Attachment 5 - QASP V2.pdf

QUALITY ASSURANCE SURVEILLANCE PLAN

for

Fitness for Duty Examinations

Human Resources Division (HRD)

TABLE OF CONTENTS

1 INTRODUCTION

1.1 Purpose

1.2 Performance Management Approach

1.3 Performance Management Strategy

2 ROLES AND RESPONSIBILITIES

2.1 The Contracting Officer

2.2 The Contracting Officer’s Technical Representative

3 IDENTIFICATION OF REQUIRED PERFORMANCE STANDARDS / QUALITY

LEVELS

4 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 Surveillance Techniques ............. ……………………………………………………….3

4.2 Customer Feedback ......................................................................... ……………….3

4.3 Acceptable Quality Levels

5 QUALITY ASSURANCE DOCUMENTATION

5.1 The Performance Management Feedback Loop

5.2 Monitoring Forms

6 ANALYSIS OF QUALITY ASSURANCE ASSESSMENT

6.1 Determining Performance

6.2 Reporting

6.3 Reviews and Resolution

ATTACHMENT 1: PERFORMANCE REQUIREMENTS SUMMARY

ATTACHMENT 2: SAMPLE QA MONITORING FORM

ATTACHMENT 3: SAMPLE QA CUSTOMER COMPLAINT FORM.………………………11

QUALITY ASSURANCE SURVIELANCE PLAN

1 INTRODUCTION

The Government seeks to ensure that this Quality Assurance Surveillance Plan (QASP) is responsive to properly assess contract performance pursuant to the requirements stipulated in the Statement of Work (SOW) entitled Fitness for Duty Examinations for the Human Resources Division (HRD) at FBI Headquarters (HQ). This plan sets forth the procedures and guidelines the FBI will use in ensuring the required performance standards or acceptable quality levels (AQLs) are achieved by the Contractor.

1.1 Purpose

The purpose of this QASP is to describe the systematic methods used to monitor Contractor performance and to identify the required surveillance documentation and the Government resources to be employed. This QASP provides the primary means for evaluating whether the Contractor is meeting the AQLs identified in the SOW and that the Contractor is in compliance with its Quality Control Plan (QCP).

This QASP defines the roles and responsibilities of all members of the Government’s integrated project team (IPT), identifies the performance objectives, defines the methodologies used to monitor and evaluate the Contractor’s performance, describes the Government’s quality assurance (QA) documentation requirements, and describes the analysis of QA monitoring results.

1.2 Performance Management Approach

The SOW structures the acquisition around “what” AQLs the Contractor is required to attain. This QASP defines the performance management approach taken by the FBI to monitor and manage the Contractor’s performance to ensure the expected outcomes or performance objectives communicated in the SOW are achieved. Performance management rests on developing a capability to review and analyze information generated through performance assessment. The ability to make decisions based on the analysis of performance data is the cornerstone of performance management; this analysis yields information that indicates whether expected outcomes for the project are being achieved by the contractor.

Performance management represents a significant shift from the more traditional quality assurance (QA) concepts in several ways. Performance management focuses on assessing whether outcomes are being achieved in accordance with (IAW) safety practices, local / federal codes, and to what extent. This approach somewhat migrates away from scrutiny of compliance with the processes and practices used to achieve the outcome. A performance -based approach enables the Contractor to play a large role in how the work is performed, as long as the proposed processes are within the stated constraints. The only exceptions to process reviews are those required by law (Federal, state, and local) and compelling business situations, such as safety and health. The “results” focus provides the Contractor with flexibility to continuously improve and innovate over the course of the contract as long as the critical outcomes expected are being achieved and / or the desired performance levels are being met.

1.3 Performance Management Strategy

The Contractor is responsible for the quality of all work performed. The Contractor measures that quality through its own QCP. QC is work output, not workers, and therefore includes all work performed under this contract regardless of whether the work is performed by Contractor employees or by subcontractors. The Contractor’s QCP will set forth the staffing and procedures for self - inspecting the quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the SOW.

