Attachment 2 - QASP - Regulated Medical Waste Quality Assurance Surveillance Plan VISN19.pdf

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

1 INTRODUCTION

This quality assurance surveillance plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS) entitled VISN 19 Regulated Medicals Waste Disposal. This plan sets forth the procedures and guidelines VISN 19 Rocky Mountain Networks Healthcare Systems, will use in ensuring the required performance standards or services levels are achieved by the contractor.

1.1 Purpose

1.1.1 The purpose of the QASP is to describe the systematic methods used to monitor performance and identify required documentation and resources to be employed. The QASP provides a means for evaluating whether the contractor is meeting the performance standards/quality levels identified in the PWS and the contractor’s quality control plan (QCP), and ensure the government pays only for the level of services received.

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

1.2 Performance Management Approach

1.2.1 The PWS structures the acquisition around what service or quality level is required, as opposed to how the contractor should perform the work (i.e., results, not compliance).

This QASP will define the performance management approach taken by VISN 19 Rocky Mountain Networks Healthcare Systems to monitor and manage the contractor’s performance to ensure the expected outcomes or performance objectives communicated in the PWS 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.

1.2.2 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 and to what extent. This approach 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, if 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. A “results” focus provides the contractor flexibility to continuously improve and innovate over the course of the contract if the critical outcomes expected are being achieved and/or the desired performance levels are being met.

1.3 Performance Management Strategy

1.3.1 The contractor is responsible for the quality of all work performed. The contractor measures that quality through the contractor’s quality control (QC) program. 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 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 PWS. The contractor will develop and implement a performance management system with processes to assess and report its performance to the designated government representative. The contractor’s QCP will also set forth the staffing and procedures for self‐inspecting the quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the PWS. This QASP enables the government to take advantage of the contractor’s QC program.

1.3.2 The government representative(s) will monitor performance and review performance reports furnished by the contractor to determine how the contractor is performing against communicated performance objectives. The government will make determinations regarding incentives based on performance measurement metric data and notify the contractor of those decisions. The contractor will 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 (CO/KO)

The CO is responsible for monitoring contract compliance, contract administration, and cost control, and resolving any differences between observations documented by the Healthcare System Contracting Officer's Representatives (COR) and the contractor. The CO will designate one full‐time COR 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 must be identified and designated by the CO.

2.2 The COR

The COR is designated in writing by the CO to act as their authorized representative to assist in administering a contract. COR limitations are contained in the written appointment letter. 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 authorize any contractual changes on the government’s behalf.

Any changes the contractor deems may affect contract price, terms, or conditions must 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 quality levels are included in the PWS and Attachment 1, Performance Requirements Summary. If the contractor meets the required service or performance level, it will be paid per service on the agreed costs in the contract. If the contractor exceeds the service or performance level, it is eligible to receive an incentive or award fee as stated in the contract. Failure to meet the required service or performance level will result in a deduction from the monthly amount.

4 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 Surveillance Techniques

To minimize the performance management burden, simplified surveillance methods shall be used by the government to evaluate contractor performance when appropriate. The primary methods of surveillance are:

Direct observation – Each service shall be observable by the CORs

100 percent inspection – Each service provided, the COR shall review the generated documentation and enter summary results into the Surveillance Activity Checklist

Periodic inspection – the COR typically performs the periodic inspection

4.2 Customer Feedback

The contractor is expected to establish and maintain professional communication between its employees and customers. The primary objective of this communication is customer satisfaction. Customer satisfaction is the most significant external indicator of the success and effectiveness of all services provided and can be measured through customer complaints.

Performance management drives the contractor to be customer focused through initially and internally addressing customer complaints and investigating the issues and/or problems, but the customer always has the option to communicate complaints to the CO or COR, as opposed to the contractor.

Customer complaints, to be considered valid, must set forth clearly and in writing the detailed nature of the complaint, must be signed, and must be forwarded to the COR. The COR will accept those customer complaints and investigate.

Customer feedback may also be obtained either from the results of formal customer satisfaction surveys or from random customer complaints.

4.3 Acceptable Quality Levels

The acceptable quality levels (AQLs) included in Attachment 1 for contractor performance are structured to allow the contractor to manage how the work is performed while providing negative incentives for performance shortfalls. For certain critical activities, such as citations involving Department of Transportation (DOT) or any State regulators the desired performance level is established at 0 percent. As in the VA strives to have no DOT or State issues with Regulate Medical Waste disposal. Other levels of performance are keyed to the relative importance of the task to the overall mission performance at VISN 19 Rocky Mountain Networks Healthcare Systems.

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 PWS and assessed using the performance monitoring techniques shown in Attachment 1.

5.2 Monitoring Forms

The government’s QA surveillance, accomplished by the COR, will be reported using the monitoring form in Attachment 2. The forms, when completed, will document the government’s assessment of the contractor’s performance under the contract to ensure the required results are being achieved.

5.2.1 The COR will retain a copy of all completed QA surveillance forms.

6 ANALYSIS OF QUALITY ASSURANCE ASSESSMENT

6.1 Determining Performance

6.1.1 The government shall use the monitoring methods cited to determine whether the performance standards/service levels/AQLs have been met. If the contractor has not met the minimum requirements, it may be asked to develop a corrective action plan to show how and by what date it intends to bring performance up to the required levels.

6.2 Reporting

6.2.1 At the end of each quarter, the CORs will prepare a written report for the VISN 19 Rocky Mountain Networks Healthcare Systems summarizing the overall results of the quality assurance surveillance of the contractor’s performance. This report, which includes the contractor’s submitted service report and the completed quality assurance monitoring forms (Attachment 2), will become part of the QA documentation. It will enable the government to demonstrate whether the contractor is meeting the stated objectives and/or performance standards, including cost/technical/scheduling objectives.

6.3 Reviews and Resolution

6.3.1 The CORs may require the contractor’s project manager or designated alternate to meet with the CO and other government IPT personnel as deemed necessary to discuss the performance evaluation. The COR 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 will meet with the CORs as often as required or per the contractor’s request. The agenda of the reviews may include:

Service 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

6.3.2 The QAR must coordinate and communicate with the contractor to resolve issues and concerns regarding marginal or unacceptable performance.

6.3.3 The COR and 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 service levels, procedures, and metrics will be incorporated as a contract modification at the convenience of the procuring CO (PCO) or

ACO.

ATTACHMENT 1: PERFORMANCE REQUIREMENTS SUMMARY

Required Services (Tasks)

Performance Standards

Acceptable Quality Levels

Methods of

Surveillance

Incentive (Positive and/or Negative)

(Impact on Contractor Payments)

Establish pickup schedules for all stations within 30 days of award

IAW Local, State, Federal, to include DOT, EPA, and the Performance Work Statement

(PWS)

95% of shipments scheduled within 30 calendar days

Direct observation and 100% inspection

Positive

Make pickup of material within 7 calendar days of written/oral request for out of cycle pick ups

IAW Local, State, Federal, to include DOT, EPA, and the Performance Work Statement

(PWS)

95% of waste pickups made out‐ of‐cycle are within 7 calendar days

Direct observation and 100% inspection

Positive

Provide notification to COR within 24 hours of determination that pickup cannot be scheduled as requested or made as scheduled

IAW Local, State, Federal, to include DOT, EPA, and the Performance Work Statement

(PWS)

100% notification within required timeframe

Direct observation

Negative

Contractor to evaluate and prepare waste for

IAW Local, State, Federal, to include DOT, 100% compliance Direct observation

Positive packaging and labeling

EPA, and the Performance Work Statement

(PWS)

Prior to removal and transport of regulated medical waste and non‐ hazardous waste generated by the VA, obtain approval and signature for each manifest from the VA facility’s approved staff

IAW Local, State, Federal, to include DOT, EPA, and the Performance Work Statement

(PWS)

100% compliance Direct observation and 100% inspection

Periodic Inspections of records

Positive

Provide all requested training within 60 calendar days of receiving request

Performance Work Statement

(PWS) 3.2

95% of training provided within required timeframe

Direct observation and 100% inspection of records

Positive

Evaluate the VA’s waste streams annually for opportunities for waste management efficiency and minimization.

Performance Work Statement (PWS) 3.1s

100% of HCS are provided improvements annually

Periodic Inspection

Positive

Provide monthly report to the CORs that identifies types and weights of wastes shipped from each facility and provides a breakdown of the

Performance Work Statement (PWS) 3.1p

95% compliance per specified time frame

Periodic Inspection of records costs of services and the specific services.

Attend quarterly program meetings with the CORs and CO to address contract performance.

Performance Work Statement (PWS) 3.1q

95% compliance Direct observation

Periodic Inspection of attendance records

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 Per Pick Up

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: _________________