4 QASP - PT.pdf

Attachment 4 to Solicitation #FA520922Q0006

QUALITY ASSURANCE SURVEILLANCE PLAN

FOR

PHYSICAL THERAPIST

6 Jul 2021

This Quality Assurance Surveillance Plan (QASP) has been developed as identified in Air Force Instruction (AFI) 63-138, FAR 46.401, DFARS 246.401, and DFARS 237.172. The QASP has been developed to evaluate contractor actions while implementing the Performance Work Statement (PWS). This plan will be used by the Contracting Officer’s Representative (COR) to ensure contractor compliance on the Physical Therapist contract. This plan prescribes the objective in having the services, the goals of the multi-functional team, team members and their roles and responsibilities, and how the multi-functional team will assess contractor performance and manage the contract to obtain efficiencies, improved performance, and cost savings throughout its life cycle.

1. OBJECTIVE

The objective is to provide all labor, materials, tools, equipment, parts, transportation, and other items and services necessary for the Physical Therapist in accordance with (IAW) the PWS. In addition to the services described in the PWS, the Contractor is expected to be a partner with the base community in continuously improving the quality of programs and services offered to customers. This QASP is designed to provide the COR with an effective and systematic method of monitoring contractor performance for each listed objective on the Services Summary (SS) in the PWS. This QASP is based on the premise that the contractor, and not the Government, is responsible for management and quality control actions to meet the terms of the contract. The role of the Government is quality assurance to ensure contract standards are achieved. The Government will also rely on the Contractor's existing or developed quality control system to ensure contractual requirements are met. The Contractor is required to develop a comprehensive program of inspections and monitoring actions. The COR is to be objective, fair, and consistent in evaluating the contractor’s performance against the standard.

2. GOALS OF THE MULTI-FUNCTIONAL TEAM

The Government personnel listed in paragraph 3 below will participate in performance management of the Contractor. The goals of the MFT are to manage this contract and to provide an avenue to collectively work together to create a strong working relationship between the using agency, contracting and the contractor and to provide the highest level of contract performance and customer service. Working together will reduce costs and improve contract performance.

Contractor input shall be encouraged throughout the contract. Their roles and responsibilities are described in paragraph 3 below.

3. MULTI-FUNCTIONAL TEAM ROLES & RESPONSIBILITIES.

The following Government personnel will participate in performance management of the Contractor. Their roles and responsibilities are described as follows:

3.1. Contracting Officer’s Representative (COR).

3.1.1. Responsible for monitoring, assessing, recording, and reporting on contractor compliance with the terms and conditions of the contract. A primary and/or alternate COR will be appointed for this contract. The Functional Commander/Director (FC/FD)/COR Supervisor is the designating authority. The COR will have primary responsibility for completing quality assurance monitoring forms that will be used to document the inspection and evaluation of the contractor’s performance. The COR will maintain surveillance documentation and notify the Contracting Officer (KO) or Contract Administrator (CA) of any significant performance deficiencies and recommend improvements to the QASP and PWS throughout the life of the acquisition.

3.1.1.1. The COR will develop a surveillance schedule -- either computer generated or locally revised forms may be used based on the surveillance plan’s requirements. This schedule should indicate contract number, SS number (inspection items) and paragraph numbers of the PWS, and date of inspections. The schedule must be completed before the first day of the surveillance period that it covers, and shall be uploaded to WAWF CORT Tool (https://wawf.eb.mil). The schedule shall be marked “FOR OFFICIAL USE ONLY” and shall not be shown to the contractor. If necessary, the COR’s supervisor will sign the schedule before the schedule will be posted to CORT Tool. The CA will download the schedule from CORT Tool.

3.1.1.2. Changes to the assessment schedule shall be posted promptly. Copies of the changed schedule shall be reposted to CORT Tool for the CA and/or KO’s review. The COR shall document the reason(s) for changes of the assessment schedule, and maintain the documentation in the COR files with the corresponding changed assessment schedule.

3.1.1.3. The COR will conduct inspections of all SS item requirements. The COR may also receive feedback from customers and other Government employees and pass them on to the Contractor's on-site manager(s) for correction. Completion of the surveillance for the month will be signed by the COR. If discrepancies are found during surveillances, the COR Supervisor must sign surveillance documentation for the purpose of oversight.

3.1.1.4. The COR is responsible to conduct, at minimum, quarterly assessments of maintenance performed on contractor-operated, Government-owned equipment and facilities, however, any service contracts under which the contractor is required to perform merely once or twice a year, shall not apply to this rule.

3.1.2. Invoices. Invoice in accordance with WAWF is mandatory per DFAS 252.232-7003 Electronic Submission of Payment Requests and Receiving Reports. The COR will then certify and forward the electrical invoice to DFAS for payment and cc 374 CONS/PKBB. Invoices shall contain the information required by FAR 52.212-4(g).

3.2. Contracting Officer (KO).

The KO will be responsible for monitoring the overall contractor’s performance, including the areas of contract compliance, contract administration, cost control, and property control as well as reviewing the COR assessment of the contractor’s performance and resolving all discrepancies between the COR and the contractor. The KO is the only person with the authority to direct the Contractor in the performance of duties under the contract and to make interpretations of and/or changes to the contract. The KO will facilitate MFT meetings. The KO shall remind requirements personnel, when they are preparing the QASP, to include a requirement for surveillance of the contractor’s implementation of the clause at FAR 52.222-50, Combating Trafficking in Persons (see PGI 222.1703).

3.3. Functional Commander/Director (FC/FD)/ COR Supervisor.

The FC/FD/COR Supervisor is responsible for developing the PWS and the QASP to ensure mission requirements are performance-based, foster innovation, and define metrics. The FC/FD/COR Supervisor will assign competent and capable functional experts and COR(s) to the MFT. The FC/FD/COR Supervisor will nominate a primary and an alternate COR (if necessary) and notify the KO of any changes to this designation and any significant Contractor deficiencies related to the performance of the contract. The FC/FD/COR Supervisor is responsible for identifying mission essential services and developing the necessary documents IAW DoDI 1100.22, Policy and Procedures for Determining Workforce Mix. The FC/FD/COR Supervisor is responsible for reviewing Contractor’s performance documentation prepared by the COR ensuring contract compliance.

3.4. Contracting Squadron Commander (CONS/CC).

The CONS/CC serves as the business advisor to senior leadership, i.e. wing and group commanders. The CONS/CC conducts post-award annual execution reviews, briefing top the 10 contracts in the aggregated amount to the Service Advocate (SA) thru the Service Designated Official (SDO), and annually reports the Health of Services Assessment to the SA thru the SDO.

The CONS/CC ensures the MFT exercises acquisition authorities and responsibilities IAW the Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS), Air Force Federal Acquisition Regulation Supplement (AFFARS), and Air Force instructions. The CONS/CC is responsible for developing and implementing acquisition strategies for services acquisitions; providing oversight of the MFT for planning assessing contractor performance; managing the acquisition throughout the life of the requirement; and, ensuring the MFT receives the appropriate level of training to meet local needs.

3.5. Quality Assurance Program Coordinator (QAPC).

The QAPC develops, manages, and implements the base Quality Assurance Program; supports the MFT in the development of contract requirements, ensuring requirements are clearly stated and enforceable; aids in the development of the Services Summary (SS) and QASP; and, provides training to all COR Supervisor, COR(s) and others (if necessary) that interact with this contract, as needed.

3.6. The Contract Administrator (CA).

The CA is the focal point for issues regarding the contract; prepares and processes modifications to the contract; assists the KO in ensuring Contractor performance meets contract standards; and, records and transcribes minutes for meetings.

3.7. Others as needed.

http://www.acq.osd.mil/dpap/dars/pgi/pgi_htm/PGI222_17.htm

The MFT may include other organizations as deemed necessary.

4. PERFORMANCE ASSESSMENT

4.1. The following SS provides for the performance evaluation required by the PWS.

Performance Objective PWS para

Performance Threshold Method of Inspection

SS#1: Licensure/Certification.

Must have a valid, current unrestricted state license in any one of the 50 states, the District of Columbia, Puerto Rico, or the U.S.

Virgin Islands.

1.2.1.3.

100% Compliance Periodic Inspection (Annually)

SS#2: Performs the full spectrum of services as a staff PT. The PT shall have knowledge of the full range of professional principles and practices of physical therapy.

Deliver comprehensive physical therapy services within the personnel, supply, and equipment capabilities of the facility.

1.2.2.1.

Chief Physical Therapy will review the submitted reports, patient notes

Periodic Inspection (Monthly)

SS#3: Ensures compliance of all physical therapy plan of care is executed by technical staff.

1.2.3.10.

Chief Physical Therapy will review

SS#4: Provide exercise and physical therapy guidelines to the clinical staff as required. 1.2.3.11.

Chief Physical Therapy will review

4.2. The COR will perform inspections to ensure contractor compliance with the appropriate paragraphs of the PWS and will record the date and results of the inspection.

4.3. Assessment documentation shall include, at a minimum, the date, time, and location the assessment was conducted, the results of the assessment (acceptable or unacceptable), PWS paragraph number referencing the requirement, a short description of the requirement being surveyed, applicable remarks, signature of the COR conducting the assessment. When the COR determines contractor performance is unacceptable, the specific reason for the unacceptable performance shall be recorded on the COR’s assessment documentation.

4.4. Methods of Inspection.

4.4.1. 100% Inspection. (reflection of what % is in the Performance Threshold box of your

SS):

Standard: Basically there are no deficiencies allowed for items requiring 100% inspection, thus the COR shall accomplish inspection for all 100% inspection SS. The COR shall notify the KO for appropriate action IAW FAR 52.212-4, Contract Terms and Conditions – Commercial Items or the appropriate inspection of services clause, if there are any failures to perform.

Procedures: The COR shall inspect each task immediately after completion of the task or by the due date, and record the results on the surveillance checklist as acceptable or unacceptable. The contract number, date, PWS paragraph, and COR’s signature will also be annotated on the form.

