Attachment 6 - QASP SE PM.doc

Department of Homeland Security

Regional Maintenance and Repair Contract for the Southeast Region

Customs and Border Protection

Border Patrol Facilities and Tactical Infrastructure Quality Assurance Surveillance Plan January 2023 Table of Contents

11.

INTRODUCTION

22.

DEFINITIONS

33.

QUALITY CONTROL PLAN

44.

METHODS OF SURVEILLANCE

55.

FUNCTIONAL PERFORMANCE AREAS AND STANDARDS

66.

FAILURE TO MEET PERFORMANCE STANDARDS

77.

NOTIFICATIONS

88.

COMPLAINTS

99.

ATTACHMENTS

10Attachment 1—Performance Requirements Summary (PRS)

14Attachment 2 – Contract Discrepancy Report (CDR)

15Attachment 3 – Contract Performance Monitoring Tool

QUALITY ASSURANCE SURVEILLANCE PLAN

For the

Southeast Regional Maintenance and Repair Contract

1. INTRODUCTION

The Government’s Quality Assurance Surveillance Plan (QASP) is based on the premise that the contractor, and not the Government, is responsible for the preventive and remedial maintenance of the designated equipment, as well as all the management and quality control actions required to meet the terms of the contract. The role of the Government in quality assurance is to ensure performance standards are achieved and maintained. The contractor is required to develop a comprehensive program of inspections and monitoring actions and to document its approach in a Quality Control Plan (QCP). The contractor’s QCP, upon approval by the Government, will be made a part of the resultant agreement.

This QASP is designed to provide an effective surveillance method to monitor the contractor’s performance relative to the requirements listed in the agreement. The QASP illustrates the systematic method the Government will use to evaluate the services the contractor is required to furnish.

This QASP is based on the principle that the Government must validate that the contractor is complying with quality standards in providing preventive and remedial maintenance. Performance standards address all facets of preventive and remedial maintenance, etc. Good maintenance management by the contractor and use of an approved QCP will ensure that the facility is operating within acceptable quality levels (AQL).

Revision Tracking

2. DEFINITIONS

Performance Requirements Summary (Attachment 1): The Performance Requirements Summary (PRS) depicts the work and results that the Government intends to qualitatively inspect. The PRS is based on:

1. The Code of Federal Regulations

2. GSA PBS Public Building Maintenance Standards, January 2022

3. American National Standard Institute

4. American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE)

5. National Fire Protection Association (NFPA) Standards and Codes

6. American Society of Mechanical Engineers (ASME)

7. National Electric Institute

8. National Fire Protection Agency

9. Environmental Protection Agency

10. International Electrical Code

11. International Building Code

12. International Fire Code

13. International Plumbing Code

14. International Mechanical Code

15. All rules and regulations governing usage of firearms, public buildings and grounds.

16. All regulations and guidelines provided to the contractor through the COR.

The PRS identifies performance standards grouped into four functional areas, and quality levels essential for the successful performance of each requirement. The PRS is used by the Government (or its designated representative) when conducting quality assurance surveillance to guide the COR and his/her designees through the inspection and review processes for assessing compliance in meeting Government and industry standards.

Functional Area: A logical and consistent grouping of performance standards.

Contracting Officer’s Representative (COR): The COR or his/her designee in the field, interacts with the contractor to inspect and accept services/work performed in accordance with the technical standards prescribed in the agreement. The Contracting Officer (CO) issues a written memorandum or certificate that appoints the COR. Other individuals may be designated to assist in the inspection and quality assurance surveillance activities.

Performance Standards: The performance standards are established and/or defined in the contract, its Performance Work Statement and this QASP. Other standards that are specific to equipment maintenance and remedial repair services are stated in this document.

Measures: The method for evaluating compliance with the standards.

Acceptable Quality Level: The minimum level of quality that will be accepted by the Government in order to meet the performance standard.

Withhold: Amount of monthly invoice payment withheld pending correction of a deficiency. See Attachment 1 for information on percentage of invoice amount that may be withheld for each functional area. Funds withheld from payment are recoverable (See Sections 7 and 8) if the COR and CO confirm resolution/correction and should be included in the next month’s invoice.

Deduction: Funds may be deducted from a monthly invoice for an egregious act or event, or if the same deficiency continues to occur. The contractor will be notified immediately if such a situation arises. The CO in consultation with the Program Office will determine the amount of the deduction. Amounts deducted are not recoverable. The assessment of deductions does not preclude the CO from initiating other applicable contract actions and remedies, if applicable.

3. QUALITY CONTROL PLAN

As a part of its agreement with the Government, the Contractor is required to develop, implement, and maintain a Quality Control Plan (QCP) that describes the methods it will use to ensure compliance with performance requirements. Such reviews are performed by the contractor in order to validate its operations and assure the Government that the services meet the performance standards.

