MEMORANDUM OF UNDERSTANDING
FOR DATA SHARING AND USE
This Data Sharing and Use Agreement (“Agreement”) is made and entered into by and between Acumen,
LLC. a California limited liability company located at 500 Airport Blvd., Suite 100. Burlingame, CA 94010
(“Acumen”). and the Virgin Islands Department of Health, Immunization Division (the ‘Participating uS
Jurisdiction”), an executive agency of the Government of the U.S. Virgin Islands of U.S. Virgin Islands
(uS Jurisdiction “IISJ’). Acumen and IISJ may be referred to herein collectively as the “Parties” or
individually as a “Party” through the Virgin Islands Department of Property and Procurement. This
Agreement shall be effective upon its execution by all signatories (“Effective Date”) is made this
________
day of,..
. 2022. in the Territory of the U.S. Virgin Islands.
WHEREAS. Participating IIS Jurisdiction is a governmental agency created under law and a public health
authority under 45 CFR § 164.501 of the regulations promulgated under the Health Insurance Portability and
Accountability Act (HIPAA). Among its authorized public health activities is the receipt of information and
reports concerning immunization, vaccination, disease, injury, and vital events for purposes including
public health surveillance, investigations, and interventions:
WHEREAS, under the sponsorship of the Center for Biologics Evaluation and Research (CBER) of the
Food and Drug Administration (FDA). Acumen serves as a Trusted Agent contractor of the FDA (“FDA
Agent”) in its surveillance programs monitoring the safety and effectiveness of vaccines distributed to the
U.S. market: in this role, Acumen acts as a “public health authority” as defined in 45 CFR § 164.501 of
HIPAA:
NOW, THEREFORE, in consideration of the mutual covenants, terms, and conditions set forth herein.
and for other good and valuable consideration, the receipt and sufficiency of which are hereby
acknowledged. the Parties agree as tbllows:
1.
Background and Purpose
1.1
Background.
FDA launched the Biologics Effectiveness and Safet) (BEST) Initiative in 2017 to enact
an active post-market surveillance of the safety and effectiveness of biologic products, with
BEST promulgated by the 21st Century Cures Act of 2016 (Cures Act). The Cures Act
directed FDA to establish a regulatory t’ramework incorporating use of real-world evidence
to support expedited product development and conduct post-approval evaluations of
product outcomes. A major component of BEST comprises rapid-cycle surveillance of the
health outcomes related to immunizations. with its findings intended to inform FDA in its
regulatory actions affecting the use and availability of different vaccines in U.S. healthcare
markets.
Acumen serves as the primarY FDA CBER contractor providing the data analysis services
necessary for the near real-time monitoring of the use of vaccines in the Medicare and
Medicaid populations. Acumen’s activities principally focus on establishing and building
reliable capacities to conduct analyses of data from national electronic healthcare systems
to follow the experiences of immunized individuals, assessing the extent to which these
individuals experience various adverse (safety) and favorable (effectiveness) outcomes
potentially attributable to vaccination. Acumen’s data holdings include complete historical
medical encounters and enrollment data for the entirety of Medicare and Medicaid (all
states) populations. with records updated daily and weekly; these holdings further include
comprehensive personally identifiable information (P11) and protected health information
(PHI) for all beneticiaries in these populations.
Acumen maintains official Federal
government health data facilities, entitled the Acumen Data Center (“ADC”).’ where it
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securely stores and analyzes the data used to monitor the safety and effectiveness of
vaccines and other biological products regulated by the FDA.
Acumen conducts ‘signal detection’
of adverse health events and initial empirical
investigations of potential safety signals associated with immunizations. FDA heavily
relies on these rapid-cycle findings to evaluate the post-market safety and efficacy of
released vaccines, with processes in place to regulate their use and inform further studies
of individual vaccines. Acumen’s use of US vaccination data in its empirical analyses and
reporting constitutes a public health surveillance activity, not independent research.
1.2
Purpose.
Acumen. as a Trusted Agent of FDA (FDA Agent). seeks to acquire lIS registry records
with frequent updating for the universe of individuals ever enrolled in the Medicare and
Medicaid programs. The request here is for individual-level immunization data to be made
available to Acumen for linkage to Medicare and Medicaid beneficiaries enabling Acumen
to perform statistical analyses and evaluations requested FDA, with descriptive findings
and analytical results shared with FDA to inform its regulation. rule, and decision—making.
