Federal & VA Compliance: Risk Management Framework (RMF)

Overview

The “What Really Happened” (WRH) Master Curriculum is engineered to meet and exceed the rigorous compliance standards required for federal contracting, specifically within the Department of Veterans Affairs (VA) and Department of Defense (DoD). This section outlines the Risk Management Framework (RMF) and the Hardened Overlays applied to the curriculum to ensure safety, data integrity, and institutional reliability.

1.0 Hardened Overlays (Session 12 Integration)

Hardened overlays are specialized administrative and safety protocols layered onto the core curriculum to mitigate risk in high-activation environments. For Session 12 (Internal Behavioral Conflict Systems), the following overlays are mandatory:

Overlay ID	Name	Description	Compliance Link
HO-12.1	Somatic Redline Protocol	Immediate cessation of content if physiological activation exceeds baseline safety markers.	View Protocol
HO-12.2	Non-Clinical Boundary Guard	Explicit script markers preventing facilitators from drifting into clinical therapy territory.	View Script Notes
HO-12.3	VA Privacy & PII Shield	Hardened data handling procedures for participant “Parts Audit” reflections.	Privacy Policy

2.0 Federal Compliance Standards

Capitol Contracts LLC ensures that all curriculum delivery aligns with the following federal mandates:

2.1 VHA Directive 1030 Compliance

The WRH curriculum integrates the Three Lines of Model (3LM) for risk management, ensuring oversight at the facilitator, institutional, and federal levels.

Line 1: Facilitator self-audit and real-time regulation.
Line 2: Institutional oversight and compliance monitoring.
Line 3: Independent audit and federal reporting.

2.2 SAMHSA Trauma-Informed Care (TIC) Standards

Every session is audited against the six key principles of the SAMHSA TIC framework:

Safety
Trustworthiness and Transparency
Peer Support
Collaboration and Mutuality
Empowerment, Voice, and Choice
Cultural, Historical, and Gender Issues

3.0 Risk Mitigation & Safety Templates

To maintain the integrity of the “Hardened” status, facilitators must utilize the following standardized templates:

4.0 Institutional Identifiers

Unique Entity Identifier (UEI): HH77KN5AV5X7
Commercial and Government Entity (CAGE) Code: 9ZFJ6
NAICS Codes: 611710 (Educational Support Services), 541611 (Administrative Management and General Management Consulting Services)