The Contractor’s QCP shall include monitoring methods that address inspection methods and schedules consistent with the regular reviews conducted by CBP. The reports and other results generated by the Contractor’s QCP activities shall be provided to the COR. Reporting requirements are identified in the Performance Work Statement (PWS).

The frequency and type of the Contractor’s reviews should be consistent with what is necessary in order to ensure compliance with the performance standards, but no less frequent than what is described in the Government’s monitoring instrument/worksheets (See Attachment 3).

The Contractor’s QCP is not limited to the processes outlined in Attachment 3 or the Performance Metrics specified in PWS; however, the Required Plans, Records, Reports and Additional Requirements Section C.5.2. presented in PWS must be produced by the Contractor to assure the Government that the services meet the performance standards. Also, some of the documentation that must be generated and made available to the COR for inspection is listed below. The list is intended to be illustrative but is not all-inclusive. The Contractor must develop and implement a program that addresses the specific requirement of each standard and the means it will use to document compliance.

· Written policies and procedures to implement and assess operational requirements of the standard

· Documentation and record keeping ensuring ongoing operational compliance with the standards (e.g.; records, logbooks, repair records, hazardous material disposal records, register of receipts, reports, etc.)

· Staff training records

· Contract discrepancy reports (CDRs) and records of investigative and/or corrective actions taken, if applicable.

· Equipment inspections / Maintenance Logs

· Safety and environmental inspection reports

· Quality Control inspection reports

· All other documentation needed to evaluate the effectiveness of the Contractor’s QCP, as deemed appropriate by the Government.

4. METHODS OF SURVEILLANCE

The Government will inspect the Contractor’s operations using worksheets it developed for this purpose. All work will be subject to an annual complete review of the contract. The Government’s program review will utilize the key performance indicators (KPIs) or performance measures identified in the PWS (see Section C.5.1).

The COR or designee will evaluate the Contractor’s performance by (a) conducting site visits to assess the equipment maintenance conditions, (b) reviewing program documentation and reporting and (c) interviewing Contractor personnel. NOTE: For day-to-day activities, the Government will conduct its surveillance using the worksheets created for this purpose, along with the Contract Deficiency Reports (See Attachment 2) and the “Contract Performance Monitoring Tool” set forth in Attachment 3.

4.1 Site Visits: Site visits are used to observe actual performance and to conduct interviews to determine the extent of compliance with performance standards, and to ensure any noted defects are effectively addressed and corrected as quickly as possible. Facility Locations will have an on-site Field COR designee. Routine reviews may involve direct observation of the Contractor personnel performing tasks, interacting with residents and other staff members, and/or reviewing documentation that demonstrates compliance with the CBP standards. On-site inspections may be performed by the Field CBP COR or by other parties designated as representatives of CBP. Inspections may be planned (e.g., annual inspections and the regularly scheduled inspections identified in Attachment 3) or ad-hoc.

4.2 Ad-Hoc: These inspections are unscheduled and will be conducted as a result of special interests or unexpected conditions arising from routine monitoring of the Contractor’s QCP, an unusual occurrence pertaining to the agreement or other CBP concerns. These inspections may also be used as a follow-up to a previous inspection. Inspection findings will be provided to the Contractor as appropriate.

When visiting a site, either the COR or a designated third party may conduct their own inspections of Contractor performance activities or accompany the Contractor’s designated Quality Control Inspector (QCI) on scheduled inspections. The COR may also immediately inspect the same area as soon as the QCI has completed the quality control inspection to determine if any surveillance areas were overlooked. The COR may also inspect an area prior to the QCI and compare results. The COR will record all findings; deficiencies noted will be provided in writing and must be corrected within a reasonable amount of time (See Attachment 2).

4.3 Review of Documentation: The Contractor must develop and maintain all documentation as prescribed in the performance standards (e.g., maintenance logs, policies, and records of corrective actions). In addition to the documentation prescribed by the standards, the Contractor must also develop and maintain documentation that demonstrates the results of its own inspections as prescribed in its QCP. The COR will review both forms of documentation to affirm that the maintenance, policies/procedures, and handling of equipment all conform to the performance standards stated herein. When reviewing the Contractor’s documentation, the Government may review 100% of the documents, or a representative sample. Documentation may be reviewed during a site visit, or at periodic points throughout the period of performance.

4.4 Interviews and Other Feedback: The COR may interview key members of the Contractor’s staff, location employees, subcontractors (with the Contractor being present), and other Government personnel to ascertain current practices and the extent of compliance with the performance standards.

