SOURCES SOUGHT
Q -- INTRA-OPERATIVE NEUROPHYSIOLOGICAL MONITORING SERVICE
- Notice Date
- 11/5/2020 9:09:05 AM
- Notice Type
- Sources Sought
- NAICS
- 621111
— Offices of Physicians (except Mental Health Specialists)
- Contracting Office
- 258-NETWORK CNTRCT OFF 22G (36C258) MESA AZ 85212 USA
- ZIP Code
- 85212
- Solicitation Number
- 36C25821Q0019
- Response Due
- 11/23/2020 10:00:00 AM
- Archive Date
- 03/02/2021
- Point of Contact
- Timothy M. Harris, Contract Specialist, Phone: 520-629-4611
- E-Mail Address
-
timothy.harris5@va.gov
(timothy.harris5@va.gov)
- Awardee
- null
- Description
- This is a SOURCES SOUGHT ANNOUNCEMENT ONLY. It is neither a solicitation announcement nor a request for proposals or quotes and does not obligate the Government to award a contract. Requests for a solicitation will not receive a response. Responses to this Sources Sought must be in writing. The purpose of this Sources Sought Announcement is for market research to make appropriate acquisition decisions and to gain knowledge of potential qualified Businesses interested and capable of providing the services described below. Documentation of technical expertise must be presented in sufficient detail for the Government to determine that your company possesses the necessary functional area expertise and experience to compete for this acquisition. Responses to this notice shall include the following: (a) company name (b) address (c) point of contact (d) phone, fax, and email (e) DUNS number (f) Cage Code (g) Tax ID Number (h) Type of small business, e.g. Services Disabled Veteran Owned small Business, Veteran-owned small business, 8(a), HUB Zone, Women Owned Small Business, Small disadvantaged business, Small Business HUB Zone business, or Other than Small Business, and (i) must provide a capability statement that addresses the organizations qualifications and ability to perform as a contractor for the work described below: The Intra-operative Neurophysiological Monitoring Service described in this contract shall be provided by the contractor subject to overall clinical and technical direction by the Southern Arizona VA Health Care System s (SAVAHCS) Attending, Neurosurgery and Anesthesiologist Surgical Care Line. The contractor and employees shall have a minimum of 5 years experience in IONMS services and shall provide all equipment, labor, materials, accessories, and supplies necessary for a Complete Intraoperative Neuromonitoring (IONM) Service that can support any of the SAVAHCS surgical operating rooms in the facility. The contractor shall be capable of providing real-time data; in addition, the contractor shall provide the most recent technology and hardware to include internet connection and VPN account. The contractor will work closely with the surgeons, nursing staff, schedulers, Clinical Engineering, and Sterilization and Processing Service. The online Neurologists will provide real-time monitoring via HIPPAA & HITECH (or similar) compliant telemedicine. Base Year plus 4 Option Years from date of award. (Est. 4/1/2021-3/31/2022, Est. ultimate end date of 3/31/26). Important information: The Government is not obligated to nor will it pay for or reimburse any costs associated with responding to this sources sought synopsis request. This notice shall not be construed as a commitment by the Government to issue a solicitation or ultimately award a contract, nor does it restrict the Government to a particular acquisition approach. The Government will in no way be bound to this information if any solicitation is issued. No sub-contracting opportunity is anticipated. The North American Classification System (NAICS) code for this acquisition is 621111 ($10 Million). Notice to potential offerors: All offerors who provide goods or services to the United States Federal Government must be registered in the System for Award Management (SAM located on the web at www.sam.gov). Additionally, all Service-Disabled Veteran Owned Businesses or Veteran Owned Businesses who respond to a solicitation on this project must be registered with the Department of Veterans Affairs Center for Veterans Enterprise VetBiz Registry located at https://www.vip.vetbiz.gov. All interested Offerors should submit information by e-mail to: timothy.harris5@va.gov. All information submissions to be marked Attn: Timothy M. Harris, Contracting Specialist and should be received no later than 1:00 pm EST on November 23, 2020. After review of the responses to this announcement, the Government intends to proceed with the acquisition and a subsequent solicitation will be published. PERFORMANCE WORK STATEMENT (PWS) INTRA-OPERATIVE NEUROPHYSIOLOGICAL MONITORING SERVICE 1.0 BACKGROUND: The Southern Arizona VA Health Care System (SAVAHCS) located at 3601 S. 6th Ave., Tucson, Arizona, has an ongoing requirement for contractor services to provide Intra-operative Neurophysiological Monitoring Services. The provided care shall cover the application and interpretation of various electrophysiological and vascular tests for patients with central and/or peripheral nervous systems and/or vascular systems at risk normally provided in a similar civilian health care facility, in accordance with the specifications and requirements contained herein. 2.0 SCOPE: The Intra-operative Neurophysiological Monitoring Service described in this contract shall be provided by the contractor subject to overall clinical and technical direction by the Southern Arizona VA Health Care System s (SAVAHCS) Attending, Neurosurgery and Anesthesiologist Surgical Care Line. The contractor and employees shall have a minimum of 5 years experience in IONMS services and shall provide all equipment, labor, materials, accessories, and supplies necessary for a Complete Intraoperative Neuromonitoring (IONM) Service that can support any of the SAVAHCS surgical operating rooms in the facility. Clinical and technical direction of contract employees does not include personnel actions such as hiring, firing or job evaluation for pay purposes. Clinical and technical direction does include monitoring quality of care, assignment of cases and assignment of physician and/or technologist supervision duties. Further, the SAVAHCS Chief, Surgical Care Line or delegate retains authority to immediately correct any adverse situation potentially affecting the safety of a VA patient. DELIVERABLES 2.1 DELIVERABLE #1: Complete Intraoperative Neuromonitoring (IONM) Service The Contractor shall be capable of providing real-time data; in addition, the Contractor shall provide the most recent technology and hardware to include internet connection and VPN account. The Contractor will work closely with the surgeons, nursing staff, schedulers, Clinical Engineering, and Sterilization and Processing Service. The online Neurologists will provide real-time monitoring via HIPPAA & HITECH (or similar) compliant telemedicine. The Contractor shall provide scheduled services throughout the contract period. In the event of the absence of contractor s personnel for any reason, the contractor shall bear the responsibility of providing replacement personnel to provide the scheduled services. All and any replacement personnel must meet the Credentialing & Privileging requirements prior to providing care to SAVAHCS s patients. Finally, the Contractor will provide a complete Quality Assurance program that monitors, track any successes or complications, and trends that are reported to the SAVAHCS s Surgical Work Group (FSWG) quarterly. The Quality Assurance Surveillance Plan (QASP) is managed by the Contractor and presented to the FSWG. 2.1.1 DELIVERABLE #2: Program Management and Contractor Qualifications The Contractor shall provide all project management services under this contract. Project management services are assumed by the Government to be integral and inherent in the performance of all service tasks of this contract. The Contractor shall provide a draft comprehensive management plan with the proposal that includes all items necessary for the successful completion of this project. Face to face installation meetings and related activities shall begin within 30 days of contract award and shall be conducted at SAVAHCS s offices. 2.2 The Contractor shall provide, transport, install, participate in the simulations, be available in live surgical cases and test the medical equipment prior to utilization. 2.3 All equipment and installation shall meet manufacturers and VA specifications. The Contractor shall ensure that Clinical Engineering inspect the equipment each time it enters the medical facility. 2.4 The Contractor shall furnish all supplies, accessories, equipment, consumables, transportation, delivery, training, and services. The Contractor shall use Right Fax to transmit the reports. 2.5 The Contractor is responsible for any missing parts and components to complete the requested service. 2.6 The Contractor shall be accredited and certified by The Joint Commission. 2.7 When required, the IONM will support Deep Brain Simulation and Transcranial Doppler cases. 2.8 The Contractor shall ensure that all professional staff have the necessary licenses and certifications. Must have CNIM Certified Surgical Neurophysiologists. 2.9 The Contractor shall provide the necessary personnel to service more than one surgical operation simultaneously. 3.0 REQUIREMENTS: a. The contractor shall coordinate provision of services with the Chief, Surgical Care Line, or designee. Contractor is responsible for provision of all equipment and supplies in support of the services it provides, including monitoring equipment, internet connection and VPN account. b. The contractor shall complete all administrative tasks, documentation of patient care and required medical transcription and signature within 24 hours of procedures. The contractor and their employees shall have a minimum of 5 years experience with IONMS Services. c. The contractor shall schedule emergency cases not later than 8 hours after receiving notification. Response time for urgent cases shall be between 8 hours and 24 hours. Response time for routine cases shall be between 24 hours, but not later than 72hours. d. Complications and/or incidents incurred during the administration of this contract will be reported within 24 hours of discovery to the COR and/or clinical designee and the contractor shall provide SAVAHCS with a complete copy of the medical records for review. This copy is to occur as close to the time of the adverse event as is practicable but NLT 48 hours. Also, contractor is to allow SAVAHCS access to patient records as requested by the SAVAHCS. e. The contractor agrees to be reimbursed for services in relation to current Medicare rates applicable to the appropriate CPT codes (listed in Schedule) under Medicare Locality Fee Schedule-Arizona Locality 01. f. The VA Medical Center, SAVAHCS shall establish and maintain a record keeping system that will record the hours worked by the contractor employee(s). Contractor's employee(s) shall report to Surgical Care Line's COR, Anna Malone, or designee upon arrival at the Southern Arizona VA Health Care System. 4.0 CREDENTIALING/PRIVILEGING: a. The contractor shall insure that all contract physicians are credentialed and privileged according to the Credentialing and Privileging process as described in VHA Handbook 1100.19 and local policy. No services will be provided by any contract physician prior to obtaining approval by the VA's Professional Standards Board, Medical Executive Board, and Facility Director. The contractor will be provided copies of current requirements and updates as they are published. b. The contractor shall allow a minimum of 90 calendar days for review of credentials by the SAVAHCS Professional Standards Board and the SAVAHCS Director or his/her designee. Period required for review of credentials shall be at no additional cost to the Government. c. Privileges will require renewal at least every two (2) years in accordance with Medical Center and Joint Commission requirements. d. Physicians assigned by the contractor to work at the SAVAHCS will be required to report specific patient outcome information, such as complications, to the Service Chief. Quality improvement data provided by the physicians and/or collected by the Service will be used to analyze individual practice patterns. The Service Chief will utilize the data to formulate recommendations for the Professional Standards Board to consider in the renewal of clinical privileges. 5.0 APPROVAL OF CONTRACTOR PERSONNEL: SAVAHCS reserves the right to refuse employment under this contract or require dismissal from contract work of any contractor employee or subcontractor employee who, by reason of previous unsatisfactory performance at the VA or for any other reasonable cause, is considered by the Contracting Officer to be objectionable, as long as thirty (30) days written notification of unsatisfactory performance has been provided to the contractor and the problem has not been cured in the thirty (30) day period. 6.0 KEY PERSONNEL AND TEMPORARY EMERGENCY SUBSTITUTIONS: The Contractor shall assign to this contract the following key personnel: a. During the first ninety (90) days of performance, the Contractor shall make NO substitutions of key personnel unless the substitution is necessitated by illness, death, or termination of employment. The Contractor shall notify the Contracting Officer, in writing, within 15 calendar days after the occurrence of any of these events and provide the information required by paragraph (c) below. After the initial 90-day period of the contract, the Contractor shall submit the information required by paragraph (c) to the Contracting Officer at least 15 days prior to making any permanent substitutions. b. The Contractor shall provide a detailed explanation of the circumstances necessitating the proposed substitutions, complete resumes for the proposed substitutes, and any additional information requested by the Contracting Officer. Proposed substitutes shall have comparable qualifications to those of the persons being replaced. The Contracting Officer will notify the Contractor within 15 calendar days after receipt of all required information of the decision on the proposed substitutes. The contract will be modified to reflect any approved changes of key personnel. c. For temporary substitutions where the key person will not be reporting to work for three (3) consecutive workdays or more, the Contractor will provide a qualified replacement for the key person. This substitute shall have comparable qualifications to the key person. Any period exceeding two weeks will require the procedure as stated above. 7.0 ARRANGEMENT FOR REPLACEMENT STAFF: The contractor shall provide scheduled services throughout the contract period. In the event of the absence of contractor's personnel for any reason, the contractor shall bear the responsibility of providing replacement personnel to provide the scheduled services. The replacement personnel must meet the Credentialing/Privileging requirements prior to providing care to SAVAHCS patients. 8.0 QUALITY MANAGEMENT AND ADHERENCE TO POLICIES: The contractor shall insure that contract technologists and physicians participate in continuous quality improvement programs in the organization as described in VHA Handbook 1100.19. In addition, the services to be performed by the contractor will be done so in accordance with VA policies and procedures, Joint Commission, federal and state laws, and the regulations of the medical staff by laws of the VA facility. This includes but is not limited to outcome measurements, access and levels of care, patient satisfaction, reporting of adverse events, and patient records. This data will be provided to the COR on a quarterly basis. 9.0 QUALITY ASSURANCE: a. The contractor shall maintain a Quality Assurance (QA) program under this contract and provide tracked and trended data to the Surgical Care Line s COR or designated POC, SAVAHCS, on a quarterly basis. This information will be shared with the Executive Committee of the Medical Staff (ECMS) when renewing the contract. b. Complications incurred during the administration of this contract will be reported within 24 hours of discovery to the Surgical Care Line s COR or designated POC. The contractor will provide SAVAHCS with a complete copy of the medical records should a complication or adverse event occur. c. It is anticipated that contracted services will provide the same level of oversight of quality and patient safety that SAVAHCS would provide if we were providing the service. This will be in compliance with quality of patient care contracts document that reviews Joint Commission standard and how SAVAHCS structures the contract to ensure compliance with the standard and our responsibility to ensure appropriate care. 10.0 PERFORMANCE MONITORING: The contractor will be monitored through a variety of mechanisms, including but not limited to: a. QA monitors to assess the quality of care provided by the contractor. b. Review of medical record documentation. c. The Contractor shall meet Joint Commission standards, as applicable. These performance standards may change during the course of the contract. Any new or revised quality/performance criteria or standards will be provided to the contractor before their implementation date and renegotiated into the contract as necessary. Attachment 1 contains the Performance Metrics that will be used to monitor the contractor. d. Monitoring of contractor s time shall be demonstrated through sign-in/ sign-out sheets. The contractor shall be required to sign an attendance log upon reporting to work and departing from work. The Contracting Officer s Representative (COR) is designed to be the Surgical Care Line s Administrative Officer. The COR shall be SAVAHCS s official responsible for verifying contract compliance. After contract award, any incidents of contractor noncompliance as evidenced by the monitoring procedures shall be forwarded immediately to the Contracting Officer. 11.0 EMPLOYMENT & LIABILITY: The contractor shall be responsible for protecting the personnel furnishing services under this contract. To carry out this responsibility, the contractor shall provide the following for these personnel who include worker s compensation, professional liability insurance, health examinations, income tax withholding and social security payments. The parties agree that Contractor personnel without formal VA appointments shall not be considered VA employees for any purpose and shall be considered employees of the contractor. 12.0 AUTOMATED DATA PROCESSING (ADP) SECURITY: If it becomes necessary, all contractor personnel accessing the Veterans Health Information and Technology architecture system will be required to sign and abide by all VA security policies and applicable confidentiality statues, 38 U.S.C., 5701, 7332, and the privacy act, 5U.S.C. 552a, as well as background check. 13.0 CONTRACTOR PERSONNEL SECURITY REQUIREMENTS: Per VA Directive 0710, all contractor employees and subcontract personnel requiring access to Department of Veterans Affairs' computer systems shall be subject to a background investigation and must receive a favorable adjudication from VA Office of Security and Law Enforcement. a. Position Sensitivity - Position sensitivity has been designated as Low Risk $231.00. b. Background Investigation - The level of background investigation commensurate with the required level of access is Minimum Background Investigation. c. Contractor Responsibilities: The contractor shall bear the expense of obtaining background investigations. If the investigation is conducted by the Office of Personnel Management (OPM), the contractor shall reimburse VA within 30 days. Contractor shall prescreen all personnel requiring access to the computer systems to ensure they maintain a U.S. citizenship, are able to read, write, speak, and understand the English language. The contractor shall submit the following information to the CO within 30 days of receipt of contract award: (i) Applicant s full name to include complete middle names (ii) SSN (iii) Date of birth (DOB) and place of birth to include city, state, country (iv) Occupation (v) Email address of company s POC to send results and resolve issues The contractor, when notified of an unfavorable determination by the Government, shall withdraw the employee from working under the contract. Failure to comply with personnel security requirements may result in termination of contract for default. d. Government Responsibilities: The VA Office of Security and Law Enforcement will provide the necessary forms to the contractor or to the contractor's employees after receiving the above information electronically at https://vaww.letc.little-rock.med.va.gov. Upon receipt, the VA Office of Security and Law Enforcement will review the completed forms for accuracy and forward the forms to OPM to conduct the background investigation. The VA facility will pay for investigations conducted by the Office of Personnel Management (OPM) in advance. In those instances, contractor will reimburse the VA facility within 30 days. The VA Office of Security and Law Enforcement will notify the contracting officer and contractor after adjudicating the results of the background investigations received from OPM. The contracting officer will ensure that the contractor provides evidence that investigations have been completed or are in the process of being requested. e. System Security: 1. If contractor is to have access to the VA computer system, the Contractor shall provide VHA with the full assurance that security measures have been implemented which are consistent with 0MB Circular A-l30 and VA Departmental Standards. Procedures for User Access: Access requirements to VA information systems by Contractors and Contractor personnel shall meet or exceed those requirements established for VHA employees as described in VA Directives (and others) and in any subsequent VISTA policy statements. A written and signed request for user access by VISTA Management, or designee(s), constitutes management approval (sponsorship) to initiate a request for access to any sensitive automated information system. Access shall be granted to non-VA users only if the purpose for access meets criteria of the Privacy Act and VA Confidentiality regulations and transfer. Contractor shall ensure that personnel providing services under this contract complete VHA required HIPAA and Cyber Security Awareness training prior to commencement of work and will be required to complete this training a minimum of 1 time per Fiscal Year. Training may be completed at http://www.vhaprivacytraining.net/frame.htm and https://www.ees-learning.net/librix/loginhtml.asp?v=librix respectively. Contractor personnel must complete this training and provide the certificates of completion with their completed User Access Request forms as a condition of being granted access, or continued access, to VA's computer systems. Copies of the Certificates of Completion must be provided to the Contracting Officer and Facility Information Security Officer annually."" 2. Contractor shall be required to sign and abide by the VA Computer Access Security Agreement and Confidentiality Agreement. 14.0 SECURITY REQUIREMENTS FOR CONTRACTOR EMPLOYEES: Contractor shall insure the confidentiality of all patient and employee information and shall be held liable in the event of breach of confidentiality. Any person, who knowingly or willingly discloses confidential information from the VA, may be subject to fines of up to $20,000.00. 1. Records: Contractor personnel who obtain access to hardware or media which may manipulate or store drug or alcohol abuse data, sickle cell anemia treatment records, records or tests or treatment for or infection with H1V, medical quality assurance records, or any other sensitive information protected under 38 U.S.C. §4132 or §3305, as defined by the Department of Veterans Affairs, shall not have access to the records unless absolutely necessary to perform their contractual duties. Any individual who has access to these data shall disclose them to no one, including other employees of the Contractor not involved in the performance of the particular contractual duty for which access was obtained. Violation of these statutory-provisions as stated in department regulations by the Contractor s employees may involve imposition of criminal penalties. 2. To ensure that individuals providing services under the contract have not engaged in fraud or abuse regarding Section 1128/A of the Social Security Act regarding federal health care programs, the contractor is required to check the Health and Human Services-Office of Inspector General (HHS/OIG), list of Excluded Individuals/Entities on the OIG website: www.hhs.gov/oig for each person providing services under this contract. Contractor is to certify that persons listed in contractor s proposal have been compared against the OIG list and are not listed. During the performance of this contract the contractor is prohibited from using any individual or business listed on the list of excluded Individuals/Entities. 15.0 COMPLIANCE WITH HIPAA: Department of Health and Human Services (DHHS), as mandated by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR parts 160 &164, subparts A, C, E; use and disclosure of protected health information requires the Government to enter into a Business Associate Agreement (BAA) with contractors who need access to protected health information and who do not meet any of the HIPAA exceptions. This requirement _ _does _X_ does not, meet the following exception and _X_does __ does not, require a BAA [ ] Health Care provider for treatment [ ] Health plan sponsor that provides health insurance benefits or coverage for the group health plan [ ] Health plan that is a public benefits program, such as Medicare or Social Security [ ] Health plan or health care provider for payment purposes [ ] Organization whose access to protected health information would be incidental (e.g. janitorial, postal, electrician, etc.) [ ] Organization Health Care Arrangement (OHCA) relating to joint health care activities of the OHCA [ ] A person or entity for research purposes; other {explain} 16.0 SAVAHCS RESPONSIBILITIES: The COR or designee is responsible for scheduling and coordinating with the contractor, and resolution of any operational and administrative issues. The COR will also conduct as necessary any post award discussion to review and resolve administrative issues and identify areas of concern for contract clarification. The COR is also the POC for the contractor to route issues and discussions through. Request for service will be issued via email, telephonic, or any other medium acceptable to both parties for requesting services. Any issues that rise above routine or become disputed must be forwarded to the CO. SAVAHCS is responsible for scheduling and coordinating with the contractor to establish a monitoring and evaluating procedure. Monitoring procedures will be established to ensure contractor compliance with established requirements. The COR will be responsible for global monitoring of contract compliance, and reporting any noncompliance as evidenced by the established monitoring procedures. Any serious incident of noncompliance or habitual unresolved situations as evidenced by the monitoring procedures shall be reported in writing to the CO for determination and resolution. 17.0 WORK HOURS: a. The services covered by this contract shall be furnished by the contractor as defined herein. The contractor will not be required, except in case of emergency, to furnish such services during off-duty hours as described below. b. The following terms have the following meanings: (1) Work hours: Monday through Friday, 7:00 a.m. - 6:00 p.m. (2) National Holidays: The 10 holidays observed by the Federal Government are: New Year s Day Martin Luther King s Birthday Presidents Day Memorial Day Independence Day Labor Day Columbus Day Veterans Day Thanksgiving Christmas (3) Off-Duty hours: Friday through Monday, 6:01 p.m. - 6:59 a.m. Attachment 1 Service Delivery Summary Task Performance Measures Acceptable Quality Level Method of Surveillance Action Authorization for Service Pre-approval 100% Observation and random inspection (auditing) of daily surgical reports by COR Non-payment for services performed without prior authorization. Contractor must coordinate with facility for scheduled surgical procedures within allotted time frame. Within 24 hours of receiving referral 100% Observation and Auditing. Provide to Contracting Officer. Review for determining Option Year Renewals. Complications incurred during the administration of this contract will be reported. Within 24 hours of discovery to the Surgical Care Line or designated POC 100% Observation and random inspection (auditing) of Quality Assurance Survey/Checklist (e.g. read/interpret accuracy, technical problems, equipment problems) completed by Neurosurgery staff and reported to COR Notification to Contracting Officer. Contractor will complete all administrative tasks, documentation of patient care and required medical transcription and signature. Within 24 hours of procedures 100 % Observation and random inspection (auditing) of Quality Assurance Survey/Checklist (e.g. read/interpret accuracy, technical problems, equipment problems) completed by Neurosurgery staff and reported to COR Provide to Contracting Officer. Review for determining Option Year Renewals. Contractor shall maintain a Quality Assurance program under this contract and provide tracked and trended data to the Surgical Care Line or designated POC, on a quarterly basis Quarterly Review 100 % Observation and random inspection (auditing) of Quality Assurance Survey/Checklist (e.g. read/interpret accuracy, technical problems, equipment problems) completed by Neurosurgery staff and reported to COR Provide to Contracting Officer. Review for determining Option Year Renewals. Contracted IONMS shall be licensed in the state of Arizona. Qualifications of personnel shall be subject for review by the SAVAHCS. Personnel assigned by the contractor to perform services covered by this contract shall meet all professional qualifications and be reviewable by the Department of Veterans Affairs. At all times 100 % At time of contract award and any time a new contracted employee starts. Remove and replace any contract personnel who are found to be unacceptable to VA. Contractor is to maintain the confidentiality of patient records in accordance with the Privacy Act, Title 5, U.S.C. 552a, Title 38 U.S.C. 5701, 5705, 7362; and the Health Insurance Portability and Accountability Act (HIPAA) under Public Law 104-191 Monthly 100 % Observation and random inspection (auditing) Notification to Contracting Officer of any breach in maintaining confidentiality
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- Place of Performance
- Address: Southern Arizona VA Health Care System (SAVAHCS) 3601 S. 6th Avenue Tucson, Arizona 85723
- Record
- SN05847619-F 20201107/201105230147 (samdaily.us)
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