D.1 Quality Assurance Surveillance Plan (QASP)KT signed.pdf

Quality Assurance Surveillance Plan (QASP)

Onsite Emergency Department Physician Services 36C25623R0009

The contractor will 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.

This QASP does not detail how the contractor accomplishes the work. Rather, the QASP is created with the premise that the contractor is responsible for management and quality control actions to meet the terms of the contract. It is the Government’s responsibility to be objective, fair, and consistent in evaluating performance.

This QASP is a “living document” and the Government may review and revise it on a regular basis. However, the Government shall coordinate changes with the contractor through contract modification. Copies of the original QASP and revisions shall be provided to the contractor and Government officials implementing surveillance activities.

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: Keo R. Stephanie Stephanie.Keo@va.gov 713-791-1414 ext 26408

Assigned Contract Specialist (CS): Troy Davis troy.davis@va.gov 713-770-2659

Organization or Agency: U.S. Department of Veterans Affairs

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: Karla Thompson – karla.thompson@va.gov – 601-362-4471 ext 51354

Organization or Agency: G.V. “Sonny” Montgomery Medical Center, Department of Veteran Affairs

3. CONTRACTOR REPRESENTATIVES

The following employee(s) of the contractor serve as the contractor’s program manager(s) for this contract.

Primary Program Manager (Name, e-mail, and phone number):

Alternate Program Manager (Name, e-mail, and phone number):

mailto:Stephanie.Keo@va.gov mailto:troy.davis@va.gov mailto:karla.thompson@va.gov

4. PERFORMANCE STANDARDS

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. 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: Observing interactions, processes, and/or behaviors as they occur in natural or unusual settings to collect evaluative information.

b. PERIODIC INSPECTION. Inspections scheduled and reported quarterly or as needed per COR delegation.

c. ONGOING PROVIDER PRACTICE EVALUATION (OPPE): Data pertinent to care performed for each provider working under this contract biannually and/or as needed, to include Focused and Ongoing Preofessional Practice Evaluations (FPPE).

d. VALIDATED USER/CUSTOMER COMPLAINTS. Surveillance of written complaints received concerning Contractor relations with the Government employees or patients. The CO is final authority on validating complaints.

e. RANDOM SAMPLING. The randomly selected sample of an unspecified amount that is at least more than (one) 1 of any item or record directly related to the measure on an as needed basis throughout the period of performance.

6. QASP MATRIX

Measures PWS Reference

Performance Requirement

Standard Acceptable Quality Level

Surveillance Method

Met AQL/DID NOT MEET

AQL-

CPAR RATING/ADD

COMMENTS

Provider Quality Performance

4.6.4.1 All contractor’s

physician(s) shall perform in accordance with clinical standards

Ongoing Provider Professional Evaluations

(OPPE)

documentation for all (100%) staff providing services under the task order contract.

100% OPPE

Qualifications of Key 4.6.4.2 All contractor’s All (100%) 100%, no deviations initial

Personnel physician (s) shall contractor’s accepted inspection of be board physician(s) are qualification certified/board board documents All NVVPA and all contractor’s (100%) nursing physician practitioners are assistant(s), shall current with an be certified by unrestricted NCCPA, and all licensure as a contractor’s nurs nurse practitioners in practitioner.

any U.S. State, commonwealth, territory or the Districy of

Columbia.

Scope of Practice/Privileging 4.6.4.3 Contractor’s physician(s) perform within their individual scopes of practice/privileging

All (100%) contractor’s physician(s) perform within their scope of practice/privilege s 100% of the time.

100% OPPE and/or

FPPE

reviews.

Patient Access 4.6.4.4 Contractor’s physician(s) shall be available and in location as needed to properly perform tasks as specified.

All (100%) contractor’s physician(s) are on time and available to perform services.

100% Periodic Sampling of Time and Attendance Sheets

Patient Safety 4.6.4.5 Patient safety incidents shall be reported using VA Joinit Patient Safety Reporting (JPSR) System.

All incidents reported immediately (within 24 hours.)

All (100%) of patient safety incidents are reported using JPSR within 24 hours of incident.

100% Direct Observation and JPSR reports

Maintains licensing, registration, and certification

4.6.4.6 Updated

Licensing, registration and certification shall be provided as they are renewed.

Licensing and registration information kept current.

All (100%) licensing, registration(s) and certification(s) for contractor’s physician(s) shall be provided as they are renewed.

Licensing and registration information kept current.

100% Periodic Sampling or Random Sampling of contractor credentialing files

Mandatory Training 4.6.4.7 Contractor shall complete all required training per VAMC policy

All (100%) of required training is complete on time by contractor’s physician(s) and advanced practice provider(s) .

100% completions, no deviations

Periodic Sampling review of TMS reports

Privacy, Confidentiality and

HIPAA

4.6.4.8 Contractor is

aware of all laws, regulations, policies and procedures relating to Privacy, Confidentiality and HIPAA and complies with all standards Zero breaches of privacy or confidentiality

All (100%) contractor’s physician(s) (s) comply with all laws, regulations, policies and procedures relating to Privacy, Confidentiality and HIPAA. Zero breaches of privacy or confidentiality.

100% completions, no deviations

Periodic Inspection- Contractor shall provide evidence of annual training required by

VAMC,

reports violations per VA Directive 6500.6.

EDIS Utilization 4.6.4.9 Contractor must complete training for the proper utilization of EDIS and utilize the software as it was designed to be used.

All (100%) contractor physician(s) and advancwed practive provide(s) must complete training for the poper utilization of EDIS and utilize the software as it was designed to be used

EDIS Adoption Metrics as captured on EMMT must meet 75% threshold for all contractor’s physicians. And advanced practice providers.

Periodic sampling of

EDIS

adoption metric compliance through review of data on the Emergency Medicine Management Tool (EMMT)

E-Verify 4.4.5.8 Contractor must enroll in the E- Verify program within 30 calendar days of contract award and remain in compliance thereafter.

100% compliance

100% Reporting Periodic sampling and/or Quarterly review of compliance

SCA Reporting 4.4.5.9 Contractor must report all required contract activities annually by October 31

100% compliance

100% Reporting Annually

7. CPAR RATINGS ASSIGNED TO QASP ITEMS:

Metrics and methods are designed to determine rating for a given standard and acceptable quality level. The following ratings shall be used (Reference: CPARS User Manual: https://www.cpars.gov/documents/CPARS-Guidance.pdf:

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).

https://www.cpars.gov/documents/CPARS-Guidance.pdf

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 Report (CR), 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 CR in writing. The CR 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 CR will also state how long after receipt the contractor has to 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 CRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO.

See Sample CR on the following page.

9. COR AND CONTRACTOR ACKNOWLEDGEMENT OF QASP

SIGNED:

COR Karla Thompson DATE

SIGNED:

CONTRACTOR NAME/TITLE DATE

CONTRACT REPORT

1. CONTRACT NUMBER 2. REPORT NUMBER FOR THIS DISCREPANCY

3. TO: (Contracting Officer) 4. FROM: (Name of COR)

5. DATES

a. CR PREPARED

b. RETURNED BY

CONTRACTOR:

c. ACTION COMPLETE

6. Issue Identified (Describe in detail. Include reference to PWS Directive; attach continuation sheet if necessary.)

7. SIGNATURE OF COR Date:

8. SIGNATURE OF CONTRACTING OFFICER Date:

9a. TO (Contracting Officer) 9a. FROM (Contractor)

10. CONTRACTOR RESPONSE AS TO CAUSE AND ACTIONS TO PREVENT RECURRENCE.

(Cite applicable quality control program procedures or new procedures. Attach continuation sheet(s) if necessary.)

11. SIGNATURE OF CONTRACTOR REPRESENTATIVE Date:

12. GOVERNMENT EVALUATION.

13. GOVERNMENT ACTIONS

14. CLOSE OUT

NAME TITLE SIGNATURE DATE

CONTRACTOR

NOTIFIED

COR

CONTRACTING

OFFICER