36C24419R0074-030.pdf
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- 36C24419R0074
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36C24419R0074 D.28 Quality Assurance Surveillance Plan.pdf
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Version 6/20/2019 Page 1 of 12
Quality Assurance Surveillance Plan (QASP)
Outpatient Site of Care Service
The contractor shall be evaluated in accordance with the following:
1. PURPOSE
This Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate performance for the stated contract. This QASP explains the following:
• What will be monitored.
• How monitoring will take place.
• Who will conduct the monitoring?
• How monitoring efforts and results will be documented.
2. GOVERNMENT ROLES AND RESPONSIBILITIES
The following personnel shall oversee and coordinate surveillance activities.
a. 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 assure that the contractor receives impartial, fair, and equitable treatment under this contract. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance.
Assigned CO: Mark Knorr
Assign CS: Brandi Shellhammer
Organization or Agency: Department of Veterans Affairs NC04/ Erie VAMC
b. Contracting Officer’s Representative (COR) – The COR is responsible for technical administration of the contract and shall assure proper Government surveillance of the contractor’s performance. The COR shall keep a quality assurance file. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government’s behalf.
Assigned COR: TBD
3. CONTRACTOR REPRESENTATIVES
The following employee(s) of the contractor serve as the contractor’s program manager(s) for this contract.
Primary:
Alternate:
4. PERFORMANCE STANDARDS
Version 6/20/2019 Page 2 of 12
The contractor is responsible for performance of ALL terms and conditions of the contract. CORs will provide contract progress reports quarterly to the CO reflecting performance on this plan and all other aspects of the resultant contract. The performance standards outlined in this QASP shall be used to determine the level of contractor performance in the elements defined.
To be paid the full capitated rate on the schedule, the contractor must provide services as required in the entire contract and to meet or exceed the acceptable quality level outlined in this section/sub-sections. If any portion of the requirement is not met and/or the acceptable quality level in any of the elements in this section/subsection are not maintained, the contractor will be notified by the contracting officer for response outlining the contractor’s proposed remedy. The Government may seek an equitable price reduction or adequate consideration for acceptance of nonconforming services per FAR 52.212-4.
Performance standards define desired services. The Government performs surveillance to determine the level of Contractor performance to these standards.
The Performance Requirements are listed below in Section 6. The Government shall use these standards to determine contractor performance and shall compare contractor performance to the standard and assign a rating. At the end of the performance period, these ratings will be used, in part, to establish the past performance of the contractor on the contract.
5. METHODS OF QA SURVEILLANCE
Various methods exist to monitor performance. The COR shall use the surveillance methods listed below in the administration of this QASP.
a. DIRECT OBSERVATION. 100% surveillance: method not applicable.
b. PERIODIC INSPECTION. Inspections scheduled and reported quarterly per COR delegation or as needed. Ten (10) randomly selected patient files will be reviewed per inspection period. All inspections and reports will be conducted in compliance with VA Privacy and Information security standards.
c. VALIDATED USER/CUSTOMER COMPLAINTS. Data collected from I CARE cards, congressional and patient-initiated interactions.
d. RANDOM SAMPLING. Ten (10) randomly selected patient files will be reviewed per quarter. All reviews and reports will be conducted in compliance with VA Privacy and Information security standards.
e. Verification and/or documentation provided by Contractor.
Version 6/20/2019 Page 3 of 12
6. Measures
VHA Contracted Outpatient Clinics Quality Assurance Surveillance Plan (QASP) Template
As of: October 2018
METRIC PWS
Para
Performance
Requirement
Standard Acceptable
Quality Level
(tailor to meet your requirements)
Method of
Surveillance and frequency
Met
AQL/Did
Not Meet
AQL
(Add comment)
DOMAIN: ACCESS
New PC Appointments
Completed within 20
Days of Create Date
(pc18)
New Primary Care
Completed Appointments less than or equal to 20 days from create date
(See Performance Measure
Report for more information)
PWS
para.
4.9.1
Contractor shall provide completed appointments for new PC patients <=20 days from the create date
Contractor shall provide completed appointments for new PC patients <=20 days from the create date no less than 76% of the time
Contractor shall provide completed appointments for new PC patients <=20 days from the create date no less than 95% of the time.
VA will monitor progress quarterly by using data from the Performance
Measure Report.
Established PC Patient
Average Wait Time in
Days (pc17)
Established Primary Care
Completed Appointments less than or equal to 20 days from Patient
Indicated Date (patient desired date) or the clinically indicated date information)
PWS
para.