The Contractor shall develop and implement a performance management system with processes to assess and report its performance to the designated Government surveillance representative. The Contractor’s QCP will set forth its staffing methodology and its procedures for self - inspecting the quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the SOW as identified in QASP Attachment 1, “Performance Requirements Summary”. Importantly, this QASP enables the Government to take advantage of the Contractor’s QCP.

Government representative(s) will monitor performance and review the Contractor’s Monthly Status Reports (MSRs) to determine how it is performing against communicated performance objectives. The Contractor shall be responsible for making required changes in processes and practices to ensure performance is managed effectively.

2 ROLES AND RESPONSIBILITIES

2.1 The Contracting Officer

The Contracting Officer (CO) is responsible for monitoring contract compliance, contract administration, cost control, and resolving any differences between the observations documented by the Government’s quality assurance evaluator -- the Contracting Officer's Representative (COR). The CO will designate a full - time COR at contract award as the Government authority for performance management. The number of additional representatives serving as technical inspectors depends on the complexity of the services measured, as well as the Contractor’s performance, and will be identified and designated as necessary by the CO.

2.2 The Contracting Officer’s Representative

The COR will be designated in writing by the CO to act as his / her authorized representative to assist in administering a contract. COR limitations are contained in the written appointment letter, a copy of which will be provided to the Contractor. Overall, the letter will convey that the COR is responsible for technical administration of the project and ensures proper Government surveillance of the Contractor’s performance. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government’s behalf. Any changes that the Contractor deems may affect contract price, terms, or conditions shall be referred to the CO for action. The COR will have the responsibility for completing QA monitoring forms used to document the inspection and evaluation of the Contractor’s work performance. Government surveillance may occur under the inspection of services clause for any service relating to the contract.

3 IDENTIFICATION OF REQUIRED PERFORMANCE STANDARDS / QUALITY

LEVELS

The required performance standards and / or AQLs are identified in QASP Attachment 1, the PRS, which is included as part of the SOW. Failure to meet the required AQLs may constitute grounds for Termination for Default of the contract.

4 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 Surveillance

The Government will monitor Contractor achievement of the AQLs via 100% inspection as stipulated in the PRS.

4.2 Analysis and Reporting of Surveillance Results

The COR will inspect the services rendered based on the performance standards outlined within the SOW and QASP / PRS. All tasks that are considered to have unacceptable performance shall be substantiated and documented on the Contractor Discrepancy Report (CDR) or equivalent. The form will be completed and submitted to the Contractor within twenty – four (24) hours following the inspection. The Contractor shall return the CDR form or equivalent identifying the corrective action taken within the time allotted by the COR.

At the end of each quarter, the COR will summarize the overall results of the Contractor’s performance for the previous month and issue the report to the CO. If appropriate, the CO may investigate the findings further to determine if all facts and circumstances surrounding the findings are accurate. The CO may discuss the findings or a trend in findings that indicate unacceptable performance with the Contractor.

4.3 Customer Feedback

All concerns communicated to the COR regarding Contractor performance will be documented and evaluated on a planned schedule developed by the COR. This method may help the COR focus on areas that may require further action from the CO.

Performance management shall drive the Contractor to be customer focused through initially and internally addressing customer complaints and investigating all identified issues.

4.4 Acceptable Quality Levels

The AQLs included in the PRS are structured to allow the contractor to manage how the work is performed. For most requirements, the AQL is ninety – eight (98) percent compliance.

5 QUALITY ASSURANCE DOCUMENTATION

5.1 The Performance Management Feedback Loop

The performance management feedback loop begins with the communication of expected outcomes. Performance standards are expressed in the SOW and are assessed using the performance monitoring techniques identified in the PRS.

5.2 Monitoring Forms

The Government’s QA surveillance, accomplished by the COR will be reported using the QA Monitoring Forms in Attachments 2 and 3. The forms, when completed, will document the Government’s assessment of the Contractor’s performance under the contract to ensure that the required results are being achieved IAW Attachment 1.

5.2.1 The COR will retain a copy of all completed QA Monitoring Forms.

6 ANALYSIS OF QUALITY ASSURANCE ASSESSMENT

6.1 Determining Performance

Government shall use the monitoring methods cited to determine whether the performance AQLs have been met. If the Contractor has not met the minimum requirements, it will be asked to develop a Corrective Action Plan (CAP) to show how and by what date it intends to bring performance up to the required levels.

6.2 Reporting

At the end of each quarter, the COR will prepare a written report summarizing the overall results of the quality assurance surveillance of the Contractor’s performance. This written report, which includes the Contractor’s MSRs for that quarter and the completed QA Monitoring Forms will become part of the QA documentation. It will enable the Government to document whether the Contractor is meeting the AQLs.

6.3 Reviews and Resolution

The COR may require the Contractor to meet with the CO, the COR, the Government PM and other Government IPT personnel as deemed necessary to discuss performance evaluation. The CO, COR, and / or Government PM will define a frequency of in - depth reviews with the Contractor, including appropriate self - assessments by the Contractor;

however, if the need arises, the Contractor shall meet with the CO and / or COR as often as required or per the Contractor’s request. The agenda of the reviews may include:

• Monthly performance assessment data and trend analysis

• Issues and concerns of both parties

• Projected outlook for upcoming months and progress against expected trends, including a corrective action plan analysis

• Recommendations for improved efficiency and / or effectiveness

• Issues arising from the performance monitoring processes

The COR will coordinate and communicate with the Contractor to resolve issues and concerns regarding marginal or unacceptable performance.

The COR, CO and the Contractor should jointly formulate tactical and long - term courses of action. Decisions regarding changes to metrics, thresholds, or service levels should be clearly documented. Changes to AQLs, procedures, and metrics will be incorporated as a contract modification as deemed appropriate by the CO.

ATTACHMENT 1: PERFORMANCE REQUIREMENTS SUMMARY

Desired Outcomes (What do we want to accomplish as the end result of this contract?)

Required Service (What task must be accomplished to give us the desired result?)

Performance Standard (What should be the completeness, reliability, accuracy, timeliness, quality and / or cost be?)

Acceptable Quality Level

(AQL)

(How much error will we accept?)

Monitoring Method (How will we determine that success has been achieved?)

1) Successful contact of Applicant (Pre- Employment) /Employee (Periodic) for examinations by the applicable examining office within forty-eight

(48) hours of work order receipt.

a) Directly contact Applicant/Employee by phone to schedule examination within the required timeframe as stated below.

b) Inform the appropriate FBI POC of any unsuccessful direct contact efforts.

Applicant assessments are scheduled as required.

98% of scheduled assessments meet all stated requirements.

Survey Applicant coordinators and evaluate feedback. (trend analysis)

2) Successful scheduling of Official Foreign Travel Reviews, including DoS examinations within ten

(10) business days of work order receipt

a) Schedule an examination appointment with the Applicant/Employee within forty-eight (48) hours of notification and agree upon an appointment date that is within ten (10) business days of the notification.

b) Inform the appropriate FBI POC of any cancellations or no -shows via e-mail within one

(1) business day.

c) Ensure that every examination is conducted by the appropriate level provider and all documentation has been completed in entirety.

Applicant aAssessments are scheduled as required.

98% of scheduled assessments meet all stated requirements.

Survey Applicant coordinators and evaluate feedback. (trend analysis)

d) Provide the Applicant or employee with clear instructions and directions to the examination site.

3) Successful scheduling of Applicant (Pre-Employment) Medical Assessments within fifteen (15) business days of work order receipt

a) Schedule an examination appointment with the Applicant/Employee within forty-eight (48) hours of notification and agree upon an appointment date that is within fifteen (15) business days of the notification.

b) Inform the appropriate FBI POC of any cancellations or no -shows via e-mail within one

(1) business day.

c) Ensure that every examination is conducted by the appropriate level provider and all documentation has been completed in entirety.

d) Provide the Applicant or employee with clear instructions and directions to the examination site.

Applicant assessments are scheduled as required.

98% of scheduled assessments meet all stated requirements.

Survey Applicant coordinators and evaluate feedback. (trend analysis)

4) Successful scheduling of Periodic Fitness for Duty Assessments and Medical Surveillance Exams within thirty

(30) business days of work order receipt

a) Schedule an examination appointment with the Employee/Applicant within forty-eight (48) hours of notification and agree upon an appointment date that is within thirty (30) business days of the notification.

b) Inform the appropriate FBI POC of any cancellations or no

Applicant Aassessments are scheduled as required.

98% of scheduled assessments meet all stated requirements.

-shows via e-mail within one

(1) business day.

c) Ensure that every examination is conducted by the appropriate level provider and all documentation has been completed in entirety.

d) Provide the Applicant or employee with clear instructions and directions to the examination site.

5) Successful scheduling of Expedited Work Order within two five

(25) business days from completed assessment/examination

a) Schedule an examination appointment with the Applicant/Employee within forty-eight (48) hours of notification and agree upon an appointment date that is within five (5) business days of the notification.

b) Inform the appropriate FBI POC of any cancellations or no -shows via e-mail within one

(1) business day.

c) Ensure that every examination is conducted by the appropriate level provider and all documentation has been completed in entirety.

d) Provide the Applicant or employee with clear instructions and directions to the examination site.

Expedited assessments are scheduled as required.

98% of scheduled assessments meet all stated requirements.

6) Successful completion of Standard Referral Report Submission within ten

(10) business days from completed assessment/examination

a) Review and complete all components of the examination package (i.e., FD-1093, FD-1065) prior to electronically sending to

FBI.

b) Conduct all examinations in accordance with the Statement of Work section C.

c) Ensure all “yes” answers to the FD- 1065 are explained fully.

d) Prepare a summary of findings.

e) Submit the completed medical examination package electronically within ten (10) business days of physical exam.

f) Provide a fitness for duty recommendation for FBI employees only.

Assessments are completed as required.

98% of assessments meet all stated requirements.

100% review of PERs.

7) Successful completion of Expedited Referral Report Submission within five two (52) business days from completed assessment/examination

a) Review and complete all components of the examination package (i.e., FD-1093, FD- 1065) prior to electronically sending to FBI.

b) Conduct all examinations in accordance with the Statement of Work section C.

c) Ensure all “yes” answers to the FD-1065 are explained fully.

d) Prepare a summary of findings.

e) Submit the completed medical examination package electronically within ten two

(210) business days of physical exam.

Assessments are completed as required.

98% of assessments meet all stated requirements.

100% review of PERs.

f) Provide a fitness for duty recommendation for FBI employees only.

8) Each Contracted provider maintains and protects their Applicant and FBI files as required.

The Contracted provider is to maintain any paper or electronic records in accordance with applicable legal and professional standards and then, destroyed by the Contracted provider.

While in the Contracted providers’ possession, all applicant and FBI records shall be secured according to applicable legal requirements and professional standards for confidentiality and privacy purposes.

Non - Disclosure Agreement: The Contractor / Contracted provider shall not disclose any of the Applicant’s examination results unless a critical result is identified that requires immediate care.

Examination records are maintained and secured as required.

98% of examination records are maintained and secured as required.

Random inspection conducted at FBI discretion.

9) The Contractor / Contracted provider shall provide timely follow-up if examination packages are found to be incomplete.

Respond, at no cost to the Government, to any clarification requests and / or corrections of the examination package within seventy - two (72) hours.

100 % compliance with requested information in a timely manner.

Ad hoc whenever post – assessment support is required.

ATTACHMENT 2:

QUALITY ASSURANCE

MONITORING FORM

SERVICE or STANDARD:

SURVEY PERIOD:

SURVEILLANCE METHOD (Check):

Random Sampling 100% Inspection Periodic Inspection Customer Complaint

LEVEL OF SURVEILLANCE (Check):

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): Meets Standards

Does Not Meet Standards Narrative of Performance During Survey Period:

PREPARED BY: DATE:

ATTACHMENT 3:

QUALITY ASSURANCE

CUSTOMER COMPLAINT FORM

SERVICE:

DATE:

HOW REPORTED (Check):

Random sampling (talking with customers) Automated generated complaint Call or walk-in

ANALYSIS OF RESULTS:

Observed Service Provider Performance Measurement Rate: % Service Provider’s Performance (Check): Meets Does Not Meet Standards

Narrative of Complaint:

PREPARED BY: DATE: