QASP.pdf

QASP

HIPAA Privacy and Security Policy

Services

HHS/CDC/NIOSH World Trade Center Health Program (WTCHP)

April 22, 2015

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP) For

HIPAA Privacy and Security Policy Services

TABLE OF CONTENTS:

1.0 Mission Page # 3

2.0 Purpose 3

3.0 Authority 3

4.0 Roles and Responsibilities 4

5.0 Contractor’s Quality Control Plan (QCP) 5

6.0 Performance Requirements and Method(s) of Surveillance 6

7.0 Surveillance Documentation 7

8.0 Acceptance of Services 8

9.0 Contract Management 8

Appendices:

1. Services Summary (SS) and Method of Surveillance 10

2. Corrective Action Report (CAR) 12

3. Customer Complaint Record 13

4. Performance Assessment Report (PAR) 14

5. COR Services Summary Monthly Surveillance Report 15

5a. Performance Ratings used for COR Services Summary Surveillance Report 17

1.0 Mission

In an effort to meet the increased demands of the Health Insurance Portability and Accountability Act (HIPAA), NIOSH WTC Health Program (WTCHP) created a HIPAA Privacy and Security

Risk Assessment Team (RAT). The primary focus of the team is to serve as the focal point for program issues, policy understanding, guidance and oversight of program requirements in support of WTC Health Program which in turn provides direction to all WTCHP contractors. The WTC

Health Program HIPAA Risk Assessment Team is also responsible for providing HIPAA Privacy policy management and support to all the WTC Health Program contractors contracted with the

National Institute for Occupational Safety and Health (NIOSH) WTC Health Program. The team coordinates efforts through the HHS Office of General Counsel (OGC). This interface will include Privacy Act issues/concerns, as well as HIPAA Privacy and security issues/concerns, to include breach notifications.

2.0 Purpose

This Quality Assurance Surveillance Plan (QASP) is a government-developed document used to determine if the contractor’s performance meets the performance standards outlined in the contract.

The QASP establishes procedures on how to conduct surveillance/inspection process to ensure successful PWS performance. It provides a systematic method for continuous oversight process to determine conformity with the technical requirements of the contract. The QASP establishes:

What will be monitored.

How monitoring will take place.

Who will conduct monitoring.

How monitoring efforts and results are documented.

The contractor is responsible for implementing and delivering performance that meets contract objectives using its Quality Control Plan (QCP). The QASP provides the structure for the government’s surveillance of the contractor’s performance to assure that it meets contract requirements. It is the government’s responsibility to be objective, fair and consistent in evaluating contractor performance. The Contracting Officer (CO) shall also ensure that the contractor receives impartial, fair, and equitable treatment under this contract and determines the final assessment of contractor performance.

The QASP is not part of the contract nor is it intended to duplicate the contractor’s QCP. This

QASP is a living document. Flexibility in the QASP is required to allow for an increase or decrease in the level of surveillance necessary based on contractor performance.

The government may provide a copy of the QASP to the contractor to facilitate open communication. In addition, the QASP should recognize that unforeseen or uncontrollable circumstances might occur that are outside the control of the contractor.

The QASP should ensure early identification and resolution of performance issues to minimize impact on mission performance.

3.0 Authority

Authority for issuance of this QASP is provided under Part 37.604 and 46.4 of the Federal

Acquisition Regulation (FAR), Inspection of Services clauses (also reference 52.212-4 Contract

Terms & Conditions—Commercial Items Paragraph (a) Inspection/Acceptance), which provides for inspection, acceptance and documentation of the service called for in the contract or order. This acceptance is to be executed by the Contracting Officer (CO) or a duly authorized representative.

4.0 Roles and Responsibilities

Multi-Functional Team Roles and Responsibilities:

The purpose of the multi-functional team (MFT) is to create an environment that shapes and effectively executes acquisitions within their purview. The emphasis is on teamwork, trust, common sense and agility. These stakeholders are responsible for the acquisition throughout the life of the requirement, instituted under the authority of the senior leadership; every representative within the multi-functional team brings to the team their unique level of expertise. The following personnel comprise the MFT and shall oversee and coordinate surveillance activities.

Government Representatives:

Contracting Officer (CO) – The CO shall ensure performance of all necessary actions for effective contracting, ensure compliance with the contract terms, and shall safeguard the interests of the United States in the contractual relationship. The CO shall also ensure that the contractor receives impartial, fair, and equitable treatment under this contract and shall determine the final assessment of the contractor’s performance. The CO shall designate a primary and alternate COR prior to contract award. Upon request, the CO shall provide an assessment on COR performance to the COR Supervisor. The CO is the only person with the authority to make interpretations of and changes to the contract.

Specific duties of the CO include:

Delegating authority for inspection and/or acceptance to COR in accordance with the terms and conditions of the contract.

Informing the contractor of the names, duties, and limitations of authority for all COR assigned to the contract.

Periodically assessing the COR’s performance.

Managing contractor performance surveillance data, including submitting Contractor

Performance Assessment Reporting System (CPARS) reports.

Ensuring the MFT reviews this QASP annually (at a minimum) for recommended changes.

Providing contract-specific training (to include refresher training) administered by CO or CO’s designee to all appointed CORs.

Contracting Officer’s Representative (COR) - The COR is responsible for providing continuous program and technical oversight of the contractor’s performance. While the COR may serve as a direct conduit to provide Government guidance and feedback to the contractor on technical matters, they are not empowered to make any contractual commitments or any contract changes on the government’s behalf. The COR is responsible for reporting early identification of performance problems to the CO and may use the applicable appendix items for documenting contractor performance.

Specific duties of the COR include:

Evaluating and documenting the contractor’s performance in accordance with the procedures set forth in the QASP.

Recommending any changes necessary to the contract, PWS, QASP, or other items to provide operations that are more effective or eliminate unnecessary costs.

Keeping a COR file that accurately documents the contractor’s actual performance

(i.e. COR surveillance reports).

Utilizing COR file data (i.e. performance and COR surveillance reports) to assist the

CO in the preparation of the CPARS reports.

Receiving required training before performing any COR duties (IAW MP5301.602-

2(d)).

To notify the CO immediately regarding contractor non-compliance with FAR 52.222-

50, “Combating Trafficking in Persons.”

o The Contractor shall comply with FAR 52.222-50, Combating Trafficking in

Persons. Additional information about Trafficking in Persons can be found at the site for the Department of State’s Office to Monitor and Combat

Trafficking in Persons: http://www.state.gov/j/tip

Quality Assurance Program Coordinator (QAPC) - The QAPC is responsible for developing, managing, and implementing the Quality Assurance Program. The QAPC provides the QAPC Led Training & may provide refresher training, as needed.

Contractor Representatives:

Contractor – Complies fully with the terms and conditions of the contract and ensures non- conforming contract services are identified and corrected.

Specific duties of the Contractor include:

Participating as a member of the MFT in the post-award management phase.

Maintaining and implementing their commercial quality procedures that ensure contract requirements are met.

Ensuring that the QCP is revised when necessary to prevent recurrence of non- conforming contract services.

Tendering to the government for acceptance, only those services that conform to contract requirements.

Recommending any changes to the contract that will provide operations that are more effective or eliminate unnecessary costs.

5.0 Contractor’s Quality Control Plan (QCP)

A Contractor’s QCP, and updates a needed, is provided in accordance with the terms and conditions of the contract. The Contractor’s QCP compliments this QASP and is located in the contract file.

http://www.state.gov/j/tip

The Contractor shall submit a QCP no later than five (5) days after award. The Contractor shall develop and maintain an effective quality control plan to ensure services are performed in accordance with this PWS. The Contractor shall develop and implement procedures to identify, prevent, and ensure non-recurrence of defective services. The Contractor’s QCP is the means by which he assures himself that his work complies with the requirement of the contract. The

Contractor is responsible for contract management and quality control, not the Government. The

QCP will be delivered via e-mail to the CO for the COR’s acceptance. The COR will provide a written notice of any changes to be made to QCP or notice of acceptance in writing to the

Contractor. The Contractor shall submit any updates to the QCP within five business days after the first review by the COR. Any updates to the QCP will be reviewed by the COR for acceptance in writing.

6.0 Performance Requirements and Method(s) of Surveillance

6.1 Contract Surveillance

The goal of the QASP is to ensure that contractor performance is effectively monitored and documented. The COR’s contribution is their professional, non-adversarial relationships with the

CO and the contractor, which enables positive, open and timely communications. The COR uses the methods contained in this QASP to ensure the contractor complies with contract requirements.