4.9.2
Contractor shall provide completed appointments for established
PC patients
<=20 days from the patient indicated date
Contractor shall provide completed appointments for established
PC patients
<=20 days from the patient indicated date no less than 97% of the time
Contractor shall provide completed appointments for established
PC patients
<=20 days from the patient indicated date no less than
97% of the time.
VA will monitor progress quarterly by using data from
PCMH SHEP Access
Composite
Composite % based on 3 questions from the
SHEP/PCMH report: 1)
Get an urgent care appointment as soon as needed, 2) Get a routine care appointment as soon
PWS
para.
4.9.3
Contractor shall provide: 1) urgent care appointments as soon as needed,
2) routine care appointments as soon as needed, and 3) same day answers to
Contractor’s
SHEP access composite score shall meet or exceed 51%
Contractor’s
SHEP access composite score shall meet or exceed
69%
VA will monitor progress quarterly by quarterly using data from
SHEP/PCMH
report.
http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render
Version 6/20/2019 Page 4 of 12 as needed, and 3) Get same day answer to your medical question.
(See SHEP/PCMH Report for more information) patients’ medical questions
SHEP Question 7
In the last 6 months, how many days did you usually have to wait for an appointment when you needed care right away?
(Less is better)
PWS
para.
4.9.4
Contractor shall provide timely appointments when patients need care right away
Contractor’s
SHEP
question 7 score shall meet or exceed 41%
Contractor’s
SHEP question
7 score shall
41%.
by quarterly using data from
Same-Day
Appts w/ PCP
Measures the percent of requested same day appointments with PCP
(See PACT Compass for more information)
PWS
para.
4.9.5
Contractor shall provide same day appointments with primary care provider
Contractor’s same day appointments with PCP rate shall meet or exceed 60%
Contractor’s same day appointments with PCP rate shall meet or exceed 70% by using data from the PACT Compass.
Appointment
Cancellations
Cancelled by clinic rate for all active clinic stop codes (mop13)
(Lower is better) information)
PWS
para.
4.9.6
Contractor shall not unnecessarily cancel patient appointments
Contractor’s rate of appointments cancelled by clinic shall not exceed
9%
Contractor’s rate of appointments cancelled by clinic shall not exceed 9% by using data from
DOMAIN:
QUALITY OF CARE
Composite - Behavioral
Health Screening
Composite of mdd40 -- Vets screened annually for major depression dx.
ptsd51 -- PTSD screening using the PC-PTSD at required times
PWS
para.
4.9.7
Contractor shall complete all behavioral health screenings and follow-up evaluations
Contractor shall maintain a behavioral health composite score of at least 95%
Contractor shall maintain a behavioral health composite score of at least
95% the CBOC Report.
https://bioffice.pa.cdw.va.gov/default.aspx?bookid=e71e8f03-6829-403c-b002-b114ae1ac26f|ispasFalse|report8427c340-7848-4f27-a2d1-61dc7dfa3ea1|ws1|wsb0|isDisabledAnalyticsFalse|isDashboardPanelOnTrue https://bioffice.pa.cdw.va.gov/default.aspx?bookid=e71e8f03-6829-403c-b002-b114ae1ac26f|ispasFalse|report8427c340-7848-4f27-a2d1-61dc7dfa3ea1|ws1|wsb0|isDisabledAnalyticsFalse|isDashboardPanelOnTrue https://securereports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPC%2fPACTCompassCubeSSRS%2fMainMenu&rs:Command=Render http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render
Version 6/20/2019 Page 5 of 12 sa17 -- Vets screened for alcohol misuse w/ score
GE 5 w/ timely brief counselling sa7 -- Vets screened annually for alcohol misuse sre1 -- (mdd41 and ptsd52) aggregated scores for timely suicide evaluations
(See the CBOC Report for
Composite – Diabetes
Composite of dmg27h_ec DM: BP LT
140/90 ( eMeasure ) dmg34h_ec DM: Medical attention for nephropathy -
Renal Testing
(OP)(eMeasure) statn7_ec Statin therapy for patients with diabetes ( eMeasure )
PWS
para.
4.9.8
Contractor shall manage patients with diabetes in accordance with
VA standards
Contractor shall maintain a diabetes composite score of at least 79%
Contractor shall maintain a diabetes composite
79%
Composite - Ischemic
Heart
Composite of ihd53_ec and statn1_ec Statin
Therapy for patients with cardiovascular disease
(eMeasure)
PWS
para.
