Quality Assurance Surveillance Plan Final.pdf

US Department of Agriculture (USDA)

Quality Assurance Surveillance Plan

Contents Project Name Solicitation / Contract Number Section 1: Introduction

1.1 Purpose

1.2 QASP Relation to the Contract

1.2.1 QASP Revisions

1.2.2 Surveillance of Performance Progression

1.3 QASP Relation to the Quality Control Plan (QCP)

Section 2: Performance Description

2.1 Performance Standards and Acceptable Quality Levels (AQLs)

2.1.1 Allowable Deviation

2.1.2 Substantially Complete

2.2 Non-Performance

2.2.1 Documentation

2.2.2 Remedial Actions

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

3.2.2 Contracting Officer Representative (COR)

3.2.3 Customers

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods ................................................................................................................ Error! Bookmark not defined.

4.2 Analysis and Results .................................................................................................................. Error! Bookmark not defined.

Appendix A: Example Performance Requirement Summaries Appendix B: Example Discrepancy Report Appendix C: Customer Feedback Record Appendix D: Example Guide / Inspection List Appendix E: Example Quality Assurance Monitoring Appendix F: Example Customer Complaint Investigation Appendix G: Example Surveillance Activity Checklist

Project Name USFS Medical Qualifications for Wildland Firefighters

Solicitation / Contract Number 12318722R0002 / Contract Number

Section 1: Introduction This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS) entitled USFS Medical Qualifications for Wildland Firefighters The requirement to maintain minimum Interagency Wildland Firefighter Medical Standards is a condition of employment and critical to performing the full range of essential arduous duties and responsibilities safely and efficiently. This plan sets forth the procedures and guidelines that the USDA, Forest Service eMedical will use in ensuring the required performance standards or services levels are achieved by the contractor.

1.1 Purpose

The purpose of the QASP is to describe the systematic methods used to measure performance and to identify the reports required and the resources to be employed. The QASP provides a means for evaluating whether the contractor is meeting the performance standards identified in the PWS. This QASP is designed to define roles and responsibilities, identify the performance objectives, define the methodologies used to monitor and evaluate the contractor’s performance, describe quality assurance reporting, and describe the analysis of quality assurance monitoring results.

1.2 QASP Relation to the Contract

1.2.1 QASP Revisions

The Contracting Officer Representative (COR) may make revisions or changes to the QASP procedures and surveillance methods or increase or decrease the degree of surveillance methods at any time during the contract performance period. Changes to the Metric must be incorporated into the PWS, Performance Requirement Summary (PRS) and QASP by a bilateral modification to contract that is issued by the Contracting Officer (CO). A copy of the QASP is provided to the contractor to enable the contractor to enhance its Quality Control (QC) program to perform in accordance with its Quality Control Plan (QCP).

1.2.2 Surveillance of Performance Progression

As the performance period progresses, the levels of surveillance may be altered for service areas where performance is either consistently excellent or unsatisfactory. If consistently good performance, then the amount of surveillance may be reduced. If observations reveal consistent deficiencies, increased surveillance may be implemented.

1.3 QASP Relation to the Quality Control Plan (QCP)

The QCP is a required element of contract and the Contractor shall adhere to its established quality control processes and procedures in managing and performing work as described in the contract. While the QCP represents the way in which the Contractor will ensure its quality and timeliness of services, as defined in the PWS, the QASP represents the way in which the Government personnel specified in Section 3: Contractor and Government Responsibilities, Paragraph 3.2, Government Responsibilities will evaluate the contractor’s performance. The contractor’s QC program and the residual organization’s QASP should be complementary programs that ensure successful contractor performance.

Section 2: Performance Description Performance of the contractor will be monitored through the surveillance methods described in Section 4: Surveillance Methods to Perform Quality Assurance to assess the Contractor’s performance against PWS requirements.

2.1 Performance Standards and Acceptable Quality Levels (AQLs) For selected activities in the PWS, the PRS provides a performance standard and an AQL. A performance standard is the expected level of contractor performance. An AQL defines the level of performance that is satisfactory. Depending on the service evaluated and the evaluation method selected, performance standards and AQLs may be stated as a number of occurrences or as a percentage. Performance standards and AQLs for random sampling and 100 percent inspection are generally stated as percentages. For periodic inspections, performance standards may be stated as either percentages or as absolute numbers.