The COR function is responsible for a wide range of surveillance requirements that effectively measure and evaluate the contractor’s performance. Additionally, this QASP is based on the premise that the contractor, not the Government, is responsible for management and quality control/quality assurance actions to meet the terms of the contract.

Incentives. Performance that continually exceeds the performance objectives as outlined in the

PWS may result in reduced surveillance and favorable Contractor Performance Assessment

Reports (CPAR). Performance that does not meet the performance objectives as outlined in the

PWS may result in re-performance of the defective service in accordance with the Inspection of

Services clause, reduction of fee/price, negative CPAR reporting and/or increased surveillance.

Non-Service Summary (SS) Items. Quality performance is expected on all contract requirements by the contractor and is not limited to just SS items. All Non-SS items may be inspected by the COR.

6.2 Surveillance Summary

The Services Summary (SS) and Method of Surveillance (Appendix 1) is the list of performance objectives and thresholds that must be performed by the contractor. This summary details the method(s) of surveillance the COR will use to validate and inspect these performance objectives.

Inspection of each objective will be documented in the COR file.

Performance objectives define the desired outcomes. Performance thresholds define the level of service required under the contract to meet the performance objective. The Government performs surveillance, using this QASP, to determine the quality of the contractor’s performance as it relates to the performance thresholds. The PWS and QASP should be used to form the foundation of the

COR’s inspection.

Method(s) of Surveillance:

100% Inspection: The COR will inspect and evaluate the contractor’s performance each time it is performed. The result of the contractor’s overall performance is then evaluated to determine acceptability of the service provided.

Customer Complaint: The COR is the point of contact and must collect all customer complaints.

The Customer Complaint Record below will be used for this purpose. All complaints and any resulting resolution of such complaints must be documented with the information required on the customer complaint form. Customer complaint forms become a permanent part of the COR file.

7.0 Surveillance Documentation

7.1 Corrective Action Report (CAR) (Appendix 2)

Corrective Action reporting is divided into two categories, which are as follows: minor and major.

Minor: A minor discrepancy is a departure from established standards having little bearing on the service provided. Some examples would be data deliverables with minor grammatical or spelling errors or insufficient copies of documents. When the COR identifies a minor discrepancy, the COR shall document the discrepancy and verbally contact the designated contractor representatives, but is not required to notify the CO. However, if the same minor discrepancy is identified more than once, it may be an indication that a major discrepancy is occurring or has occurred because the contractor has not taken proper steps to prevent recurrence.

In this case, the COR shall notify the CO in writing, which may include e-mail.

Major: If at any time the COR identifies a condition as having a significant adverse effect on the quality of the service, such as those stated below, the COR shall document their findings and notify the CO immediately in writing. E-mail is acceptable. Major discrepancies will be reported by the COR to the designated contractor representative in writing; however, copies of written correspondence will be coordinated with the CO prior to issuance to the contactor representative. Some examples are contractor failure to meet a performance objective, failure to provide adequate corrective action to preclude recurrence of government-identified findings, failure to provide corrective action to deficiencies identified by the COR within a prescribed suspense period or failure to adhere to security regulations that results in a security incident.

7.2 Customer Complaint Record (Appendix 3)

The COR shall ensure complaint procedures and forms are made available to all customers (See

Customer Complaint Record below). Any personnel that observe questionable or incomplete services or services not performed, or performed improperly, should immediately contact the COR.

The COR shall receive, document, and validate or invalidate all complaints. If the complaint is invalid, the COR shall contact the complainant and explain why the complaint was invalid. The

COR shall fully document the resolution for each complaint on the Customer Complaint Record.

Complaints will be tracked and if the performance threshold is exceeded, the COR shall notify the

CO in writing. The CO will notify the contractor and appropriate action can be taken.

7.3 Performance Assessment Report (PAR) (Appendix 4)

PARs will be used to report all minor discrepancies and will be generated by the COR and sent to the contractor for corrective action. Contractor will be given ten (10) days to correct PARs unless they have requested an extension. If three (3) minor discrepancies are found, combine them and process a CAR.

7.4 COR Services Summary Monthly Surveillance Report (Appendix 5)

The communication of expected outcomes begins the performance management feedback loop.

Performance standards are expressed in the PWS and are assessed using the methods of surveillance shown in the SS surveillance.

This report shall be submitted to the CO no later than the 5 th business day of each month.

8.0 Acceptance of Services

Before acceptance of product(s) or service(s) and/or approval of an invoice, the COR shall prepare a COR Services Summary Surveillance Report (Appendix 5) in accordance with the QASP and

FAR 52.212-4 (Contract Terms and Conditions – Commercial Items), Inspection and Acceptance

Clause or FAR 52.246-4 Inspection of Services—Fixed Price (or -5 for Cost Reimbursement/-6

T&M & LH, etc.). The report can be tailored to meet the surveillance needs for the requirement but as a minimum, it must contain the Services Summary with Performance Ratings & explanation(s) for any PWS requirement rated above or below “Satisfactory” (See Attachment 1 to Appendix 5 for definitions of Performance Ratings). The report shall identify both positive and negative performance. The report shall be signed and dated by the COR & CO and uploaded to the CORT

Tool.

The COR will certify that acceptable services were received, in accordance with the terms and conditions of the contract. The COR will certify receipt of contractor services via the Wide Area

Workflow (WAWF) website. Certification of services shall be accomplished no later than seven

(7) days after receipt of the invoice. To avoid payment of interest penalties, if the invoice is unacceptable, it should be rejected in WAWF within the first seven (7) days after receipt of the invoice, and the CO should be notified immediately.

9.0 Contract Management

The MFT shall conduct periodic progress meetings to review the contractor’s performance. At these meetings, the CO will apprise the contractor of how the Government views the contractor’s performance and the contractor will apprise the Government of problems, if any, being experienced.

The contractor will immediately notify the CO and/or COR of any work being performed that the contractor considers over and above the requirements of the contract. Appropriate action shall be taken to resolve any outstanding issues (i.e. CPARS, customer complaint reports, etc.).

The MFT shall also provide any recommended changes to the QASP to the CO at the progress meetings or on an annual basis (at a minimum).

Initial Contract Performance Review: This evaluation shall take place within 30 days after the contractor assumes full performance responsibilities (i.e. after completion of transition / mobilization) to ensure the contractor has successfully started performance, completed transition, is fully operations, and is within the estimated cost, schedule, and performance parameters of the contract.

Initial Contract Performance Review Criteria

Technical. Assess the contractor’s conformance to contract requirements, specifications and standards of good workmanship (e.g., commonly accepted technical, professional, environmental, safety, or health standards).

Schedule. Assess the timeliness of the contractor against contract requirements;

task orders, milestones, delivery schedule, administrative requirements, and sample negative and positive turnaround times (e.g., efforts that contribute to or affect the schedule variance).

Management/Performance. Assess the integration and coordination of all activity needed to execute the contract, specifically the completeness and quality of problem identification, corrective action plans, the contractor’s history of reasonable and cooperative behavior, customer satisfaction and management of subcontracts including progress on small business subcontracting goals.

Staffing. Assess the contractor’s performance in selecting, retaining, supporting and replacing when necessary, personnel.

COR Contract File: A contract file must be established and maintained by the COR.

Appendix 1 – Services Summary (SS) and Method of Surveillance:

Requirement

PWS

Paras

AQL/Performance Threshold

(Performance is acceptable if…)

Surveillance/

Monitoring Method

Assist the WTC Health

Program HIPAA RAT with HIPAA compliance.

2.1.1 There are no more than five (5) HIPAA

deficiencies, to include late, missed, unaccomplished responses or suspenses, as substantiated by the COR, in any six

(6) consecutive- month period.

Deficiencies will be tracked using a spreadsheet.

WTCHP Concerns

Policy Consultancy 2.1.4 The Contractor provides policy consultant services via recommendations and analysis with no more than five (5) deficiencies, to include late, missed, unaccomplished responses or suspenses, as substantiated by the COR, in any six (6) consecutive-month period. Deficiencies will be tracked using a spreadsheet.

Task deliverables

Development and

Updates of Training

Manual

2.1.8 Training manual is updated within

60 days of changes in law, and accurately developed 90% of the time. Deliveries will be tracked using a spreadsheet.

100% Inspection by the

COR

HIPAA Privacy and

Security Annual

Refresher Training

2.1.8 The Contractor delivers the annual

refresher training 100% of the time.

Training accomplishment will be tracked using a spreadsheet.

100% Inspection by the

COR

Monthly Newcomer’s

HIPAA Orientation briefing

2.1.8 The Contractor shall include in the training

manual a monthly “Newcomers” HIPAA briefing/training. The training shall include the notification of an absence, if any, for any “Newcomers” not completing the training within the first 30 days of employment. The “Newcomers” training will be tracked using a spreadsheet.

100% Inspection by the

COR

Communication 2.1.10 The Contractor returns all forms of

HIPAA-related communications (phone, email, etc.) with supported agencies, Contractors, and WTCHP personnel by

COB of the following business day every day that the communication was received 90% of the time.

WTCHP workforce, Stakeholders, and

Business Associates

Complaints

Paras

AQL/Performance Threshold

(Performance is acceptable if…)

Surveillance/

Monitoring Method

Quarterly Reports 2.4.1 Due by the 10 th business day of the month following the quarter being reported no less than 3 quarters per annual PoP. All deliverables delivered to the COR will be tracked by the COR.

100% Inspection by the

COR

Monthly Status

Reports (MSR)

2.4.2 Due by the 5th business day of the

month being reported 11 out of every

12 months. All deliverables delivered to the COR will be tracked by the COR.

100% Inspection by the

COR

Comprehensive HIPAA Risk Analysis Report 1.2

Draft – 90 days after contract award

Final – 150 days after contract award

100% Inspection by the

COR

WTCHP HIPAA Policies Report

1.2 Draft – 120 days after contract award

Final – 180 days after contract award

COR

Training Module(s)

Development and

Deployment Updates and

Implementation

2.1.8 Define the deployment plan and process

involved with implementing and beginning

HIPAA web base training. The intended audience is the WTCHP workforce, stakeholders, and contractors---Draft – 90 days after contract award.

Production simulation testing of training module—150 days after contract award.

Initial implementation of training module

–270 days after contract award.

Final implementation of HIPAA training modules, manual including CDs with detailed presentation on HIPAA Privacy and Security rules—due 360 days after contract award.

100% Inspection by the

COR

Trip Reports (TR) 2.8.3 Due by the 5 th business day after the last day of travel 90% of the time. All deliverables delivered to the COR will be tracked by the COR.

COR

Appendix 2 – Corrective Action Report

CORRECTIVE ACTION REPORT (CAR)

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

1. CONTRACTOR 2. CONTRACT NUMBER 3. TYPE OF SERVICES

4. FUNCTIONAL AREA 5. SUSPENSE

DATE

6. CONTROL

NUMBER

7. DEFICIENCY MAJOR MINOR

FINDING:

FINDING IMPACT:

Please respond with a written corrective action plan that details the corrective action of the cited deficiency, the cause of the deficiency, and actions taken to prevent recurrence by Suspense Date in Block 5. If date was not entered in Block 5, the contractor is not required to provide a response.

8. CONTRACTING OFFICER’S REPRESENTATIVE (COR)

TYPED NAME AND GRADE

SIGNATURE AND DATE

9. ISSUING AUTHORITY

TYPED NAME AND GRADE

SIGNATURE AND DATE

10. COR RESPONSE TO CONTRACTOR CORRECTIVE ACTION AND ACTION TAKEN TO PREVENT

RECURRENCE

11. COR DETERMINATION

ACCEPTED REJECTED

12. CLOSE DATE

Appendix 3 – Customer Complaint Record

CUSTOMER COMPLAINT RECORD

DATE/TIME OF COMPLAINT

SOURCE OF COMPLAINT

ORGANIZATION BUILDING NUMBER INDIVIDUAL PHONE NUMBER

NATURE OF COMPLAINT

CONTRACT REFERENCE

VALIDATION

DATE/TIME CONTRACTOR INFORMED OF COMPLAINT

ACTION TAKEN BY CONTRACTOR

RECEIVED/VALIDATED BY

Appendix 4 – Performance Assessment Report

PERFORMANCE ASSESSMENT REPORT (PAR)

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

1. CONTRACT/TASK ORDER NUMBER 2. CONTRACTOR 3. TYPE OF SERVICES

4. CONTRACTING OFFICER’S REPRESENTATIVE (COR) SIGNATURE AND DATE

5. COR PHONE

6. SUSPENSE DATE

I. PERFORMANCE

7. DEFICIENCY (CHECK ALL BOXES THAT APPLY)

NEW

REPEAT

NO DEFICIENCY NOTED

8. SERVICES SUMMARY 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 COR CITED DEFICIENCY

III. ACTION CORRECTED

14. CONCUR NON-CONCUR COR SIGNATURE AND DATE

15. COR REMARKS (REQUIRED)

16. CONTRACTOR REPRESENTATIVE REMARKS

Appendix 5 - COR Services Summary Monthly Surveillance Report

CONTRACT/TASK ORDER #:

SERVICE: HIPAA Privacy Policy Services

SURVEY PERIOD:

Paras

AQL/Performance Threshold

(Performance is acceptable if…)

Surveillance/

Monitoring Method

Performance Rating

See Appendix 5.a for ratings & definitions

Assist the WTC Health Program with HIPAA Privacy and Security requirement compliance.

2.1.1

There are no more than five (5) HIPAA deficiencies, to include late, missed, unaccomplished responses or suspenses, as substantiated by the COR, in any six (6) consecutive-month period. Deficiencies will be tracked using a spreadsheet.

Customer Complaint

Resolution of

Complaints

2.1.2

The Contractor resolves, investigates, and coordinates all HIPAA complaints throughout the various levels 95% of the time. Complaints will be tracked electronically via database or spreadsheet.

Policy Consultancy

2.1.4

The Contractor provides policy consultant services via recommendations and analysis with no more than five (5) deficiencies, to include late, missed, unaccomplished responses or suspenses, as substantiated by the COR, in any six (6) consecutive-month period. Deficiencies will be tracked using a spreadsheet.

Development and

Updates of Training

Modules

2.1.8

Training modules are updated within 60 days of changes in law, and accurately developed 90% of the time. Deliveries will be tracked using a spreadsheet.

100% Inspection by the COR

HIPAA Privacy and

Security Annual

Refresher Training

The Contractor delivers the annual refresher training 100% of the time. Training accomplishment will be tracked using a

Monthly SG

Newcomer’s

Orientation briefing

The Contractor shall include in the training manual a monthly “Newcomers HIPAA briefing/training. The training shall include the notification of an absence, if any, for any

Newcomers not completing the training within the first 30 days of employment. The

Newcomers training will be tracked using a

Communication

2.1.10

The Contractor returns all forms of HIPAA-related communications (phone, email, etc.) with supported agencies by COB of the following business day every day that the communication was received 90% of the time.

Quarterly Reports

2.4.1

Due by the 10 th business day of the month following the quarter being reported no less than 3 quarters per annual PoP. All deliverables delivered to the COR will be tracked by the COR.

Paras

AQL/Performance Threshold

(Performance is acceptable if…)

Surveillance/

Monitoring Method

Performance Rating

See Appendix 5.a for ratings & definitions

Monthly Status Reports

(MSR)

2.4.2

Due by the 5th business day of the month being reported 11 out of every 12 months. All deliverables delivered to the COR will be tracked by the COR.

Final Privacy & Security Training Manual

2.4.4

Draft – 150 days after contract award Final – 180 days after contract award

Trip Reports (TR)

2.8.3

Due by the 5 th business day after the last day of travel 90% of the time. All deliverables delivered to the COR will be tracked by the COR.

SERVICE or STANDARD (For Non-Service Summary Items found not meeting standards):

Appendix 5.a - Performance Ratings used for

COR Services Summary Monthly Surveillance Report

The evaluation ratings are as follows:

Excellent/Outstanding – Performance meets contractual requirements and exceeds many to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with no problems and the contractor actions were highly effective.

Very Good - Performance meets contractual requirements and exceeds some to the Government’s benefit.

The contractual performance was accomplished with few minor problems for which corrective actions taken by the contractor were effective.

Satisfactory - Performance meets contractual requirements. The contractual performance contains some minor problems for which corrective actions taken by the contractor were satisfactory.

Marginal - Performance does not meet contractual requirements. The contractual performance reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented.

Unsatisfactory – Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The contractual performance contains a serious problem(s) for which the contractor’s corrective actions appear or were ineffective.