FDA will not have direct access to immunization data, only access to data summaries and
some de-identified records to validate the quality of clinical records.
Acquiring timely and comprehensive immunization data at the individual level is critical
in growing FDA’s capabilities to perform required. reliable surveillance investigations of
vaccine outcomes. BEST monitoring requires reliable linkage of immunization data to
medical service encounters to identify the incidence and timing of treatments and probable
impacts on health outcomes. The llS immunization registries accurately capture data about
individuals vaccine exposures not recorded in medical encounter events collected from
health insurance entities, such as Medicare and Medicaid. Misclassifying individuals as
unvaccinated when they are in fact vaccinated sharply diminishes statistical capabilities to
ascertain elevated risks or may significantly underestimate rates of vaccine effectiveness.
The required frequency of updating immunization information depends on the needs and
priorities of FDA’s rapid-cycle vaccination surveillance program. hich can be as frequent
as weekly updates during influenza vaccination seasons.
2.
Legal Authorities
2.1
FDA Aeent (Acumen)
2.1.1
Acumen serves as the prime contractor for the task order ‘Conduct Surveillance
Activities for Safety and Effectiveness of Biologics’ (contract HHSF-223-2018-
100201) under FDA’s BEST IDIQ entitled Data. Tools, and Infrastructure for
Surveillance of Biologics
(contract FDA- 18-223-SQL-Il 96209). The primary
objectives of this contract consist of expanding and enhancing CBERs available
data sources,
infrastructure, methods.
and tools to conduct near real-time
surveillance and rapid-cycle epidemiologic studies that promote CBERs Office of
Biostatistics and Pharmacovigilance mission to assure the safety and effectiveness
of biologic products including vaccines, blood and blood products. tissues, and
advanced therapeutics.
2.1.2
The following statutory and regulatory provisions describe F DA’s authorizati on by
law to collect PHI/Pil data (encompassing immunization records) and to delegate
its “public health authority’ for this activity to Acumen as its Trusted Agent. The
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provisions below come from the Health Insurance Portability and Accountability
Act (HIPAA) Privacy Rule Part 164. Title 45 (Public Welfare). and the Food and
Drug Administration Amendments Act of 2007 (FDAAA):
(a)
Title 45 CFR § 164.512(b)(1)(i) of the HIPAA Privacy Rule permits a
“covered entity’ or part of a “hybrid entity’ to disclose PHI to a public
health authority that is authorized by law to collect or receive such
information to
carry
out
authorized
public
health
activities.
Such
disclosures should be limited to the minimum data necessar to carr’ out
the assigned public health activities (Title 45 CFR § 164.502(h)).
(b)
Under Title 45 CFR § 164.501, a “public health authority” includes an
agency of the United States responsible for public health matters as part of
its official mandate. FDA is such an agency. Section 905 of FDAAA
grants FDA authority to provide for active adverse event surveillance
using data from healthcare programs, among other sources. The BEST
Projects operate under this authority.
(c)
As described in Title 45 § CFR 164.501 of the HIPAA Privacy Rule, the
definition of “public health authority” also includes a “person or entity
acting under a grant of aLithority from or contract” with a public agency
that is responsible for public health matters as part of its official mandate.
As such, when FDA’s contractor (Acumen) reaches out to registries for
individual immunization records for the surveillance work described
above, it will be doing so as a public health authority.
(d)
HIPAA-covered entities must verify that a person requesting PHI for
public health purposes is a public health authority. For this purpose.
HIPAA—covered entities are entitled to rely on a written statement on
appropriate government letterhead that the person is acting under the
government’s authority (see 45 CFR § 164.5 l4(h)(2)(ii)(C)). A copy of
this letter, or content from this letter placed on FDA letterhead, should be
provided by the FDA designated contractor to each PHI provider from
whom immunization data will be sought under the BEST Projects. It will
serve to provide the necessary written statement of authority to FDA
contractors working on the project.
(e)
The HIPAA Privacy Rule also requires covered entities to comply with the
minimum necessary rule stated in Title 45 CFR § 164.502(b) but permits
covered entities to rely on representations by a public health authority that
it is requesting only the minimum amount of PHI necessary to carry’ out
its public health mission (see 45CFR
§
164.5 14(d)(3)(iii)(A)). The
immunization records requested to conduct FDAs’ safety and effectiveness
surveillance are essential to producing reliable information for FDA to
meet its statutory and regulatory requirements. In the judgment of FDA,
these requests constitute the mininuim necessary information required to
carry out FDA’s responsibilities under the BEST Program. Thus. IIS
registries and HIPAA-covered entities may determine that data requests
from FDA conveyed through its Trusted Agent Acumen meet the
mini mum necessary standards.