The contract requires the Contractor to perform all work as specified. Any inaccuracies or omissions in services or products are referred to as “defects” on the part of the Contractor. The Contractor shall be responsible for all identified defects and may be required to perform the work at no cost to the government. The AQLs take into account that in some instances an allowable level of deficiencies (deviations) is possible while overall performance continues to meet the government’s desired level of service.

2.1.1 Allowable Deviation

The AQLs define the level or number of performance deficiencies the Contractor is permitted to reach under this contract. AQLs take into account the difference between an occasional defect and a gross number of defects. AQLs can be expressed as a percentage of or as an absolute number (e.g., three per month). There may be instances where 100 percent compliance is required, and no deviation is acceptable (e.g., where safety is involved).

2.1.2 Substantially Complete

In some cases, service outputs are evaluated using subjective values (e.g., excellent, satisfactory, unsatisfactory). The criteria for acceptable performance and for defects must be defined for these service outputs. The concept of “substantially complete” should be the basis for inspections based on subjective scales. Work is considered “substantially complete” where there has been no significant departure from the terms of the contract and no omission of essential work. In addition, the Contractor has performed the work required to the best of its ability and the only variance consists of minor omissions or deficiencies.

2.2 Non-Performance

Non-performance occurs when the contractor’s performance does not meet the AQL for a given requirement.

Requirements may contain multiple performance elements, and therefore, deficiencies may occur in one or more aspects of performance (e.g., timeliness, accuracy, completeness, etc.) or subject areas of effort.

When surveillance indicates that the contractor's service output is not in compliance with the contract requirements, the Contracting Officer’s Representative (COR) must determine whether the Contractor or the Government caused the deficiency. If the cause of the defect rests with the Government, corrective action must be taken through Government channels. If the cause of the defect is due to action or inaction by the contractor, the contractor is responsible for correction of the problem at no additional expense to the Government.

2.2.1 Documentation

Documentation of work non-performed or unacceptable work is essential for tracking Contractor performance. The COR will document deficient work by compiling facts describing the inspection methods and results and to substantiate nonconformance with the contract. Documentation reporting forms are provided in Appendices. The documentation, with any recommendations, will be forwarded to the CO. In the case of the Contractor, the COR will decide whether to elevate the problem to the CO for corrective action.

2.2.2 Remedial Actions

The Federal Acquisition Regulation allows for penalties in the event that the Contractor fails to perform the required services. Penalties are defined as those actions taken under the direction of the CO against the contractor within the general provisions of the contract for nonconformance to the PWS and PRS.

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

The Contractor is responsible for delivering products or services in accordance with the contract. Implementing its QCP, which describes the Contractor’s methods for ensuring all products and services under the contract meet established performance standards and AQLs. Maintaining, and providing for audit, quality control records and reports and all records associated with the investigation and complaint resolutions. Appointing a single quality control point-of-contact to act as a central recipient of communication from the COR or CO.

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

The CO is responsible for administering and monitoring contract compliance, contract administration, and cost control and for resolving any differences between the observations documented by COR and the contractor’s performance. The CO may delegate various day-to-day contract administration duties to an Administering ACO (ACO) and/or the COR for performance management and administrative actions such as invoice approval and issuance of Contract Discrepancy Reports may be, and normally are, delegated by the CO to the COR. The CO shall approve any revisions to the QASP processes or standards.

3.2.2 Contracting Officer Representative (COR)

The COR, is designated in writing, by the CO. The COR will ensure that the QA function is properly executed, plays a key role in contract administration and performs the contract surveillance and monitoring. Some key contract administration duties include, but are not limited to, performs surveillance as required by this QASP; make recommendations to the CO for issuance of Contract Discrepancy Reports or letters of commendation and acceptance or rejection of completed work and for administrative actions based on unsatisfactory or non-performed work, and revisions or changes to the QASP;

and assists the CO in identifying necessary contract modifications and preparing reports of Contractor performance and cost.

The COR may use the form(s) included in the Appendices to perform the inspection or other forms as approved by the CO. The Contractor overall guidance is also provided by FAR clause 52-212-2 of the contract.

3.2.3 Customers

Insert this Section if applicable Customers or organizations/offices that the Contractor provided support may be requested to assist the COR in conducting QA to provide information relating to the Contractor’s performance through Customer Feedback.

Information gained from the Customer Feedback may be used in conjunction with other methods of observation to rate the performance of the Contractor.

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods

The surveillance methods used in the QA process are the Government’s tools to monitor the Contractor’s products and services. The best means of determining whether the Contractor has met all contract requirements is to inspect the Contractor’s service products and analyze the results. Further, documented inspection results are an effective tool in contract administration that can confirm the successful achievement of all performance requirements or highlight areas where defects exist and improvements are necessary.

• 100% Inspection

• Periodic Inspection

• Customer Survey

• Customer/COR/GTM Feedback. The following procedures will be followed when a complaint is received regarding the Contractor/Contractor Employees.

o The COR/GTM will investigate and determine the validity of the complaint.

o If the complaint is determined to be invalid, the COR/GTM will inform the person who submitted the complaint of the reason(s) as soon as practical.

o For validated complaints that are true contractual non-conformances, the procedures in paragraph 4.2 below will be followed.

4.2 Performance Assessment

Anyone observing unacceptable services, either incomplete or not performed, should immediately contact the COR/GTM by telephone or email. The COR/GTM will document and validate the customer complaint, then notify the contractor. The CONTRACTOR will review and take immediate corrective action for all valid complaints.

If the COR/GTM identifies recurring instances of unsatisfactory performance, they may request to review the contractor internal quality control processes to ensure they are sufficient.

All valid customer complaints shall be corrected if applicable, as soon as possible after notification, but within the time frame identified in the Service Summary (SS). If the contractor challenges the validity of the complaint and the COR/GTM and contractor cannot come to agreement, the customer complaint will be forwarded to the CO for resolution.

Customer complaints will be tracked and if the performance threshold is exceeded, action will be taken in accordance with the applicable Inspection/Acceptance and/or Remedies for Unacceptable Performance clauses.

Customer Surveys may be distributed periodically to assess customer satisfaction with contractor performance.

When the inspections and customer feedback validations have been completed, the COR/GTM will perform an analysis of the Contractor’s performance. The purpose of the analysis is to ensure Government is receiving high-quality services from the Contractor. The COR/GTM will review the results, rate the Contractor’s compliance with the performance standards and AQLs, and characterize the Contractor’s overall performance. Analysis of all types of contract monitoring will result in one of the following outcomes: acceptance, re-performance, discrepancy report, and/or negative CPARS rating.

4.2.1 Outstanding Performance

Outstanding performance is the result of the Contractor substantially exceeding the performance standards with significant achievements and no significant deficiencies. The Government may reduce its level of surveillance when the COR/GTM determines that the Contractor provides sustained performance that significantly exceeds the requirements with no significant deficiencies.

4.2.2 Unacceptable Performance

When the contractor’s performance is deemed unacceptable, COR/GTM will determine the cause of the unacceptable performance. If any government action, or lack of action, caused or contributed to the unacceptable performance, the unacceptable performance will not be counted against the contractor. The COR/GTM will take action to ensure government action, or lack of action, does not interfere with the contractor’s performance in the future.

When the unacceptable performance is not the result of government action, or lack of action, COR/GTM will promptly notify the contractor and issue a discrepancy report to the contractor to assure corrective action is taken. By initialing and dating the assessment, the contractor representative is only acknowledging receipt of the finding of the unacceptable performance and is not agreeing or disagreeing with the performance assessment.

The COR/GTM, with CO approval, will direct the contractor to re-perform the service, if possible, without additional cost to the government. If the contractor challenges the validity of the COR/GTM’s unacceptable assessment finding, and the COR/GTM and contractor cannot come to an agreement, the matter shall be referred to the CO for resolution. The contractor shall be required to return all completed assessments to the COR/GTM no later than the suspense date indicated on the assessment. Unacceptable performance re-performed satisfactorily by the contractor shall still count as unacceptable performance.

The COR/GTM shall maintain a log of all assessments issued to the contractor (a locally devised form may be used). The log must contain the assessment number, date issued, contractor, description of unacceptable performance, suspense date, and closeout date. All assessments and logs must be maintained by the COR/GTM for the life of the contract.

4.2.3 Remedies for Unacceptable Performance

In accordance with the contract Inspection of Services clause, if any of the services do not conform to contract requirements; the government may require the contractor to perform the services again in conformity with contract requirements, at no increase in contract amount. This includes but is not limited to termination of contractor personnel and recruitment of substitute personnel equally qualified within established timeframes. When the defects in services cannot be corrected by re-performance, the government may:

• Require the contractor to take necessary action to ensure future performance conforms to contract requirements;

• Reduce the contract price to reflect the reduced value of the services performed.

If the contractor fails to promptly perform the services again or to take the necessary action to ensure future performance in conformity with contract requirements, the government may:

• By contract or otherwise, perform the services and charge to the contractor any cost incurred by the Government that is directly related to the performance of such service; or

• decrement invoice as stated in the PWS related to performance; or

• Terminate the contract for cause.

Appendix A: Performance Requirement Summaries The following documents are examples only, which is not all inclusive, that can be revised and used, if applicable, in the QASP as attachments or exhibits.

EXAMPLE- 1

PERFORMANCE REQUIREMENT SUMMARY

Performance Task (PWS Reference)

Performance

Indicator

Standard

Acceptable Quality

Level (AQL)

Method of Surveillance

Timeliness and Accuracy of Delivery-Supplies/ Services (PWS, Section 6.6.4)

Supplies/Services delivered as ordered – Quantity / Quality

Delivery matches Order quantity and Supplies/ Services description

95% of all deliveries match order quantity and supplies / services

Inspection of Monthly Sales and Delivery Report.

PWS

Task Required

Services Performance Standard Acceptable Quality

Level Monitoring Method

Phase In Period

Contractor PM and Alternate completes requirements and obtain GFP laptop

100%, Notify COR with instances of delays or miscommunications in processing personnel.

CO or designee observation

Project Plan

Select, recruit, orient, monitor, maintain, and pay quality Medical Providers.

Adherence to Timeline

Validated COR/GTM feedback

Validated customer feedback

Alternate Plan

Alternate plan for providing exams and medical services to locations where MP’s are not found within 50 road miles radius.

Adherence to timeline of plan implementation outlined below and in

PWS

90% of locations outside of 50 mile road radius will have medical exams and services provided

Status update and complete list of MP’s that are recruited, trained and available to implement plan in Regions 8, 9, 10 and smokejumper bases(reference Attachment C). Provide complete list of MP’s to COR by DATE:

7/15/22-OR- 2 weeks prior to

95% of coverage area/identified stations will have designated MP’s recruited, trained, and ready to perform exams

CO/ GTM observations and review of deliverables implementation of AMP in those regions, whichever occurs later.

Status update and complete list of MP’s that are recruited, trained and available to implement plan in Region 6 (reference Attachment C).

Provide complete list of MP’s to COR by DATE

December 15, 2022 -OR- 2 weeks prior to implementation of AMP in region 6, whichever occurs later.

95% of coverage area/identified stations will have designated MP’s recruited, trained, and ready to perform exams

CO/ GTM observations and are recruited, trained and available to implement plan in Region 5 (reference Attachment C).

Provide complete list of MP’s to COR by DATE.

July 15, 2023

-OR-

2 weeks prior to implementation of AMP in region 5, whichever occurs later.

will have designated MP’s recruited, trained, and ready to perform exams are recruited, trained and available to implement plan in Regions 1 and 3 (reference Attachment C).

Provide complete list of MP’s to COR by DATE.

December 15, 2023

-OR-

2 weeks prior to implementation of AMP in regions 1 and 3, whichever will have designated MP’s recruited, trained, and ready to perform exams are recruited, trained and available to implement plan in Regions 2 and 4 (reference Attachment C).

Provide complete list of MP’s to COR by DATE.

December 15, 2024

-OR-

2 weeks prior to implementation of AMP in regions 2 and 4, whichever area//identified stations will have designated MP’s recruited, trained, and ready to perform exams

Support to MP’s for all scheduling, payment, tracking, and medical record training and access issues Responsive to MP’s for access-related issues

No more than 25 complaints per quarter

Assist USFS Wildland fire personnel in scheduling exams with pre-identified MP’s within 5 business days of examinee request

No more than 25 complaints per quarter

Project COR/ GTM observations and review of deliverables

COR validate customer complaints

Track all exams, completed and missed.