4.9.9
Contractor shall manage patients with ischemic heart disease in accordance with
VA standards
Contractor shall maintain an ischemic heart composite score of at least 78%
Contractor shall maintain an ischemic heart composite
78%
Composite – Prevention
Composite of dmg31h
DM: Retinal exam, timely by disease (OP) p61h Colorectal Cancer
Screening Ages 50-75 p42 Cervical Cancer
Screening Women age 21-
29y
PWS
para.
4.9.10
Contractor shall provide preventive health care in accordance with
VA standards
Contractor shall maintain a prevention composite score of at least 80%
Contractor shall maintain a prevention composite score of at least
80%
VA will monitor progress quarterly http://vaww.car.rtp.med.va.gov/programs/pm/pmReportsCBOC.aspx
Version 6/20/2019 Page 6 of 12 p43h Cervical Cancer
Screening Women age 30-pvc11h Pneumococcal
Immunizations (OP) EPRP sample p32h Breast Cancer
Screening including tomography for Women
50-74y (OP) HEDIS
Composite – Tobacco
Composite of smg8 Pts using tobacco provided w/counsel (OP) smg9 Pts using tobacco offered referral (OP) smg10 Pts using tobacco offered meds (OP)
PWS
para.
4.9.11
Contractor shall provide tobacco counseling and care in accordance with
VA standards
Contractor shall maintain a tobacco composite score of at least 94%
Contractor shall maintain a tobacco composite
94%
Clinical Reminders PWS para.
4.9.12
Contractor shall complete all clinical reminders as indicated in the
VA EHR.
Contractor shall complete no less than 90% of all clinical reminders as indicated in the VA EHR
Contractor shall complete no less than
90% of all clinical reminders as indicated in the
VA EHR
VA will monitor progress monthly by
Clinical supervisor will perform monthly chart audits.
Progress Notes and
Patient Care Encounter
(PCE) Module
Documentation
PWS
para.
4.9.13
Contractor shall complete workload and encounter documentation as defined in the
PWS within 2 business days.
Progress notes must be connected to the correct visit/encounter and location, entered into the
VA EHR on the same day as the visit/encounter, Contractor shall properly complete documentatio n for each patient encounter
100% of the time
Contractor shall properly complete documentation for each patient encounter
100% of the time progress monthly by
Clinical supervisor will perform monthly chart audits.
Version 6/20/2019 Page 7 of 12 meet CMS guidelines, and include content as defined in
PWS.
DOMAIN:
PANEL MANAGEMENT
Percent of Teams with
Core Teamlet Staffing
Ratio >=3
The total Core Primary
Care Support Staff
(clerical/administrative associate, RN care manager, and clinical associate) FTE divided by the total Primary Care
Provider FTE entered in the PCMM Web
Application.
(See mPACT Dashboard
PWS
para.
4.9.14
Contractor shall provide core teamlet staffing at a ratio of >=3
FTE core teamlet members (RN care manager, clinical associate, administrative associate) for each PCP FTE
100% of
Contractor’s primary care teams shall have a core teamlet staffing ratio of >=3
100% of
Contractor’s primary care teams shall have a core teamlet staffing ratio of >=3
VA will monitor progress quarterly by using data from the mPACT
Dashboard.
Percent of Women
Assigned to Women’s
Health PACT or
Designated Women’s
Health Provider
(WH1)
The total number of female patients assigned to a Women’s Health PACT
(identified by having
*WH* in the team name or a primary or secondary team focus of Women’s
Health) OR to a provider with a team role of
DESIGNATED WH
PROVIDER (WH-PCP)
divided by the total number of unique female patients assigned to
Primary Care Teams
PWS
para.
4.9.15
Contractor shall ensure that an appropriate number of WH-
PACTs or WH-
PCPs are available at site of care to ensure that all VHA access goals are met for women
Veterans who choose to be seen by a designated women’s health provider.
Contractor’s percent of women assigned to
Women’s
Health PACT or
Designated
Women’s
Health
Provider shall meet or exceed 77%
Contractor’s percent of women assigned to
Women’s
Health PACT or Designated
Women’s
Health Provider exceed 100% https://bioffice.pa.cdw.va.gov/default.aspx?bookid=e97f10a0-94e2-4186-b157-3e30a33fb349|ispasFalse|reporta945bca6-c8d6-4239-9190-f20255341eb2|ws4|wsb0|isDisabledAnalyticsFalse|isDashboardPanelOnTrue https://securereports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPC%2fPACTCompassCubeSSRS%2fMainMenu&rs:Command=Render
Version 6/20/2019 Page 8 of 12
Percent Primary Care
Patients Enrolled in
Home Telehealth
Reflects the total number of unique PC patients enrolled in home telehealth (numerator) divided by the total number of unique patients assigned to primary care teams (denominator)
PWS
para.