4.4.2. Periodic Inspection.

Standard: Deficiencies shall not exceed the performance thresholds cited in the SS for each performance objective. The COR shall notify the KO for appropriate action IAW FAR 52.212-4, Contract Terms and Conditions – Commercial Items or the appropriate inspection of services clause, if any of the above service areas exceed the performance thresholds.

Procedures: The COR shall inspect the performance objectives indicated in SS (insert frequency, such as, annually, semi-annually, quarterly, monthly, weekly, etc.) and indicate performance as acceptable or unacceptable. The surveillance documentation should outline the same items indicated on the COR’s surveillance schedule. If during an inspection the COR finds unacceptable service they will conduct an investigation to ascertain the validity and cause of the unacceptable service and notify the Contractor’s contract manager of the findings. Based on the findings, the contract manager may be asked to re-perform. If the contract manager disagrees with the finding and challenges the validity, the COR will contact the KO. The deficiency will be recorded even if correction of the unacceptable condition(s) is accomplished. If a repeated unacceptable service is received indicating the same deficiency during the same service period (month, quarter, etc.), the COR should contact the KO for appropriate action.

4.5. Assessment of Non-SS Items. All other tasks required under the PWS may be inspected on a random basis at a frequency determined by COR Supervisor and the KO.

4.6. Remedies for Non-Conformance. If inspections indicate unacceptable performance, the COR will notify the Contractor of the deficiencies for correction. The Contractor will be given an appropriate time frame (depending on the discrepancy identified) after notification to correct the unacceptable performance. If deficiencies are not corrected within the required time frame, the COR should notify the KO for action. If the Contractor disagrees with the noted discrepancy and an agreement cannot be reached, the KO shall make a final decision. When reperformance is not possible, contract price may be reduced to reflect the reduced value of the services performed.

5. PERFORMANCE MANAGEMENT

5.1. Market Research. Market research will be used as a tool throughout the life of the contract to remain current with the most efficient and effective assessment methods and techniques of the commercial marketplace. As a minimum, market research, if necessary, will be conducted annually prior to exercising the option periods.

5.2. MFT Meetings. The MFT will manage the contract for the life of the contract. This team will form a partnership between the Government and the Contractor to ensure the best possible service is provided for the life of the contract. This team will meet upon exercising contract options, if required. All performance assessment documentation will be reviewed at these meetings. If performance improvement is necessary a plan of action will be created. The MFT will continually review documentation and procedures to improve efficiency. If a MFT is required more often than annually it will be scheduled by the KO.

5.3. COR Performance Assessment. The Contract Administrator will perform quarterly surveillances to ensure contract compliance and proper documentations of COR files, however any service contracts set forth less frequent surveillance requirement do not apply to this rule.

5.4. Contract Performance Assessment Reporting System (CPARS)(it may apply). The COR shall conduct, document, track, and analyze Contractor performance via regularly scheduled assessments. The assessment results shall be maintained as Past Performance Information and utilized to prepare and support annual CPARS reporting. More frequent updates may be made as required to document a significant improvement or degradation of the level of contract performance. The Assessing Official Representative (AOR) or Assessing Official (AO) will be the COR who will also prepare the CPAR document and coordinate with FC/FD/COR Supervisor for concurrence. The Contractor will have input prior to this CPAR being finalized.

The Contractor will select their personnel to serve as Contractor Representatives (CR) to review and comment on the CPAR. The CPAR will be sent to the Reviewing Official (RO) if there is significant disagreement on the CPAR's ratings between the AO/AOR and the CR or if the AO chooses to revise the assessment as a result of the CR's comments. The RO can provide narrative comment (the RO’s comments supplement those provided by the AO; they do not replace the ratings/narratives provided by the AO). The RO must be a Government employee and is usually the KO. It is a best practice to coordinate the CPAR with the KO when the RO is not the KO.

- Only used for the contract over $1 M aggregate.

5.5. Trafficking in Persons. The COR must immediately inform the KO if contractor/subcontractor and/or contractor/subcontractor personnel fail to comply with the requirements of FAR 52.222.50, and the KO shall take actions IAW Defense COR Handbook on Combating Trafficking in Persons: http://www.acq.osd.mil/dpap/cpic/cp/docs/USA001390- 12_DoD_COR_Handbook_Signed.pdf.

6. REVISIONS TO THIS QUALITY ASSURANCE SERVEILLANCE PLAN

Revisions to this QASP are the joint responsibility of the FD/FC/COR Supervisor, KO, and COR. The COR reviews the PWS and QASP annually and will provide proposed changes, if http://www.acq.osd.mil/dpap/cpic/cp/docs/USA001390-12_DoD_COR_Handbook_Signed.pdf http://www.acq.osd.mil/dpap/cpic/cp/docs/USA001390-12_DoD_COR_Handbook_Signed.pdf necessary, through the FC/FD/COR Supervisor to the MFT for review. This is a living document that can be changed at any time if the overall scope of the contract does not change.

Appendix A Sample 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 B Sample Customer Complaint Log

Date Customer Name ORGN/Phone

Number Complaint

Section Referred to & Date

Complaint: