk assessment for potential violence.
  3. The second individual may be one of the following:
    1. Law enforcement officer;
    2. Mental Health Professional;
    3. Mental health paraprofessional who has received annual safety and violence prevention training described in RCW 49.19.030; or
    4. Other first responder, such as ambulance or fire personnel.
  4. The Contractor shall ensure that retaliation does not occur against an individual who, following consultation with the clinical team supervisor, refuses to go to a private home or other private location alone.
  5. The Contractor shall have a plan to provide training, mental health staff back-up, information sharing, and communication for crisis outreach staff who respond to private homes or other private locations.
  6. The Contractor shall ensure that every crisis intervention worker dispatched on a crisis visit has prompt access to information about the client they are being sent to evaluate. Information to be available shall include any history of dangerousness or potential dangerousness documented in crisis plans or commitment records and is available without unduly delaying a crisis response.
  7. The Contractor shall ensure that every crisis intervention worker who engages in home visits to consumers or potential consumers for the provision of crisis services is provided with a wireless telephone or comparable device for the purpose of emergency communication.
The Contractor shall participate in recovery and resiliency initiatives as identified by BHRD as follows:
  1. Update Contractor recovery and resiliency plans at least annually;
  2. Make staff, consumers, and space available for County-sponsored recovery transformation activities;
  3. Ensure all clinical staff, including peer support specialists, participate in workforce training via online and live learning opportunities to acquire and demonstrate recovery competencies within the required timeframes; and
  4. Provide an identified liaison to the King County Recovery Specialist for implementation and maintenance of an online learning system for workforce training in mental health recovery. The liaison shall:
    1. Provide information about clinical staff members who will be accessing training on the online learning system, including name, email address and the name of their immediate supervisor, for implementation of the online learning system in order for those staff to be registered as users (both initially and as users are added or deleted). The positions of these clinical staff members must be funded via a mental health contract with BHRD;
    2. Participate in train-the-trainer activities and periodic meetings with the County as the online learning system is implemented and maintained;
    3. Provide training and support to Contractor staff for implementation and ongoing support of the use of the online learning system;
    4. Ensure access to online training is appropriate and by staff members who have been identified and properly registered to use the system; and
    5. Provide 30 days notification to BHRD should the Contractor decide to execute a contract directly with the provider of the online learning management system.

For Substance Use Disorder Treatment Providers

  1. Title 42 CFR Confidentiality of Alcohol and Drug Abuse Patient Records, or any successors;
  2. Chapters 18.19, 18.130, 18.205, 26.44, 69.50, 70.96A, 74.09, 74.34, and 74.50, RCW or any successor;
  3. Chapters 246-887, 388-800, 388-877B and 388-810, WAC, or any successors;
  4. Official publications and/or policies and procedures distributed by DSHS;
  5. The KCBHO P & P and its revisions;
  6. The Contractor shall ensure consistent compliance with all state and federal requirements as noted in the CFR, RCW, WAC, and official state publications related to services for underserved and special needs populations. These populations include youth; pregnant, parenting and postpartum women; rural populations; ethnic minorities; American Indians and Alaska Natives; gay, lesbian, bisexual, transgender, and questioning populations; the deaf and hearing impaired; the elderly; persons with disabilities; and persons with Acquired Immune Deficiency Syndrome (AIDS).