All activities are in accordance with PWS guidance

Project COR/ GTM observations and review of deliverables

COR validate customer complaints

Ensure MP’s complete all components of the requested examination type and any ancillary, as-needed services ordered

90% of MP’s under contract will perform and input exam

Statistical random sampling by

COR

Ensure MP’s accurately input exam results into eMedical system and submit to MQP for review by RMO’s

No more than 25 missing or late exam results input per quarter

Validated Customer Complaints

Provide timely payment to the exam provider, invoice the government for all medical exam services scheduled under this contract and ensure no personal insurance information or payment is collected from examinees scheduled under this contract. Any unauthorized billing of examinees will be resolved within seven (7) business days of notification

No more than 25 complaints per quarter

Validated Customer Complaints

Monthly Status Reports

Report documenting tasks, updates & issues, and actual workload data monthly.

Includes number of exams scheduled, completed, missed, etc.

Monthly, last Friday of each month, by 3:00 PM EDST until the contract expires beginning August 1, 2022

Project COR/ GTM observations and review of deliverables

Evaluation Meetings

Performance of service will be evaluated using QASP to determine whether or not it meets the performance requirements of the contract

Quarterly, as schedule by

COR

Task Tracking Management System

Access to system to update on timelines, workflow status, action items, etc.

As requested by COR, within 3 business days of request

Ad Hoc Reports i.e trending systemic problems with eMedical, repeated non-compliance with one or more MP, etc) estimated at 4 reports annually

As requested by COR, Within 10 business days of request

Transition Plan, end of contract period

Identify and outline a plan for phasing and transitioning services and information back to the Government.

Includes return of all Government furnished property and equipment.

6 months prior to the end of the contract

Quality Control Plan

Includes the monitoring, measuring, and evaluating of quality while services are ongoing to assure performance standards and adequate oversight of MP’s are met.

10 business days after notification of award

Quality Control Plan

Appendix B: Discrepancy Report FOR CO/COR Use (GTM utilize Appendix H, Performance Assessment Report).

DISCREPANCY REPORT 1. DISCREPENCY REPORT NO.

2. TO: (Contractor / Project Manager Name) 3. FROM: (Name of COR)

CONTRACT NUMBER: DATE:

PREPARED ORAL NOTIFICATION RETURNED BY CONTRACTOR ACTION COMPLETE

4. DISCREPENCY OR PROBLEM (Describe in Detail. Include PWS references. Attach Continuation Sheet if Necessary)

5. SIGNATURE OF COR

6. TO: (Name of COR) 7. FROM: (Contractor / Project Manager)

8. CONTRACTOR RESPONSE AS TO CAUSE, EFFECT, CORRECTIVE ACTION AND ACTIONS TO PREVENT RECURRENCE (Attach Continuation Sheet if necessary. Cite applicable Contractor QC program procedures or new QC procedures)

9. SIGNATURE OF CONTRACTOR REPRESENTIVE 10. DATE

11. GOVERNMENT EVALUATION (Acceptance, partial acceptance, or rejection. Attach Coordination Sheet if necessary)

12. GOVERNMENT ACTIONS (Cure notice, show cause, other)

CLOSE OUT

KTR NOTIFIED

NAME AND TITLE SIGNATURE DATE

COR

Appendix C: Customer Feedback Record

CUSTOMER FEEDBACK RECORD

DATE AND TIME OF COMPLAINT CONTRACT NUMBER/ OR PROJECT:

SOURCE OF COMPLAINT

ORGANIZATION

INDIVIDUAL

NATURE OF COMPLAINT

PWS REFERENCE

VALIDATION

DATE AND TIME CONTRACTOR INFORMED OF COMPLAINT NAME OF CONTRACTOR REPRESENTATIVE INFORMED OF COMPLAINT

ACTION TAKEN BY CONTRACTOR (Responsible officer):

RECEIVED AND VALIDATED BY

Determination: Complaint Valid Complaint Invalid

Appendix D: Inspection List

CONTRACT NUMBER: ___________________________________

SERVICE FUNCTION:

PWS SECTION:

1 Method of Surveillance:

2 Lot Size:

3 Sample Size:

4 Performance Requirement: Performance is Excellent (E) when ___________or fewer defects are discovered per month. Performance is Satisfactory (S) when ________ or fewer defects are discovered per month. Performance is Unsatisfactory (U) when _______ or more defects are discovered per month.

5 Sampling Procedure: Instructions on how to select the sample must be clear and complete

6 Inspection Procedure: The procedure must be detailed enough to allow a yes/no objective decision as to the acceptability of performance by anyone making the inspection. Explain when evaluation is to occur and what is acceptable/unacceptable

Performance: Excellent (E), Satisfactory (S), Unsatisfactory (U), Not Applicable (N/A)

PRS Requirements Timeliness Quality of Work Notes

Overall Rating Of Inspection (E, S, U or N/A)

COR/Inspector Comments:

Contractor Signature: ___ Date: __

COR Signature: ____________________Date: _________________

Appendix E: Quality Assurance Monitoring

CONTRACT NUMBER: ______________________________________

SERVICE or STANDARD:

SURVEY PERIOD:

SURVEILLANCE METHOD (Check the applicable item):

Random Sampling 100% Inspection Periodic Inspection Customer Complaint

LEVEL OF SURVEILLANCE (Check the applicable item):

Monthly Quarterly As needed

PERCENTAGE OF ITEMS SAMPLED DURING SURVEY PERIOD: ______ %

ANALYSIS OF RESULTS:

Observed Service Provider Performance Measurement Rate: ______%

Service Provider’s Performance (Check the applicable item):

Meets Standards

Does Not Meet Standards

Narrative of Performance During Survey Period:

Prepared By: _______________________________ Date: ______________

Appendix F: Customer Complaint Investigation

CONTRACT NUMBER: _________________________

SERVICE or STANDARD:

SURVEY PERIOD: ___________________

DATE COMPLAINT RECEIVED: ____________

SOURCE OF COMPLAINT: _________________________________________ (Name) _______________________________________________________________ (Organization) ___________________ (Phone No.) _________________________________ (Email Address)

NATURE OF COMPLAINT:

RESULTS OF COMPLAINT INVESTIGATION:

DATE SERVICE PROVIDER INFORMED OF COMPLAINT: _____________

CORRECTIVE ACTION TAKEN BY SERVICE PROVIDER:

Received and Validated By: __________________________________________ Prepared By: _____________________________ Date: _________________

Appendix G: Surveillance Activity Checklist

Requirement

Performance Standard

Method of Measurement

Metrics

Method of Surveillance

Date Accomplished

Compliance (Exceed, Met, Partial Met)

PERFORMANCE ASSESSMENT REPORT (PAR)

(If more space is needed, use additional pages and identify by number)

1. CONTRACT/TASK ORDER

NUMBER

2. CONTRACTOR 3. TYPE OF SERVICES

4. GOVERNMENT TECHNICAL REP. SIGNATURE AND DATE 5. GTM PHONE 6. SUSPENSE DATE

I. PERFORMANCE

7. [ ] DEFICIENCY (CHECK ALL BOXES THAT APPLY)

[ ] NEW

[ ] REPEAT

[ ] NO DEFICIENCY NOTED

8. SERVICES SUMMARY (SURVEILLANCE MATRIX/PRS) or

PWS PARAGRAPH ITEM REVIEWED

9. BRIEF DESCRIPTION OF DEFICIENCY (IF DEFICIENCY BOX

WAS CHECKED)

10. DETAILED PERFORMANCE ASSESSMENT

II. CONTRACTOR VALIDATION

11. CONTRACTOR REPRESENTATIVE

[ ] CONCUR [ ] NON-CONCUR 12. CORRECTIVE ACTION ESTIMATED COMPLETION DATE

13. CONTRACTOR REPRESENTATIVE CORRECTIVE ACTION AND PREVENTION OF RECURRENCE OR REASON FOR NON-

CONCURRENCE OF GTM CITED DEFICIENCY

III. ACTION CORRECTED

14. [ ] CONCUR [ ] NON-CONCUR GTM SIGNATURE AND DATE

15. GTM REMARKS (REQUIRED)

16. CONTRACTOR REPRESENTATIVE REMARKS