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2.1.3
Exhibit B presents a copy of FDAs Letter of Support. citing Acunien as its
Trusted Agent for the work covered by the Purpose of this Agreement and
officially delegating its public health authority. Accordingly, when Acumen
reaches out to IIS registries for individual immunization records for FDAs
vaccination surveillance work, it does so as a public health authority.
2.2
IISJ
2.2.1
The Virgin Islands Department of Health is responsible for ensuring health care
to the residents of the Territory pursuant to Title 3. Section 23 and Title 19,
Section
1 of the Virgin Islands Code.
2.2.1
By entering into this Agreement, the JISJ agrees that it is authorized to transmit or
allow the transmission of its IISJ Response File data to the Acumen Data Center
(ADC).
2.2.2
As applicable, the Parties acknowledge that the IlSi is a
covered entity” or part
of a “hybrid entity.” as those terms are defined under the HIPAA Privacy Rule. 45
CFR § 160.103 and § 164.103. respectively.
3.
Description of Data Files and Exchaiiges
3.1
Data Files Covered by this Agreement
3.1.1
Finder File
FDA Agent (Acumen) will periodically send Finder Files to IISJ
identifying the Medicare and Medicaid beneficiaries in the IISJ’s jurisdiction and
a time flame for acquiring immunization data.
(a)
The FDA Agent Finder Files will contain P11 and PHI data, including
records depicting some or all the following data elements: beneficiary
name. date of birth. gender. Social Securit Number, mailing address.
Medicare Beneficiary Identifier, and Medicaid Beneficiary Identifier.
(b)
The data elements in the Finder File vill be limited to the minimum
necessary data elements for the IISJ or its authorized representatives to
perform a complete and accurate query identi’ing those Medicare and
Medicaid beneficiaries residing in the II S’s jurisdiction.
(c)
Each Finder Files will include the dates of service defining the time
horizon requested for records.
3.1.2
IISJ Response File— In response to receiving a Finder File, the IISJ will return to
FDA Agent an IISJ Response File disclosing vaccine events and administration
records for those Medicare and Medicaid beneficiaries identified by the Finder File
for whom the IISJ has immunization records. The IISJ Response File will contain:
(a)
The same P11 data elements provided in the Finder File to confirm the
identified individuals for whom data are being exchanged.
(b)
The PHI and administration data records describing all immunizations
received by each identified individual for the period of time specified in
the FDA Agent Finder File.
(c)
In cases of multiple or nearly complete matches of P11 data to individuals
in immunization registries. including IIS records for all these “matched’
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individuals will allow FDA Agent to identify the proper match using its
extensive supplementary data sources.
3.1.3
IISJ Data
— The accumulation of the immunization data obtained by FDA Agent
from integrating the records and data elements contained in the union of IISJ
Response Files.
3.2
Exhibit A provides the list of the data elements to be included for each uS immunization
record in the IISJ Response File. The data elements in the IISJ Response File will be limited
to the minimum necessary data elements for Acumen to undertake the Purpose of this
Agreement.
3.3
Operational Time Span for Response File Records
3.3.1
FDA Agent will transmit the IISJ a Finder File weekly or monthly, depending on
the priorities and needs of the FDA safety surveillance program.
4.
Description of Data Uses
4.1
FDA Agent (Acumen)
4.1.1
FDA Agent will link IISJ immunization records to the universe of medical records
in the Medicare and Medicaid databases collected and maintained by the Centers
for Medicare & Medicaid Services (CMS).
with linkage performed
at the
individual level. This linkage and all data analyses will be performed within the
Acumen Data Center (ADC) and will not directly involve CMS. FDA Agent will
use this integrated dataset to construct detailed health and medical service histories
for
individual
Medicare and
Medicaid beneficiaries,
enabling tracking the
incidence and timing of vaccination events and various classifications of health
outcomes.
4.1.2
FDA Agent will use these integrated datasets to conduct data analyses informing
FDA’s post-market surveillance of the safety and effectiveness of vaccines. These
data analyses serve as the primary source of information for FDA in their near real
time monitoring of health outcomes related to immunizations, including both
signal detection’ of adverse health events and initial empirical investigations of
potential safety signals. FDA heavily relies on these rapid-cycle findings to
evaluate the post-market safety and efficacy of released vaccines, with processes
in place to regulate their use and inform further studies of individual vaccines.
4.1.3
The IISJ Data governed by this Agreement will only be used for FDA monitoring
vaccines’ safety and effectiveness. Data uniquely obtained through Response Files
will not be used in any manner other than to support the Purpose ofthis Agreement.
4.2
IISJ
4.2.1
The liSi may have access to FDA Agent’s Finder Files in the querying of its
immunization registries, which will contain P11 data for Medicare and Medicaid
beneficiaries. Data from the Finder Files obtained under this Agreement may be
used only for that purpose and only as indicated in this Agreement; other uses and
disclosures by the IISJ are not permitted.
4.3
FDA and other agencies
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4.3.1
The FDA receives statistical surveillance findings from aggregated and de
identified empirical results. FDA does not have access to any P11 or individually-
identifiable PHI data.
4.3.2
No government agency, including FDA. will have access to any personally
identifiable II SJ immunization data or findings.
4.4
IISJ and Acumen exchange of personally-identifying information
4.4.1
By mutual written agreement. IISJ and Acumen may coordinate exchanging P11
data to improve the accuracy of the P11 information in their respective databases
related to vaccinated persons.
5.
Roles and Responsibilities of FDA Agent (Acumen)
5.1
Following the execution of this Agreement. FDA Agent will transmit Finder Files to the
IIJS periodically in a manner through secured and encrypted communication mechanisms.
Procedures for the
linkage and extraction of matched immunization data and the
structure/format of the Response File will be determined by I ISJ and Acumen in a manner
with the least burden incurred b the
I 1SJ. The frequenc of the acquisition of I ISJ
Response Files will depend on FDA priorities and as mutually determined by IISJ and
Acumen.
5.2
Data and System Security
5.2.1
FDA
Agent
will
use
commercially
reasonable
efforts
to
maintain
the
confidentiality of IISJ data within an IT/data infrastructure with an Authority to
Operate (ATO) accredited as a moderate-level Federal Information Security
Modernization Act (F I SMA) or Federal Risk and Authorization Management
Program (FedRAMP) system.
(a)
FISMAFedRAMP securit
provisions provide a level and scope of
security consistent with the level and scope of security established by the
Office of Management and BLidget (0MB) in 0MB Circular No. A—130,
Appendix IlI—Securit
of Federal Automated Information Systems,
which sets forth guidelines for security plans for automated information
systems in Federal agencies. Federal data centers with an ATO under
FISMA/FedRAMP are authorized to store and transmit confidential health
data and make it available for analysis.
(b)
FDA
Agent
will
use
protocols
consistent
with
FISMA’FedRAMP
provisions in executing any transmissions of llSJ’s data to authorized
entities and will not perform such transmissions unless approved by IISJ.
(c)
FISMA/FedRAMP provisions mandate that all FDA Agent employees
with any access or interaction with IISJ Data must adhere to stringent
behavioral and training security protocols consistent with this Section 5.2
(Data and System Securit). These provisions fully extend to all FDA
Agents agents. subcontractors. and their associated employees with any
access to IISJ Data or the findings derived from it.
5.2.2
FDA Agent will designate a custodian of the Response Files received from IISJ,
with this custodian responsible for ensuring the protection of 11SF immunization
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datasets and derivate files, Upon agreement execution. FDA Agent will provide
the designated custodian’s name and contact information to IISJ.
5.3
Data Protection and Disclosures
5.3.1
FDA Agent will under no circumstances use, share, copy, duplicate, or otherwise
reproduce any immunization data obtained from IISJ Response Files or any portion
thereof in any manner other than to support the Purpose.
5.3.2
FDA Agent will not disclose to any third parties. nor permit ally third parties to
access or use. any immunization data uniquely obtained through IISJ Response
linked to P11 data without prior written consent from IISJ.
5.3.3
FDA Agent will share no findings revealing personall\ -identifiable imniunization
data received through IISJ registries with the FDA or any other agency without
prior written consent from IISJ. FDA conducts its surveillance duties through
reviews of aggregated data analysis and statistical findings received from its FDA
Agent.
5.3.4
FDA Agent ill not use data acquired through llSJ Response Files for any ptlrpose
that knowingly and willfully:
(a)
infringes on IISJ’s or an third party’s copyright. patent. trademark, or
other proprietary rights or rights of publicity or privacy: or
(b)
violates any applicable law.
5.3.5
If disclosure of the IISJ Data other than that necessary to conduct the Purpose is
required by law, it shall take place only after prior notification of IISJ.
5.4
Reporting and Treatment of Data Breaches
5.4.1
FDA Agent will notify hiS without unreasonable delay. but in any event, no later
than within twenty-four (24) hours of the discovery of any acquisition, access. use.
or disclosure of privacy information that is not in compliance with the terms of this
Agreement.
5.4.2
FDA Agent will make every effort to cure any privacy violatioll as SOON as possible
and regularly update IISJ on the status and progress of such cures.
6.
Roles and Responsibilities of IISJ
6.1
Following tile execution oftilis Agreenlent, the IISJ will establish and maintain procedures
and protocols for using the Finder Files to query the IISJ registry for vaccine records and
adnlinistration data to create the IISJ Response Files.
6.2
The IISJ will establish mechanisms and procedures to create and transmit IISJ Response
Files to FDA Agent promptly and securely. Tile 11SF Response Files will be sent
electronically via encrypted transmission, as determined by IISJ and Acumen.
6.3
Data Protection, Disclosures. and Retentioll
6.3.1
The IISJ attests that it will maintain, use, and disclose the Finder File data only as
permitted by this Agreement and ill accordance with applicable law, including
HIPAA and any applicable state laws.
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6.3.2
The IISJ may have access to FDA Agent’s Finder File in quel)’ing its immunization
registries, including P11 data for Medicare and Medicaid beneficiaries. Data from
the Finder File obtained under this Agreement may be used only for that purpose
and only as indicated in this Agreement; other uses and disclosures by the IISJ are
not permitted.
6.3.3
llSJ acknowledges that FDA Agent is disclosing P11 data to the IISJ. and the IISJ
is not disclosing any P11 data beyond that already revealed by FDA Agent.
6.3.4
The Parties acknowledge that IISJ retains no form of ownership rights to the Finder
File data for which it gains access under the terms of this Agreement. and that the
IISJ does not obtain any right, title. or interest in any of the data furnished in these
Finder Files.
6.3.5
The llSJ will retain the Finder File data and any derivative only for the period of
time required to process or for purposes related to the approved uses for which the
data were received. Upon the end ofthis retention period. IISJ will securely destroy
any Finder File information in its possession. These retention provisions survive
the conclusion or termination of the Agreement.
7.
Term aiid Termination
7.1
Term.
The term of this Agreement will commence on the Effective Date and. unless
terminated earlier in accordance with Section 7.2 (Termination), will continue thereafter in
full force and effect until IISJ Data is no longer needed to fulfill the Purpose specified in
this Agreement.
7.2
Termination. In addition to any other express termination right set forth in this Agreement:
7.2.1
Either Parts’ max’ terminate this Agreement without cause upon sixty (60) calendar
days’ prior written Notice to the other Party.
7.2.2
Either Pall) may terminate this Agreement for cause, effective on written Notice
to the other Party, if the other Party materially breaches this Agreement and such
breach: (i) is incapable of cure; or(ii) being capable ofcure, remains uncured thirty
(30) calendar days after the non-breaching Party provides the breaching Party with
written Notice of such breach.
7.3
Effect of Termination.
Upon any termination or expiration of this Agreement for any
reason. FDA Agent will cease using llSJ’s Data and return or destroy any datasets derived
from IISJ Response Files in connection with this Agreement, unless otherwise directed by
I1SJ in written communication. If FDA Agent cannot perform either of the aforementioned
actions. FDA Agent will continue to protect any such information from unauthorized
access or disclosure pursuant to Section 5 so long as such information remains in its
possession and control.
7.4
Survival.
FDA Agent ‘s obligations of non-disclosure with regard to privacy information
will survive the termination or expiration of this Agreement for as long as such privacy
information remains subject to protection under applicable law.
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8.
Representations Warranties, and Limitation of Liability
8.1
IISJ Data supplied to FDA Agent pursuant to this Agreement are provided “as is.” IISJ
makes no warranty of any kind, express or implied, concerning the Data, including any
warranties of merchantability or fitness for a particular purpose.
IISJ assumes no
responsibility or legal liability concerning IISJ Data’s accuracy, reliability, completeness.
or timeliness.
8.2
IlSi will not be liable to FDA Agent for any loss, claim, or demand made by FDA Agent
or made against FDA Agent by any other party arising from the use of IISJ’s Data, except
to the extent permitted by law or when caused by the negligence or willful misconduct by
IISJ.
8.3
No indemnification for an loss, claim, damage. or liability is intended or provided by
either Party under this Agreement.
8.4
Each Party will be responsible for its o\n acts or omissions and those acts or omissions of
its officers, direct employees, contractors and agents in the performance of this Agreement.
Neither Party to this Agreement will be responsible for the acts and omissions of those
entities or individuals not a party to this Agreement.
8.5
Each Party represents its execution and performance of this Agreement will not violate any
applicable law or other agreement.
9.
General Provisions
9.1
Governing law. Each party shall be governed by the laws of its own jurisdiction and any
applicable federal laws.
9.2
Notices.
All
notices,
requests.
consents,
claims,
demands,
waivers,
and
other
communications hereunder (each, a “Notice”) must he in writing, and the sending Part)
must have written acknowledgment of receipt from the receiving Party. All Notices must
be delivered by email (with confirmation of transmission). or personal delivery, nationally
recognized overnight courier (with all fees pre-paid). or certified or registered mail (in each
case, return receipt requested. postage pre-paid). If acknowledgment of receipt is not
forthcoming without unreasonable delay, the sending Party must transmit this Notice by
certified or registered mail addressed to the Pall) at the addresses that may be designated
by the Party receiving Notice from time to time in accordance with this Section. Except as
otherwise pi’ovided in this Agreement. a Notice is effective only: (a) upon receipt by the
receiving Party; and (b) if the Party giving the Notice has complied with the requirements
of this Section.
9.3
Electronic Signatures.
Duly authorized representatives may use electronic and digital
signatures to execute this Agreement and any of its amendments, unless prohibited by any
applicable law.
9.4
Counterparts. This Agreement may be executed in two oi’ more counterparts, each of which
shall be deemed an original. but all of which together shall constitute one and the same
instrument. Signed documents.
md uding this Agreement and any amendment hereto.
transmitted via electronic means shall be afforded the same weight as documents with
signatures and will be sufficient to show execution and delivery thereof.
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9.5
Severability. The terms and provisions of this Agreement are severable, and if any term or
provision of this Agreement shall be held to be invalid, illegal, or otherwise unenforceable.
in whole or in part, the remainder of the terms and provisions, or enforceable parts thereof.
shall not be affected thereby and shall be enforced to the fullest extent permitted by law.
Upon
a determination that any term or provision
is invalid, illegal, or otherwise
unenforceable, the Parties hereto shall negotiate in good faith to modify this Agreement to
effect the original intent of the Parties as closely as possible in order that the transactions
contemplated hereby be consummated as originally contemplated to the greatest extent
possible.
9.6
Amendment and Modification.
No amendment or modification to this Agreement is
effective unless it is in writing, identified as an amendment to this Agreement, and signed
by an authorized representative of each Party to this Agreement.
9.7
Assignment.
This Agreement may not be assigned or transferred for any reason
whatsoever without the other part’s prior written consent and any action or conduct in
violation of the foregoing will be void and without effect.
9.8
Entire Agreement.
This Agreement. together with any other documents incorporated
herein by reference and all related Exhibits, constitutes the sole and entire agreement of the
Parties
ith respect to the subject matter of this Agreement and supersedes all prior and
contemporaneous understandings, agreements. and representations and warranties, both
written and oral,
ith respect to such subject matter.
9.9
Exhibit A and B attached hereto are a part of this Agreement and are incorporated herein
by reference.
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Each Party has caused this Agreement to be executed by its duly authorized representative as of
the Effective Date.
Acumen, LLC
By’:
(Signature)
Bonnie Johnson
(Print Name)
Contracts Director
(Print Title)
9/1 6’2022
(Date)
!usta E. Encarnacion, Commissioner
Department of Health
10/12/202 2
Anthony D. Thomas, Commissioner
Department of Property and Procurement
Date
APPROVED AS TO LEGAL
DEPARTMENT OF JUSTICE BY
enera
10/21/2022
WITNESSES:
4U A 4-FI&
GOVERNMENT OF THE U. S. VIRGIN ISLANDS
Date
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