1. The Contractor shall participate in recovery and resiliency initiatives as identified by BHRD.

For Agencies that have County Vehicles

  1. The Contractor shall maintain insurance coverage on the vehicle and drivers that will indemnify the County from any and all claims arising from the operation and/or use of the vehicle. A copy of the vehicle registration and proof of insurance must be kept in the vehicle. The Contractor’s insurance shall also provide for the replacement or repair of the vehicle in the event that the vehicle is rendered inoperable or stolen during the course of possession by the Contractor.
  2. The Contractor shall ensure that the vehicle is regularly maintained in a manner consistent with the manufacturer’s recommendations and that complete maintenance records are kept. All vehicle operation costs, including but not limited to fuel, maintenance, and repair are the responsibility of the Contractor. Vehicle maintenance records and County access to the vehicle for inspection shall be provided within three business days following notification by the County.
  3. The Contractor shall ensure the vehicle is operated by individuals who are trained in its operation, have a valid and current Washington State Driver’s License with appropriate endorsements for its use, and that the vehicle is operated in a safe manner at all times in compliance with the laws of the State of Washington.
  4. The Contractor shall ensure the security of the vehicle at all times, even when not in use or in the possession of a Contractor employee. In the event the vehicle is stolen, the Contractor shall file a police report and notify BHRD within 24 hours.
  5. The Contractor shall notify the County within 24 hours of any accident involving the vehicle, damage to the vehicle, personal injury or of any repairs to the vehicle in excess of $250.
  6. The Contractor shall be responsible for any fines resulting from violations of State or local laws pertaining to the operation of the vehicle. The County license plate on this vehicle does not authorize illegal parking.
  7. The Contractor shall return the vehicle to the County at the end of any Contractor contract period in which contract renewal is not intended by the County. In such cases, the vehicle shall be returned in a condition reasonable to its age and mileage. The registered ownership of the vehicle shall remain with King County.

Mental Health and Substance Use Disorder Credentialing and Monitoring Information

A contract with the King County Behavioral Health and Recovery Division (BHRD) requires the Contractor to demonstrate that they, and each proposed subcontractor, have the capacity to provide services and/or comply with the King County Behavioral Health Organization (KCBHO) standards. To provide behavioral health services, a Contractor must be certified by the Division of Behavioral Health and Recovery. The process for applying to become a Contractor in the KCBHO includes completion of a credentialing application package and approval of the application by BHRD. Once approved, being added to the KCBHO as a provider of services is contingent on whether there is a need for the service(s) being offered by the agency and the capacity of the KCBHO to add another provider.

There are multiple areas identified in the credentialing application for which information must be provided and/or verified. These include:

  • Agency Primary, Secondary, and Subcontractor Site Information
  • Agency License, Certification, and Practice Information
  • Governing Board/Board of Trustees/Ownership/Tribal Council
  • Staff Roster
  • Identification of staff designated for:
    • Disaster Planning
    • WATrac
    • Authorized Signers for contracts, amendment, invoices, and payment notifications
    • HIPAA Privacy Officer
    • Electronic Access Request used to access the King County Extended Client Lookup System
  • Agency Closure Dates
  • Licensing Review including Agency license, Staff License Information, Disciplinary Information, Debarment Certification, and Criminal History Background Checks
  • Tobacco-Free Buildings and Grounds
  • Business Continuity/Disaster Recovery Plan
  • Intent to Subcontract with Organizations
  • Moral or Religious Objections/Restrictions
  • Certificate of Insurance and Endorsement
For a copy of the credentialing application package contact Sean Davis.

Contract monitoring is conducted by the Behavioral Health and Recovery Division (BHRD) to ensure the highest quality of care and services delivery, and to evaluate adherence to pertinent County, State, and Federal regulations. BHRD’s approach to contract monitoring is one of collaboration with our Contractor’s. BHRD provides technical assistance and training for contracted providers, to improve and maintain contract compliance.

There are three components to contract monitoring: administrative, data accuracy, and clinical.

BHRD conducts monthly remote reviews of submitted administrative and fiscal reports, as well as performing an annual administrative review. Components of the administrative review rotate yearly and include items such as:

  • Policies and procedures
  • Accounting records
  • Standard contract requirements
  • Supporting documentation and justification for reimbursement requests
  • Pursuit of Third Party revenues
  • Governing Board bylaws and minutes
  • Memoranda of Understanding
  • Contractor records of their subcontractor reviews 

Data Accuracy
The verification of the accuracy of submitted service encounter data is also tested annually by comparing a random selection of clinical files to data submitted to BHRD.   In addition to reviewing data, BHRD tests progress note fidelity, as defined by the Center for Medicaid Services. 

A clinical review is conducted once per biennium.  The clinical review includes a review of client files related to Contractor exhibits. BHRD staff provides written reports of site visit findings, including recommendations, and corrective action plans as necessary. Where corrective action is indicated, BHRD follows up with the Contractor to ensure steps have been taken to make required changes and/or employ required alternatives.

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