4.9.16
Contractor shall offer and refer patients to home telehealth
Contractor shall exceed
1.6% of PC patients enrolled in Home
Telehealth
(HT)
Contractor shall exceed
1.6% of patients enrolled in Home
Telehealth
(HT)
Ratio of Non-Traditional
Encounters
This is the sum of all PC telephone encounters added to the sum of all PC group encounters added to the sum of all incoming and outgoing secure messages, and video as the numerator. The denominator is the total team assignments for the reporting period.
PWS
para.
4.9.17
Contractor shall provide telephone encounters, group encounters, and secure messaging
Contractor shall exceed
25% ratio of non-traditional encounters
Contractor shall exceed
20% ratio of non-traditional encounters
VETERAN SATISFACTION
Veteran Satisfaction
Overall rating of Primary
Care Provider on question
32 of the SHEP/PCMH survey
PWS
para.
4.9.18
The
Contractor’s
PCPs shall provide care that
Veterans rate as a 9 or 10 on question 32 of the
SHEP/PCMH
survey
Contractor’s
SHEP
question 32 score shall meet or exceed 69%
Contractor’s
SHEP question
32 score shall
69% by using data from http://vaww.reporting.oqp.med.va.gov/ReportServer?%2fPerformance+Reports%2fMeasure+Management%2fMeasure&measure=2744&rs%3aParameterLanguage=en-US&rc%3aParameters=Collapsed http://vaww.reporting.oqp.med.va.gov/ReportServer?%2fPerformance+Reports%2fMeasure+Management%2fMeasure&measure=2744&rs%3aParameterLanguage=en-US&rc%3aParameters=Collapsed http://vaww.reporting.oqp.med.va.gov/ReportServer?%2fPerformance+Reports%2fMeasure+Management%2fMeasure&measure=2744&rs%3aParameterLanguage=en-US&rc%3aParameters=Collapsed https://securereports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPC%2fPACTCompassCubeSSRS%2fMainMenu&rs:Command=Render https://securereports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPC%2fPACTCompassCubeSSRS%2fMainMenu&rs:Command=Render https://bioffice.pa.cdw.va.gov/default.aspx?bookid=e71e8f03-6829-403c-b002-b114ae1ac26f|ispasFalse|report8427c340-7848-4f27-a2d1-61dc7dfa3ea1|ws1|wsb0|isDisabledAnalyticsFalse|isDashboardPanelOnTrue
Version 6/20/2019 Page 9 of 12
COORDINATION OF CARE
Post Discharge Contact by PACT Teamlet
The percent of assigned primary care patients discharged from any VA facility who have been contacted by PACT teamlet within two business days
PWS
para.
4.9.19
The
Contractor’s
PACT teamlets shall contact their assigned patients within 2 business days of discharge from any VA facility
Contractor’s rate of post discharge contact by
PACT
teamlet shall meet or exceed 60%
Contractor’s rate of post discharge contact by
PACT teamlet exceed 75%
PACT Compass.
ENVIRONMENT OF CARE (EOC)
Percentage of
Deficiencies Identified
During EOC Rounds that are Closed Timely
(e5eoc1)
Percentage of deficiencies identified during EOC rounds that are closed within 14-business days or have a documented Plan for Action (PFA) information)
PWS
para
4.9.20
Contractor shall address deficiencies identified in
EOC rounds within 14 business days or have a documented
Plan for Action
Contractor’s rate of EOC deficiencies that are closed within
14 business days or have a PFA shall meet or exceed 85%
Contractor’s rate of EOC deficiencies that are closed within 14 days or have a PFA exceed 85% by using data from
DOMAIN: PHARMACY
Non-Formulary and
Restricted Drug
Requests
PWS
para.
4.9.21
Contractor shall submit non-formulary and restricted drug requests in the
VA EHR using the PBM consult option
Contractor shall submit non-formulary and restricted drug requests in the VA
EHR using the PBM consult option 100% of the time.
(Zero disapproval ratings for non-
Contractor shall submit non-formulary and restricted drug requests in the VA EHR using the PBM consult option
100% of the time. (No more than 10% disapproval ratings for non-formulary and restricted drug
COR will monitor performance monthly via electronic reports pulled from the VA
EHR.
https://securereports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPC%2fPACTCompassCubeSSRS%2fMainMenu&rs:Command=Render http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render http://reports2.vssc.med.va.gov/ReportServer/Pages/ReportViewer.aspx?%2fPMR%2fPerformanceMeasures%2fPerformanceMeasureReport&rs:Command=Render
Version 6/20/2019 Page 10 of 12 formulary and restricted drug requests quarterly).
requests quarterly).
Pharmacy New Drug
Order Requests
PWS
para.
4.9.22
Contractor shall submit new drug orders through the VA EHR
The contractor shall ensure that 95% all new drug order requests follow all prescribing guidelines.
This is including but not limited to ensuring all appropriate labs have been previously ordered and that the order is not a non-formulary drug.
The contractor shall ensure that 95% all new drug order requests follow all prescribing guidelines.
This is including but not limited to ensuring all appropriate labs have been previously ordered and that the order is not a non-formulary drug.
COR will monitor performance quarterly via electronic reports pulled from the VA
EHR.
Version 6/20/2019 Page 11 of 12
7. Ratings:
Metrics and methods are designed to determine rating for a given standard and acceptable quality level. The following ratings shall be used:
EXCEPTIONAL: 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 few minor problems for which corrective actions taken by the contractor were highly effective.
Note: To justify an Exceptional rating, you should identify multiple significant events in each category and state how it was a benefit to the GOVERNMENT. However, a singular event could be of such magnitude that it alone constitutes an Exceptional rating. Also, there should have been NO significant weaknesses identified.
VERY GOOD:
Performance meets contractual requirements and exceeds some to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor were effective.
Note: To justify a Very Good rating, you should identify a significant event in each category and state how it was a benefit to the GOVERNMENT. Also, there should have been NO significant weaknesses identified.
SATISFACTORY:
Performance meets contractual requirements. The contractual performance of the element or sub-element contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory.
Note: To justify a Satisfactory rating, there should have been only minor problems, or major problems the contractor recovered from without impact to the contract. Also, there should have been NO significant weaknesses identified.
MARGINAL:
Performance does not meet some contractual requirements. The contractual performance of the element or sub-element being assessed 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.
Note: To justify Marginal performance, you should identify a significant event in each category that the contractor had trouble overcoming and state how it impacted the
GOVERNMENT. A Marginal rating should be supported by referencing the management tool that notified the contractor of the contractual deficiency (e.g., Management, Quality, Safety or Environmental Deficiency Report or letter).
UNSATISFACTORY:
Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The contractual performance of the element or sub-element being assessed contains serious problem(s) for which the contractor’s corrective actions appear or were ineffective.
Note: To justify an Unsatisfactory rating, you should identify multiple significant events in each category that the contractor had trouble overcoming and state how it impacted the GOVERNMENT. However, a singular problem could be of such serious magnitude that it alone constitutes an unsatisfactory rating. An Unsatisfactory rating should be supported by referencing the management tools used to notify the contractor of the contractual deficiencies (e.g. Management, Quality, Safety or Environmental
Deficiency Reports, or letters).
Version 6/20/2019 Page 12 of 12
8. DOCUMENTING PERFORMANCE
a. The Government shall document positive and/or negative performance. Any report may become a part of the supporting documentation for any contractual action and preparing annual past performance using CONTRACTOR PERFORMANCE ASSESSMENT REPORT (CPAR).
b. If contractor performance does not meet the Acceptable Quality level, the CO shall inform the contractor. This will normally be in writing unless circumstances necessitate verbal communication. In any case the CO shall document the discussion and place it in the contract file. When the COR and the
CO determines, formal written communication is required, the COR shall prepare a Contract Discrepancy
Report (CDR), and present it to CO. The CO will in turn review and will present to the contractor's program manager for corrective action.
The contractor shall acknowledge receipt of the CDR in writing. The CDR will specify if the contractor is required to prepare a corrective action plan to document how the contractor shall correct the unacceptable performance and avoid a recurrence. The CDR will also state how long after receipt the contractor must present this corrective action plan to the CO. The Government shall review the contractor's corrective action plan to determine acceptability. The CO shall also assure that the contractor receives impartial, fair, and equitable treatment. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance and the acceptability of the Contractor’s corrective action plan.
Any CDRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO.
9. FREQUENCY OF MEASUREMENT
a. Frequency of Measurement.
The frequency of measurement is defined in the contract or otherwise in this document. The government
(COR or CO) will periodically analyze whether the frequency of surveillance is appropriate for the work being performed.
b. Frequency of Performance Reporting.
The COR shall communicate with the Contractor and will provide written reports to the Contracting
Officer quarterly (or as outlined in the contract or COR delegation) to review Contractor performance.
10. COR AND CONTRACTOR ACKNOWLEDGEMENT OF QASP
SIGNED:
COR NAME/TITLE DATE
SIGNED:
CONTRACTOR NAME/TITLE DATE
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