HomeMy WebLinkAboutGirard Associates 2023-01-27 2023-2024 City of Ukiah, CA - Quality Audit and Management Agreement for Ukiah Valley Fire Authority
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EMERGENCY MEDICAL SERVICES (EMS) QUALITY IMPROVEMENT AUDIT AND
MANAGEMENT PROGRAM AGREEMENT
This EMS Quality Improvement Audit and Management Program Agreement
(“Agreement”) is entered into on the date written below by and between City of Ukiah, a municipal
corporation with Headquarters located at 300 Seminary Avenue, Ukiah, CA 95482 (“CLIENT”),
and Girard & Associates, a Massachusetts Corporation with an office at P.O. Box 1144, Westport,
MA 02790 (“GA”). CLIENT desires to retain the services of GA and GA desires to render services
to the CLIENT upon the following terms and conditions. Therefore, in consideration of the
promises, undertakings, and covenants set forth in this Agreement, the Parties agree as follows.
1. GA SHALL
a.Administer an EMS Quality Improvement Audit and Management Program
i.Audit approximately 3,000 of CLIENT’s Ambulance Trip Sheets and enter data into
GA database.
ii.Educate CLIENT and CLIENT’s medical director on developing EMS clinical and
quality improvement performance benchmarks and best practices.
iii.Prepare and submit QI reports to CLIENT and its physician medical director for the
purpose of educating CLIENT and its physician medical director regarding CLIENT’s
performance.
iv.Develop and implement CLIENT’s annual QI plan.
v.Educate applicable CLIENT personnel on CLIENT's annual QI plan and its elements.
vi.Educate, coach, and mentor CLIENT’s applicable personnel in coordination with
CLIENT and CLIENT’s medical director to facilitate adherence to CLIENT’s QI
policies, procedures, and the applicable EMS treatment protocols.
vii.Educate CLIENT and CLIENT’s medical director on developing performance
benchmarks and best practices.
viii.Propose recommendations for improvement processes to CLIENT and CLIENT’s
medical director regarding EMT and EMS system performance.
ix.Review circumstances surrounding EMS QI variances and develop individual or
system-wide educational opportunities focused on QI benchmark achievement jointly
with CLIENT and CLIENT’s medical director.
x.Develop and recommend for CLIENT’s implementation, methods to facilitate QI
related communication between CLIENT, CLIENT’s medical director, and EMTs.
xi.Grant access to the G and A Database according to the terms set forth in Exhibit A.
2.DURATION OF THE AGREEMENT
a.The term of this Agreement shall be from January 1, 2023, to December 31, 2023, unless
terminated in accordance with Section 9.
3.COMPENSATION AND PAYMENT SCHEDULE
a.Subject to appropriation or availability of other funds, CLIENT shall compensate GA
according to the following payment schedule:
i.Total Compensation for this Agreement is: $27,900.00. Two (2) Payments of $13,950.00
are due on or before 01/15/2023 and 07/15/2023.
COU No 2223-151
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ii.Expenses, including travel, are included in this Agreement.
b.Withholding; Other Benefits
i.Compensation paid pursuant to this Agreement shall not be subject to the customary
withholding of income taxes and other employment taxes. GA shall be solely
responsible for reporting and paying any such taxes. The CLIENT shall not provide GA
with any coverage or participation in the CLIENT's accident and health insurance, life
insurance, disability income insurance, medical expense reimbursement, wage
continuation plans, or other fringe benefits provided to regular employees.
4.CONFIDENTIALITY
a.GA acknowledges and agrees that any identifiable information provided by CLIENT or
obtained by GA because of its obligations in Paragraph 1 is “Confidential Information.”
b.Except for disclosures required by law or allowed by this section, GA shall not, during the
term of this Agreement or after the termination of this Agreement, disclose any Confidential
Information to any person or use any Confidential Information for the benefit of GA or any
other person, except with the prior written consent of the CLIENT.
c.CLIENT understands that Confidential Information may be required to be disclosed to
certain individuals: employees, agents, advisors, physician medical directors, or attorneys of
GA.
d. GA shall maintain records of the persons to whom Confidential Information is distributed,
will inform all such persons of the confidential nature of the information, will direct them to
treat such information in accordance with this Agreement, and will exercise such
precautions or measures as may be reasonable in the circumstances to prevent improper use
of Confidential Information by them.
e.The term “Confidential Information” does not include information that is or becomes
publicly available (other than through breach of this Agreement) or information that is or
becomes available to GA on a non-confidential basis, provided that the source of such
information was not known by GA (after such inquiry as would be reasonable in the
circumstances) to be bound by a confidentiality agreement or other legal or contractual
obligation of confidentiality with respect to such information.
f.Confidential Information may be disclosed by GA to the extent required during inspections
or inquiries by federal or state regulatory agencies to whose jurisdiction GA is subject to and
that have the legal right to inspect the files that contain the Confidential Information. GA
will advise CLIENT promptly upon such disclosure.
g.HIPAA. Acceptable uses of Protected Health Information (PHI) by GA are limited to
ambulance trip sheet audits, including communication about the ambulance trip sheet audit
between GA, its. employees, subcontractors, agents, and CLIENT’s Business Associate(s),
and any other purpose(s) permitted or mandated by federal law/regulation pursuant to 45
C.F.R. § 164.502(j)(1) (2005) or applicable state law.
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i.Parties agree to adhere to the conditions set forth in the Business Associate Agreement,
which is attached as Exhibit B hereto.
ii.CLIENT agrees to adhere to the GA Acceptable Use Agreement (AUP) which is
attached as Exhibit C hereto.
h.Return of Documents. GA does not store paper copies of ambulance trip sheets. If
applicable, all paper copies of ambulance trip sheets will be destroyed after use. GA
acknowledges and agrees that all originals and copies of records, reports, data, documents,
lists, plans, memoranda, notes and other documentation related to the business of the
CLIENT or containing any Confidential Information that GA has in its possession, shall be
the sole and exclusive property of the CLIENT, and shall be returned by commercially
reasonable means to the CLIENT upon the termination of this Agreement or upon the
written request of the CLIENT.
i.No Release of Confidentiality Obligations. GA agrees that the termination of this
Agreement shall not release GA from any Confidentiality obligations.
5.INTELLECTUAL PROPERTY
a.“Intellectual Property” means any and all designs, devices, techniques, know-how,
inventions, discoveries, improvements, code, written materials, methods and practices,
procedures, engineering information, technology or intellectual property rights (including,
without limitation, patents, patent applications, copyrights, trademarks, trade names, trade
secrets, service marks, blueprints, designs, plans, specifications, manufacturing information
and processes and documentation thereof, formulae, procedures and all other proprietary
rights).
b. Solely with respect to its own Intellectual Property, GA shall have and retain all right, title
and interest, including ownership of copyrights, patents, trade secrets and other intellectual
property rights in and to methods, processes, techniques, strategies, materials, images,
prototypes, software, source and object code and related materials that are used or developed
solely by GA, or its agents, during the term of this Agreement, including any modifications
to, or derivative works or enhancements of, materials owned or licensed by either CLIENT
or GA and any tools, utilities, prototypes, models, processes, methodologies and other such
materials that are developed, enhanced or improved during the term of this Agreement by
GA or any of its agents or employees, which relate to the performance of the Services, or
any modification of the services to be provided under this Agreement. CLIENT
acknowledges that all of this work is GA’s Intellectual Property, none of this work is “work
for hire” and that CLIENT has no rights to the Intellectual Property developed by GA and its
agents, principals, employees, subcontractors and delivery partners.
c.GA acknowledges that it has no right, title, and interest in any Intellectual Property licensed
or owned now or in the future by CLIENT, or developed solely by CLIENT, or in use by
CLIENT at the commencement of this Agreement.
d.Each Party will protect the other Party’s Intellectual Property and Confidential Information
with the same care and diligence as it would use to protect its own Intellectual Property and
Confidential Information. Each Party will take all necessary and appropriate steps to
safeguard the other’s Intellectual Property and Confidential Information by employees,
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former employees, vendors, affiliates, and others to whom they have directly, or indirectly,
made confidential information available. Notwithstanding the foregoing, the Parties
acknowledge that the CLIENT is subject to the Massachusetts Public Records Law and may
be legally required to disclose information that it has in its possession.
e.All de-identifiable data entered into the QA/QI database is the sole property of GA. Upon
completion of the Agreement and project, GA shall de-identify all data in accordance with
federal and state law and provide client with a written attestation of de-identification upon
CLIENT's request.
6.GA REPRESENTATIONS, WARRANTIES, AND LIABILITY
a.GA, its employees, agents, and independent contractors are not responsible for any action,
including but not limited to the implementation of any disciplinary action of CLIENT's
employees, taken by the CLIENT, its Medical Director, or state, federal, or applicable
regional EMS authority because of GA’s performance of its obligations as described in
Paragraph 1 of this Agreement.
b.GA represents to the CLIENT that there is no employment contract or other contractual
obligation to which GA is subject that prevents GA from entering into this Agreement or
from performing its duties under this Agreement.
c.GA is not responsible for CLIENT’s applicable serious incident reporting obligations under
applicable state, federal law, or regional EMS authority jurisdiction.
e. GA warrants that the work contained in Paragraph 1 will be performed with reasonable care
in a diligent and competent manner in coordination with and as a delegated authority of
CLIENT’s Medical Director in a Peer Review capacity. GA's sole obligation will be to
correct any non-conformance with this warranty if CLIENT gives GA written notice within
ten (10) business days during or after the completion of this Agreement. The notice will
specify and detail the non-conformance and GA will have a reasonable time based on its
severity and complexity to correct the non-conformance.
g.This warranty is GA's only warranty concerning the services and any deliverable except
those provided under a separate license agreement and is made expressly in lieu of all other
warranties and representations, express, implied, including any implied warranties of
merchantability, or fitness for a particular purpose or otherwise, all of which are hereby
disclaimed.
h.GA will not be liable for any special, consequential, incidental, indirect, or exemplary
damages or loss (nor any lost profits, savings, or business opportunity). Further, GA
liability relating to this Agreement will in no event exceed an amount equal to the fixed fees
(excluding taxes and expenses) GA receives from CLIENT for the portion of the Agreement
giving rise to such liability, unless GA acts with gross negligence or has responsibility for
intentional wrongdoing, in which case it shall indemnify CLIENT up to its exposure under
applicable law.
7.COVENANTS
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a.CLIENT agrees that services, information, and materials provided under this agreement will
not be duplicated, shared, or otherwise distributed in any way to persons or organizations
outside of CLIENT, and any state, local, regional, or national regulatory agency. This
information is being provided exclusively for internal use by CLIENT. Notwithstanding the
foregoing, the Parties acknowledge that the CLIENT is subject to the Massachusetts Public
Records Law and may be legally required to disclose information that it has in its
possession.
b. The Parties agrees to comply with all federal, state, and local laws, regulations and
administrative requirements that pertain to the provision of emergency medical services by
CLIENT.
c.If GA, its, subcontractors, employees, or agents becomes aware of any violation of any
applicable law or regulation by CLIENT, GA will notify CLIENT as soon as reasonably
practicable.
d.CLIENT shall cooperate with GA in the performance by GA of its services under this
Agreement including, without limitation, providing GA with reasonable facilities and timely
access to data, information, and personnel of CLIENT.
e.CLIENT agrees to provide ambulance trip sheet data to GA in a mutually agreed upon
secure manner in compliance with applicable state and federal data security laws.
f.CLIENT shall be responsible for the performance of its personnel and agents including its
medical director for the accuracy and completeness of all data and information provided to
GA for the purposes of the performance by GA of its services under this Agreement.
g. CLIENT agrees that CLIENT’s physician medical director and CLIENT, not GA, is
responsible for determining whether CLIENT breached any applicable treatment protocol
and what action, if any, should be taken on under the authority of the physician medical
director and CLIENT.
h.CLIENT is responsible for all QA/QI functions and responsibilities not enumerated in
Paragraph 1 of this Agreement.
i.CLENT' agrees that CLIENT, not GA is responsible for the implementation of any
disciplinary action of CLIENT's employees that may occur because of GA’s performance of
its obligations as described in Paragraph 1 of this Agreement.
8.SEVERABILITY
a.If any provision of this Agreement or the application of it to any person or circumstance is
held invalid, such invalidity shall not affect other provisions of this Agreement which can be
given effect without the invalid provision.
b.The Parties shall add a provision as similar in terms to the illegal, invalid, and unenforceable
provision as may be possible and be legal, valid, and enforceable.
9.TERMINATION
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a.Either party may terminate this Agreement with cause upon thirty (30) days written notice.
b.If either Party has failed to perform its obligations under this Service Agreement in a material
manner, and that failure has not been satisfactorily addressed through the cure process established
in this Agreement, the injured Party shall have the right to terminate this Service Agreement for
Cause thirty (30) days following the issuance of a written notice of termination. No written
notice of Termination for Cause will be valid unless the Party issuing the notice has complied
with the cure procedure set forth below. If the performance deficiency is not addressed through
the cure process, CLIENT shall have the right to terminate this Agreement for Cause, as outlined
herein. Either Party shall also have the right to terminate this Agreement for Cause if either Party
is added to the Excluded Providers list maintained by the Office of Inspector General (“OIG”)
maintained by the Health and Human Services Administration of the Federal Government.
c.CLIENT is responsible work the cost of work already performed.
d.Procedure Regarding Cure. If a Party has failed to perform its obligations under this Service
Agreement, the Parties agree that the non-performing Party shall have the opportunity to cure the
failure to perform prior to a Termination for Cause. Therefore, prior to issuing a written notice of
termination, each Party agrees to proceed in the following manner, working, in good faith, to
address the circumstances that led to the failure to perform:
i.The Party seeking to address an area of concern shall give written notice to the non-
performing Party.
ii.The non-performing Party shall be given 30 days within which to satisfactorily address the
concern and begin implementation of the agreed upon course of action. If necessary, under
the circumstances, the complete implementation of the agreed upon course of action may
take more than 30 days but may not exceed 90 days.
iii.If the non-performing Party fails to comply with the agreed upon course of action on the
appropriate timetable, the other Party may request a meeting of the Parties’ respective senior
executives to discuss the failure to comply and termination. That meeting will be held
promptly upon request. If the senior executives are unable to agree upon a course of action to
resolve the non-performance, following good faith discussions, then the performing Party
shall be authorized to issue a notice of Termination for Cause.
iv.Upon the issuance of a notice of Termination for Cause, the Parties shall meet to discuss the
steps required to facilitate an orderly transition in connection with the termination and shall
agree upon a transition plan (“Termination Transition Plan”) that shall address timing of the
termination of services, employee communication, reconciliation of fees, and licenses for
continued use of GA intellectual property if applicable. Any disputes that arise during these
procedures and cannot be resolved by good faith dialogue among the Parties shall be resolved
through litigation if needed.
10.INDEPENDENT CONTRACTOR STATUS
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a.GA acknowledges that it is an independent contractor and is not an agent, partner, joint
venturer, or employee of CLIENT. GA shall have no authority to bind or otherwise obligate
CLIENT in any manner nor shall GA represent to anyone that it has a right to do so.
b.GA shall not assign any of its rights under this Agreement.
c.GA may subcontract and/or delegate the performance of its duties under this Agreement
without the prior written consent of CLIENT.
11.MISCELLANEOUS
a.This Agreement shall be governed by and shall be construed in accordance with the laws of
the Commonwealth of Massachusetts.
b.This Agreement constitutes the entire Agreement between CLIENT and GA pertaining to its
subject matter and supersedes all prior contemporaneous agreements, representations,
proposals, and understandings of CLIENT and GA. No supplement, modification or
amendment of this Agreement shall be binding unless executed in writing by the Parties.
c.GA reserves the right to add 1.5% per month to outstanding balances over 30 days.
d.CLIENT will be responsible for any collection costs and/or attorney’s fees allowed by law.
e.CLIENT certifies that to the best of its knowledge after reasonable due diligence that the
services provided by GA under this Agreement do not conflict with any applicable union
collective bargaining agreement.
12.MUTUAL INDEMNIFICATION
a.To the extent permitted by law, CLIENT and GA agree to indemnify and hold each other
harmless, and any employee or agent thereof (referred to individually as an “Indemnified
Party”) against all liability, including any expenses and reasonable attorney fees, based on
claims by third parties against the Indemnified Party arising from the other Party’s
negligence, fault, or wrongdoing.
b.The Parties’ obligations to indemnify each other in accordance with Paragraph 12a will
survive the expiration or termination of this Agreement.
13. INSURANCE LIABILITY.
a.Without limiting GA's obligations arising under Paragraph 12, GA shall not begin work
under this Agreement until it procures and maintains for the full period of time allowed by
law, surviving the termination of this Agreement insurance against claims for injuries to
persons or damages to property, which may arise from or in connection with its performance
under this Agreement.
b.Minimum Scope of Insurance. Coverage shall be at least as broad as:
i.Insurance Services Office ("ISO) Commercial General Liability Coverage Form No. CG
20 10 10 01 and Commercial General Liability Coverage – Completed Operations Form
No. CG 20 37 10 01.
ii.ISO Form No. CA 0001 (Ed. 1/87) covering Automobile Liability, Code 1 "any auto" or
Code 8, 9 if no owned autos and endorsement CA 0025.
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c.Minimum Limits of Insurance. GA shall maintain limits no less than:
i.Liability: $1,000,000 combined single limit per occurrence for bodily injury, personal
injury and property damage including operations, products and completed operations. If
Commercial General Liability Insurance or other form with a general aggregate limit is
used, the general aggregate limit shall apply separately to the work performed under this
Agreement, or the aggregate limit shall be twice the prescribed per occurrence limit.
d.Deductibles and Self-Insured Retentions. Any deductibles or self-insured retentions must be
declared to and approved by the CLIENT. At the option of the CLIENT, either the insurer
shall reduce or eliminate such deductibles or self-insured retentions as respects to the
CLIENT, its officers, officials, employees and volunteers; or GA shall procure a bond
guaranteeing payment of losses and related investigations, claim administration and defense
expenses.
e.Other Insurance Provisions: The policies are to contain, or be endorsed to contain, the
following provisions:
i.General Liability
(1)The CLIENT, it officers, officials, employees and volunteers are to be covered as
additional insureds as respects; liability arising out of activities performed by or on
behalf of GA, products and completed operations of GA, premises owned, occupied
or used by GA for the full period of time allowed by law, surviving the termination
of this Agreement. The coverage shall contain no special limitations on the scope-
of-protection afforded to the CLIENT, its officers, officials, employees or
volunteers.
(2)GA's insurance coverage shall be primary insurance as respects to the CLIENT, its
officers, officials, employees and volunteers. Any insurance or self-insurance
maintained by the CLIENT, its officers, officials, employees or volunteers shall be in
excess of GA's insurance and shall not contribute with it.
(3)Any failure to comply with reporting provisions of the policies shall not affect
coverage provided to the CLIENT, its officers, officials, employees or volunteers.
(4)GA's insurance shall apply separately to each insured against whom claim is made or
suit is brought, except with respect to the limits of the insurer's liability. If written on
a claims-made basis, the retroactivity date shall be the effective date of this
Agreement. The policy period shall extend one year from project completion.
ii.All Coverages. Each Insurance policy required by this clause shall be endorsed to state
that coverage shall not be suspended, voided, canceled by either party, reduced in
coverage or in limits except after thirty (30) days prior written notice by certified mail,
return receipt requested, has been given to the CLIENT.
f.Acceptability of Insurers. Insurance is to be placed with admitted California insurers with an
A.M. Best's rating of no less than A- for financial strength, AA for long-term credit rating
and AMB-1 for short-term credit rating.
g.Verification of Coverage. GA shall furnish the CLIENT with Certificates of Insurance and
with original Endorsements effecting coverage required by this Agreement. The Certificates
and Endorsements for each insurance policy are to be signed by a person authorized by that
insurer to bind coverage on its behalf. The Certificates and Endorsements are to be on forms
provided or approved by the CLIENT. Where by statute, the CLIENT's Workers'
Compensation - related forms cannot be used, equivalent forms approved by the Insurance
Commissioner are to be substituted. All Certificates and Endorsements are to be received
and approved by the CLIENT before GA begins the work of this Agreement. The CLIENT
reserves the right to require complete, certified copies of all required insurance policies, at
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any time. If GA fails to provide the coverages required herein, the CLIENT shall have the
right, but not the obligation, to purchase any or all of them. In that event, the cost of
insurance becomes part of the compensation due the contractor after notice to GA that
CLIENT has paid the premium.
h. Subcontractors. GA shall include all subcontractors or sub-consultants as insured under its
policies or shall furnish separate certificates and endorsements for each sub-contractor or
sub-consultant. All coverage for sub-contractors or sub-consultants shall be subject to all
insurance requirements set forth in this Paragraph 13.
14.COMPLIANCE
a.Compliance. The parties will comply in all respects with applicable federal and state laws
and regulations including, the federal anti-kickback statute.
b.Non-Exclusion. Each party represents and certifies that neither it nor any practitioner who
orders or provide Services on its behalf hereunder has been convicted of any conduct that
constitutes grounds for mandatory exclusion as identified in 42 U.S.C.§ 1320a-7(a). Each
party further represents and certifies that it is not ineligible to participate in Federal health
care programs or in any other state or federal government payment program. Each party
agrees that if DHHS/OIG excludes it, or any of its practitioners or employees who order or
provide Services, from participation in Federal health care programs, the party must notify
the other party within five (5) days of knowledge of such fact, and the other party may
immediately terminate this Agreement, unless the excluded party is a practitioner or
employee who immediately discontinues ordering or providing Services hereunder.
c.Referrals. It is not the intent of either party that any remuneration, benefit or privilege
provided for under the Agreement shall influence or in any way be based on the referral or
recommended referral by either party of patients to the other party or its affiliated providers,
if any, or the purchasing, leasing or ordering of any services other than the specific services
described in this Agreement. Any payments specified herein are consistent with what the
parties reasonably believe to be a fair market value for the services provided.
15.FORCE MAJEURE
a.If either party is prevented from performing any of its obligations under this Agreement due
to any cause beyond the party’s reasonable control, including, without limitation, an act of
God, fire, flood, Covid-19, explosion, war, strike, embargo, government regulation, civil or
military authority, acts or omissions of carriers, transmitters, providers of
telecommunications or Internet services, vandals, or hackers (a “force majeure event”),
time for that party’s performance will be extended for the period of the delay or inability to
perform due to such occurrence without liability to the other party; provided, however, that
CLIENT will not be excused from the payment of any sums of money owed by CLIENT to
GA through the date of the force majeure event. In no event shall CLIENT be required to
pay for services not rendered. In addition, neither party will have the right to claim damages
or to terminate this Agreement because of a force majeure event.
16.PROCUREMENT PROCESS
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a.CLIENT certifies that to the best of its knowledge after reasonable due diligence, this
procurement process and Agreement:
i.Followed all applicable rules under CLIENTS’s Charter, By-Laws, polices/procedures,
and applicable CA Law.
ii.This Agreement has been entered into in accordance with the CLIENTS’s Charter, By-
Laws, policies/procedures, and applicable CA Law.
17.CERTIFICATE OF NON-COLLUSION
a.The undersigned certifies on behalf of GA under penalties of perjury that this Agreement
has been made and submitted in good faith and without collusion or fraud with any other
person. As used in this certification, the word "person" shall mean any natural person,
business, partnership, corporation, union, committee, club, or other organization, entity, or
group of individuals.
19 COUNTERPARTS
a. This Agreement may be signed in counterparts, all of which upon execution and delivery
shall be considered an original and together shall constitute one agreement. Signed
facsimile copies of this Agreement will legally bind the parties to the same extent as original
documents.
I have read this Agreement, had the opportunity to consult with an attorney, and
represent that this Agreement shall be executed in accordance with its terms and conditions. I
further represent that I have been duly authorized to sign and enter into this Agreement.
Signed this _________ day of __________________, 2023
City of Ukiah (CLIENT) Girard & Associates, (GA)
By: _____________________________ By: __________________________
Sage Sangiacomo, City Manager Paul Girard
27 January
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EXHIBIT A
GA WEB-BASED QA/QI SOFTWARE LICENSE
1.Subject to the terms of the Agreement, as may be amended from time-to-time in accordance
with its terms, CLIENT's payment of all relevant fees for services provided in accordance with
Paragraph 1, GA grants to CLIENT, without additional cost to CLIENT, a non-exclusive, non-
transferable, non-assignable limited License for 5 authorized CLIENT workforce members to
access the GA Database and 3 authorized CLIENT workforce members to access the GA Web
Report Program and use these Web-based Software programs for its internal business purpose
to:
a. document CLIENT's internal QA/QI follow-up;
b. develop internal QA/QI Reports.
2. CLIENT shall be solely responsible for connection of CLIENT's systems to a
telecommunications service that provides Internet access for purposes of CLIENT's access and
use of the Software.
3. GA will provide a total of 3 hours of training to CLIENT on how to access and use the Software
for the limited purpose described in Paragraph 1.
4. To the extent applicable, GA will provide software technical support, maintenance, periodic
upgrades, and report customization.
5.Availability of Software
a. The Software will be available for access and use by Client an average of at least ninety-
nine percent (99%) of the time during each month during the term for such services
(Availability Requirement), excluding any period of Permitted Unavailability.
b. Permitted Unavailability includes Planned Outages (as defined below) and any
unavailability due to causes beyond the reasonable control of GA including without
limitation: any software, hardware, or telecommunication failures; interruption of failure of
telecommunication or digital transmission links; Internet slow-downs or failures; failures or
default of third party software, vendors or products, and unavailability resulting from the
actions or inactions of CLIENT or a failure of CLIENT's communications link or systems.
c. Planned Outages means the period during which GA conducts standard systems
maintenance. GA shall use reasonable efforts to schedule Planned Outages during non-peak
hours.
d. If GA fails to achieve the Availability Requirement, GA will use commercially reasonable
efforts to correct the interruption as promptly as practicable.
e. GA may, in its sole discretion, suspend CLIENT's access to the Software for any of the
following reasons: (i) to prevent damages to the Software or GA's systems; (ii) to comply
with any law, regulation, court order, or other government request; (iii) to otherwise protect
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GA from potential legal liability; or (iv) if an invoice remains unpaid for more than 45 days
or more days from the invoice date. GA will use reasonable efforts to provide CLIENT with
notice prior to or promptly following any suspension of access to the Software. GA will
restore access to the Software as soon as the event giving rise to the suspension has been
resolved.
6. Software Access
a. GA authorizes CLIENT's authorized workforce to use the User ID's assigned to CLIENT by
GA. CLIENT acquires no ownership rights in any User ID, and User IDs may be revoked or
changed at any time at GAs sole discretion.
b. CLIENT will adopt and maintain reasonable and appropriate security precautions for User
IDs to prevent their disclosure to or use by unauthorized persons. Each member of
CLIENTs authorized workforce shall have and use a unique identifier. CLIENT will use its
best efforts to ensure that no member of its authorized workforce uses a User ID assigned to
another person.
c. CLIENT's authorized workforce are authorized to access the Software solely for CLIENT's
site or from other sites from which GA has granted written approval to access the system.
e. CLIENT agrees that it will not abuse or misuse the system of Software including gaining or
attempting to gain unauthorized access to system or Software.
f. Except as required by law, CLIENT will not permit any third party (a part other than
CLIENT's authorized workforce) to have access to the Software or to use the Software
without GAs prior written agreement.
g. CLIENT will not: (i) decompile, disassemble, or reverse engineer the Software, (ii) use the
Software or any GA Confidential Information to develop a competing product or service;
(iii) provide, lease, lend, use for timesharing or service bureau purposes or otherwise use or
allow others to use any Software for the benefit of any third party; (iv) use any Product, or
allow the transfer, transmission, export, or re-export of the Software or portion thereof, in
violation of any export control laws or regulations administered by the U.S. Commerce
Department or any other government agency; or (v) remove any copyright, trademark,
proprietary rights, disclaimer or warning notice included on or embedded in any part of a
Software (including any screen displays, etc.) or any other products or materials provided by
GA hereunder. Under no circumstances, shall GA be liable or responsible for any use, or
any results obtained by the use, of the Software in conjunction with any other software or
third party products. All such use shall be at CLIENT’s sole risk.
7. Disclaimer of Warranties, and Liability
a. The Software, support, and training and any other services related to this license are
provided "as is" and "as available" with all faults and without warranties or liabilities of any
kind.
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b. GA disclaim all other warranties, express and implied, including, but not limited to the
implied warranties of merchantability, fitness for a particular purpose, quality of
information, and title/non-infringement.
c. CLIENT expressly agrees and acknowledges that the use of the Software is at CLIENT's
sole risk.
d. The Software may be used to access and transfer information including confidential
information over the Internet. CLIENT acknowledges and agrees that GA do not operate or
control the Internet and that (1) viruses, worms, Trojan Horses or other undesirable data or
software or (2) unauthorized third parties (hackers) may attempt to obtain access to and
damage customer's data, websites, computers, or networks. GA shall not be responsible or
liable for any such activities nor shall any such activities constitute a breach by GA of its
obligations of confidentiality contained in the Agreement.
e. GA will not be liable for any direct, special, consequential, incidental, indirect or exemplary
damages or loss (nor any lost profits, savings, or business opportunity).
f. CLIENT will notify GA promptly of any order or demand for any compulsory of
information if the disclosure requires access to or use of the Software. CLIENT will
cooperate with GA fully in connection with any such demand.
g. CLIENT will take appropriate disciplinary action against any member of their workforce
who violates the terms of this License.
h. CLIENT will immediately notify GA if a member of CLIENT's authorized workforce no
longer requires access to the Software.
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EXHIBIT B
BUSINESS ASSOCIATE AGREEMENT
Under the Agreement, as may be amended from time-to-time in accordance with its terms, GA or
GA’s agents or subcontractors may have access to Protected Health Information (“PHI”) from or on
behalf of CLIENT. To the extent applicable, the Parties desire to meet their respective obligations
under the Health Insurance Portability and Accountability Act of 1996, as amended (the “Act”),
including the federal privacy regulations (the “Privacy Rule”) and security regulations (the
“Security Rule”) promulgated pursuant to the Act and codified in the Code of Federal Regulations
(“C.F.R.”) at 45 C.F.R. parts 160 and 164 (collectively, “HIPAA”) and the Health Information
Technology for Economic and Clinical Health Act provisions of the American Recovery and
Reinvestment Act of 2009, Pub. Law No. 111-5 and its implementing regulations (collectively,
“HITECH”).
Business Associate Terms (“BA Terms”). If CLIENT is (i) a Covered Entity (“Covered Entity”
as defined in HIPAA) subject to HIPAA, or (ii) acting as a Business Associate (“Business
Associate” as defined in HIPAA) of a Covered Entity, and if GA is performing services on behalf of
CLIENT for which GA may receive or have access to PHI in order to perform such services, then
the Parties agree as follows:
1. Definitions. Unless otherwise defined in the Agreement, or these BA Terms, capitalized terms
will have the meanings set forth in HIPAA, or HITECH if the term is not defined in HIPAA, as
each is amended from time to time.
1.1 "Breach" shall mean the acquisition, access, use or disclosure of PHI in a manner not
permitted by the Privacy Rule that compromises the security or privacy of the PHI as
defined, and subject to the exceptions set forth, in 45 C.F.R. 164.402.
1.2 “Compliance Date” shall mean, in each case, the date by which compliance is required
under the referenced provision of HITECH and/or its implementing regulations, as
applicable; provided that in any case for which that date occurs prior to the Effective
Date of these BA Terms, the Compliance Date shall mean the Effective Date.
1.3 “Effective Date” shall mean the effective date as defined in the Agreement.
2. Business Associate Functions. Unless otherwise limited herein, in addition to any other uses
and/or disclosures permitted or required by these BA Terms, CLIENT authorizes GA to perform
services on behalf of CLIENT related to the EMS Quality Improvement Program which may
involve receipt of, or access to, PHI.
3. Disclosure and/or Use of PHI. GA may disclose and use PHI received from CLIENT or
CLIENT’s authorized agents as permitted or required by the Agreement, these BA Terms or as
otherwise required by law. GA may further use and disclose the PHI in its possession for the
proper management and administration or to carry out the legal responsibilities of GA, provided
that any third party to which GA discloses PHI for management, administration or to carry out
legal responsibilities of GA, provides written assurances in advance that: (i) the information will
be held confidentially and used or further disclosed only as required by law; (ii) the information
will be used only for the purpose for which it was disclosed to the third party; and (iii) the third
party promptly will notify GA of any instances of which it becomes aware in which the
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confidentiality of the information has been Breached. Without limiting the generality of the
foregoing, GA may, at GA’s sole discretion, disclose on behalf of CLIENT or the applicable
Covered Entity an Individual’s PHI in response to, and in accordance with, a valid authorization
executed by the Individual that meets the requirements set forth in the Privacy Rule.
4. Safeguards Against Misuse of PHI. GA will implement appropriate administrative, physical
and technical safeguards to prevent the use or disclosure of PHI received from CLIENT, or
CLIENT’s authorized agents, other than as permitted or required by these BA Terms.
5. Safeguards Related to Electronic PHI (“ePHI”). GA will implement administrative,
physical, and technical safeguards in compliance with HIPAA that reasonably and appropriately
protect the confidentiality, integrity, and availability of ePHI GA receives, maintains, or
transmits on behalf of CLIENT and as of the Compliance Date of 42 U.S.C. § 17931, comply
with the Security Rule requirements forth in 45 C.F.R. §§ 164.308, 164.310, 164.312 and
164.316.
6. Security of ePHI. GA will report to CLIENT any Security Incident with respect to ePHI of
which GA becomes aware and which has compromised the protections set forth in the Security
Rule. This reporting obligation does not include trivial occurrences, such as scans, “pings” or
unsuccessful attempts to penetrate computer networks or servers containing ePHI maintained by
GA. GA will implement reasonable and appropriate policies, procedures and documentation
regarding the security of ePHI in compliance with 45 C.F.R. §164.316.
7. Breach & Reporting of Unauthorized Uses/Disclosures of Unsecured PHI. GA will report
to CLIENT or the applicable Covered Entity without unreasonable delay, and in no event later
than ten (10) calendar days after Discovery, any Breach of Unsecured PHI. The notification
shall include, to the extent possible and subsequently as the information becomes available, the
identification of all Individuals whose Unsecured PHI was, or is reasonably believed to have
been, Breached and any other available information that the Covered Entity is required to
include in notification to Individuals, HHS and/or the media, all in accordance with the security
breach notification requirements set forth in 42 U.S.C. § 17932 and 45 C.F.R. Parts 160 & 164
subparts A, D, & E.
8. GA’s Employees, Agents and Subcontractors. GA will ensure any of GA’s employees,
subcontractors or agents who have access to PHI or ePHI received from CLIENT or CLIENT’s
authorized agents and subject to these BA Terms, agree to be bound by the same restrictions,
terms, and conditions on the use of PHI and ePHI that apply to GA under these BA Terms and
HIPAA. In addition, GA will enter into an agreement with any of GA’s subcontractors or
agents to whom GA provides PHI or ePHI, pursuant to which the agent or subcontractor agrees
to implement reasonable and appropriate safeguards to protect the PHI or ePHI provided by GA
in compliance with these BA Terms and HIPAA.
9. Availability of Books and Records. GA hereby agrees to make GA’s internal practices, books,
and records relating to the use and disclosure of PHI received from CLIENT or CLIENT’s
authorized agents reasonably available to the Secretary of Health and Human Services (the
“Secretary of HHS”) for purposes of determining CLIENT’s or the applicable Covered Entity’s
compliance with the Privacy Rule.
10. Mitigation. GA will make commercially reasonable efforts to mitigate, to the extent
practicable, any harmful effects known to GA resulting from an unauthorized use or disclosure
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of PHI received from CLIENT or CLIENT’s authorized agents in violation of these BA Terms
or HIPAA by GA or GA’s agents or subcontractors.
11. Minimum Necessary. In using, disclosing or requesting PHI subject to these BA Terms, GA
will make reasonable efforts to use, disclose or request only the minimum amount of PHI as
determined by CLIENT in its sole discretion necessary to accomplish the purpose of the use,
disclosure or request, provided that GA will comply with 42 U.S.C. §17935(b) as of its
Compliance Date.
12. Obligations regarding Individuals’ Rights. If applicable, GA agrees to document and within
thirty (30) business days after receiving a written request from CLIENT, make available to
CLIENT information necessary for CLIENT to make an accounting of disclosures of PHI about
an Individual in accordance with 45 C.F.R. 164.528, and as of its Compliance Date, in
accordance with the requirements for accounting for disclosures made through an Electronic
Health Record in 42 U.S.C. § 17935(c). To the extent applicable and as required under HIPAA,
if GA receives a request to provide an accounting directly to an Individual, GA will provide an
accounting of disclosures of PHI about such Individual directly to such Individual. Such written
requests from CLIENT will provide sufficient information necessary to allow GA to locate the
information within CLIENT’s dataset. In addition, GA agrees, at CLIENT’s sole cost and
expense, to make available PHI in a Designated Record Set necessary for CLIENT or the
applicable Covered Entity to respond to Individuals’ valid authorization for access to their PHI
in accordance with 45 C.F.R. 164.524. Notwithstanding any conflicting access provision in
these BA Terms, in the event that GA uses or maintains an Electronic Health Record of
information of or about an Individual, then GA shall provide an electronic copy (at the request
of CLIENT, and in the reasonable time and manner requested by CLIENT) of the PHI, to
CLIENT. Further, GA shall to the extent the PHI in GA’s possession constitutes a Designated
Record Set, make available PHI for amendment and incorporate any amendments or corrections
to the PHI as directed by CLIENT, all in accordance with 45 C.F.R. 164.526. In the event any
Individual requests access to PHI directly from GA pursuant to any of the foregoing sections of
the Privacy Rule, GA will, within thirty (30) business days, forward such request to CLIENT.
Any response to such requests or denials of access to, or amendment of, an Individual’s PHI
will be the responsibility of CLIENT. The foregoing is not intended to apply to any release by
GA of PHI in response to an Individual’s valid authorization as addressed under Section 3 of
these BA Terms.
13. Sale of PHI. GA agrees to not directly or indirectly receive remuneration in exchange for any
PHI in compliance with 42 U.S.C. § 17935(d) as of its Compliance Date.
14. CLIENT Obligations. If applicable, CLIENT agrees, at GA’s request, to identify which of the
records it furnishes to GA it considers to be PHI for purposes of these BA Terms. CLIENT
further agrees to obtain any consent or authorization that may be required under HIPAA or any
other applicable law and/or regulation prior to furnishing GA with PHI. CLIENT also agrees to
inform GA of any PHI that is subject to any arrangements permitted or required of CLIENT
under the Privacy Rule that may materially impact in any manner the use and/or disclosure of
PHI by GA under these BA Terms, including, but not limited to, restrictions on the use and/or
disclosure of PHI as provided for in 45 C.F.R. 164.522 and agreed to by CLIENT or the
applicable Covered Entity. CLIENT shall not request GA to make any use or disclosure of PHI
that would not be permitted under HIPAA if made by CLIENT or the applicable Covered Entity
directly. CLIENT agrees to fulfill its obligations under these BA Terms in a timely manner.
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15. No Third-Party Beneficiaries. Nothing expressed or implied in these BA Terms or the
Agreement is intended to confer, nor will it confer, upon any person any rights, remedies,
obligations or liabilities other than those explicitly detailed in these BA Terms or in the
Agreement.
16. Amendment. To the extent applicable, amendments or modification to HIPAA or HITECH
may require amendments to certain provisions of these BA Terms. Amendments shall only be
effective if executed in writing and signed by a duly authorized representative of each Party.
19. Term & Termination.
19.1 Failure of GA or CLIENT to comply with any of the material provisions contained in
these BA Terms or HIPAA will be deemed a breach under the Agreement, and either
Party will be entitled to exercise all available rights, including termination, as
provided in the Agreement.
19.2 Upon termination or expiration of these BA Terms or the Agreement, GA will return
or destroy all PHI received from, or created or received by GA on behalf of,
CLIENT that remains in GA’s possession or control and will retain no copies of that
PHI, or, if the return or destruction is not feasible in GA’s determination, extend the
protections of the BA Terms to the retained PHI and limit further uses and
disclosures to those purposes that make the return or destruction infeasible.
19.3 Notwithstanding any term of the Agreement or these BA Terms, as of the
Compliance Date of 42 U.S.C. § 17934(b), if either Party knows of a pattern of
activity or practice of the other Party that constitutes a material Breach or violation
of these BA Terms then the non-breaching Party shall provide written notice of the
breach or violation to the other Party that specifies the nature of the breach or
violation. The breaching Party must cure the breach or end the violation on or before
thirty (30) business days after receipt of the written notice. In the absence of a cure
reasonably satisfactory to the non-breaching Party within the specified timeframe, or
in the event that the breach is reasonably incapable of cure, then the non-breaching
Party may terminate these BA Terms and the Agreement or, if termination of these
BA Terms is infeasible, report the problem to the Secretary of HHS.
20. Construction of Terms. To the extent they are not clear, the terms of these BA Terms shall be
construed to allow for compliance by both Parties with HIPAA and HITECH.
21. Compliance with HITECH. To the extent applicable, the Parties desire to meet their
respective obligations under HIPAA and HITECH. The provisions of this Section apply only to
the extent HITECH specifically applies to GA. The Parties (i) will, to the extent applicable,
comply with the privacy and security requirements of HITECH and (ii) will, to the extent not
already included, amend these BA Terms to incorporate the provisions of HITECH, or its
implementing regulations that are required to be incorporated into business associate
agreements. No amendment or modification of any of the provisions of these BA Terms shall be
effective unless executed in writing and signed by a duly authorized representative of each Party as
required by Section 18 of these BA Terms. In the event the Parties are unable for any reason to
reach agreement on a mutually acceptable amendment or modification, either Party may
immediately terminate the Agreement upon written notice to the other Party.
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22. Limitation of Costs. CLIENT will compensate GA at GA’s then current time and materials
rates for all assistance, services, and work performed outside of GA’s obligations as required
under HIPAA or not otherwise contemplated by these BA Terms over the term of the
Agreement. GA will obtain CLIENT’s prior written authorization before incurring any fees in
excess of the foregoing amount. In the event CLIENT fails for any reason to approve such fees,
GA will have no obligation to perform the services, work, and assistance associated with such
fees.
23. Integration. The Parties hereby agree that these BA Terms supersede and replace any prior
written or oral agreements between the Parties related to the subject matter of these BA Terms.
24. Survival. Sections 18, 19.2, 20, and 24 of these BA Terms shall survive the expiration or
termination for any reason of the Agreement and/or these BA Terms.
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EXHIBIT C
Acceptable Use Policy
All customers and users of the services and products provided by or through GA agree to comply
with this Acceptable Use Policy (AUP) – it is part of your contract with us. The AUP reflects the
use of our products and services at the time it was drafted, but it is not static. Updating and
enhancing our products and services, along with changes in the way these products and services
may be used, requires us to update our AUP from time-to-time. If we make changes that are more
than typographical, we will provide notice to you by email to the address you provide us in your
account. Termination provisions in the Services Agreement (the “Agreement”) will apply to
changes that materially affect your use of the services. All material changes will be effective 30
days from posting here. Words that are capitalized in this AUP have the meanings given them in the
Agreement.
1. Accurate Information
You are required to provide us with accurate information. This requirement includes
information you provide to us during sign up, and in communications with us. Failure to
provide us with accurate information is a material breach of this AUP and the Agreement,
and if not cured within the time set out in the Agreement will lead to termination.
2. Abuse
It is your obligation to determine that your personnel are permitted to our services. You may
not use GA’s network or services to engage in, foster, or promote illegal, abusive, or
irresponsible behavior. You are responsible for the content you upload or transmit using our
products and services. You may use this AUP as a baseline to determine whether a particular
use is permitted. However, there may be uses that are not defined here that are not lawful, or
are generally prohibited by the Internet community. We will contact you by email should
you violate this AUP. You will be given an opportunity to cure this violation. If the violation
endangers our ability to provide the services, or our other customers, we may immediately
suspend you. The use of our products and Services in the following activities is strictly
prohibited:
o Any conduct that is likely to result in retaliation against the GA network or website,
or GA’s employees, officers or other agents, including engaging in behavior that
results in any server being the target of a denial of service attack;
o Facilitating, encouraging or providing assistance to any activity that engages in
hacking, spreading viruses or compromises security in any way;
o Facilitating, encouraging or providing assistance to any activity that engages in
defamation, slander, hate speech or any similar act;
o Is excessively violent, incites violence, threatens violence, or contains harassing
content or hate speech;
o Is unfair or deceptive under the consumer protection laws of any jurisdiction,
including chain letters and pyramid schemes;
o Creates a risk to a person’s safety or health, creates a risk to public safety or health,
compromises national security, or interferes with an investigation by law
enforcement;
o Infringes on another person’s copyright, trade or service mark, patent, or other
property right or is designed to circumvent protective systems; or
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o Is otherwise illegal or solicits conduct that is illegal under laws applicable to you or
to GA.
3. Bulk Email
If applicable, you must comply with the CAN-SPAM Act of 2003 and other laws and
regulations applicable to bulk or commercial email. You may use your Services to send bulk
mail, if you comply with the CAN-SPAM Act of 2003.
4. Mail Requirements
You must comply with the CAN-SPAM Act of 2003 and other laws and regulations
applicable to bulk or commercial email. These policies apply to messages sent using your
Services, or to messages sent from any network by you or any person on your behalf that
directly or indirectly refer the recipient to a site or an email address hosted via your Service.
GA may block the transmission of email that violates these provisions. GA may, at its
discretion, require certain customers to seek advance approval for bulk and commercial
email, which approval will not be granted unless the customer can demonstrate that all of the
requirements stated above will be met.
5. Copyrighted Material
GA complies with the Digital Millennium Copyright Act (“DMCA”). Customers are
required to comply with U.S. copyright laws. If a copyright holder believes that GA
customer has infringed a copyright, the copyright holder is required to comply with all
provisions of the DMCA. If the copyright holder has reviewed the DMCA, and understand
its provisions, it may submit your DMCA notice to GA.