5. FUNCTIONAL PERFORMANCE AREAS AND STANDARDS

To facilitate the performance review process, the required performance standards are organized into four functional areas corresponding to the requirements / KPIs in the PWS. The Government will withhold a portion of payment for a functional area if the Contractor’s fails to achieve a satisfactory rating in that specific area. Payment withholds will be based a percentage for the applicable functional area as applied to the overall monthly invoice. Refer to Section 6 of this document for more information.

CBP may, consistent with the scope the agreement, unilaterally change the functional areas and associated standards affiliated with a specific functional area. The CO will notify the Contractor at least thirty (30) calendar days in advance of implementation of the new standard(s). If the Contractor is not provided with the notification, adjustment to the new standard must be made within thirty (30) calendar days after notification. If any change affects pricing, the Contractor may submit a request for equitable price adjustment in accordance with the “Changes” clause in the contract. CBP reserves the right to develop and implement new inspection techniques and instructions at any time during performance without advance notice to the Contractor, so long as the standards are not more stringent than those being replaced, unless agreed upon by the parties.

6. FAILURE TO MEET PERFORMANCE STANDARDS

Performance of services in conformance with the PRS standards is essential for the Contractor to receive full payment as identified in the agreement. The CO may take deductions against the monthly invoices for unsatisfactory performance documented through surveillance of the Contractor’s activities gained through site inspections, reviews of documentation (including monthly QCP reports), interviews and other feedback. As a result of CBP’s surveillance, the Contractor will be assigned one of following rating relative to each performance standard:

Ratings Definitions Using the above standards as a guide, the CO may withhold payment of a portion of the Contractor’s next monthly invoice. The portion would be determined by the ratings and penalties as prescribed in Attachment 1.

As an alternative to withholding payment until a deficiency is corrected, there may be times when the situation leading to either a “Deficient” rating or an “At Risk” rating is egregious that the Government deducts (vs. “withholds”) amounts from the Contractor’s next monthly invoice, as described in Attachment 1. The deduction may be a one-time event, or may continue until the Contractor has either corrected the cause of the “Deficient” rating or an “At Risk” rating, or the contract has made substantial progress toward the correction.

Further, a deficiency found in one functional area may tie into another. If an equipment failure, for example, resulted in a deficiency it would be noted in “Equipment Maintenance and Repair Services,” but it may also relate to a deficiency in the area of “Personnel” on the grounds of competency

7. NOTIFICATIONS

(a) Based on the inspection of the Contractor’s performance, the COR will document instances of deficient or at-risk performance (e.g., noncompliance with the standard) using the CDR form located at Attachment 2. To the extent practicable, issues should be resolved informally, with the COR and Contractor working together. When documentation of an issue or deficiency is required, the procedures set forth in this section will be followed.

(b) When a CDR is required to document performance issues, it will be submitted to the Contractor with a date when a response is due. Upon receipt of a CDR, the Contractor must immediately assess the situation and either correct the deficiency as quickly as possible or prepare a corrective action plan. In either event, the Contractor must return the CDR with the action planned or taken noted. After the COR reviews the Contractor’s response to the CDR including its plan/remedy, the COR will either accept plan or correction or reject the correction/plan for revision and provide an explanation. This process should take no more than one (1) week. The CDR should not be used as a substitute for quality control by the Contractor.

(c) The COR and CO, in addition to any other designated CBP official, shall be notified immediately in the event of all emergencies that have an impact upon the Contractor’s performance and operations. Emergencies include, but are not limited to the following: work strikes, injuries requiring medical attention; fires; full or partial lock down of the facility; weapons discharge; suicide attempts; deaths; adverse incidents that attract unusual interest or significant publicity; adverse weather (e.g., hurricanes, floods, ice/snow storms, heat waves, tornadoes); fence damage; power outages; bomb threats; significant environmental problems that impact the facility operations; transportation accidents (airlift, bus, etc.) resulting in injuries, death or property damage; and sexual assaults. Note that in an emergency situation, a CDR may not be issued until an investigation has been completed.

(d) If the COR concludes that the deficient or at-risk performance warrants a withholding or deduction, the COR must include the CDR in its monthly report to his / her CBP FM&E higher management, with a copy to the CO. The CDR must be accompanied by the COR’s investigation report and written recommendation for any withholding. If contractual action including a withholding or deduction is appropriate, the COR will forward the CDR and supporting information to the CO for action. The CO will consider the COR’s recommendation and forward the CDR along with any relevant supporting information to the Contractor in order to confirm or further discuss the prospective cure, including the Government’s proposed course of action. As described in Section 6 above, portions of the monthly invoice amount may be withheld until such time as the corrective action is completed, or a deduction may be taken

(e) Following receipt of the Contractor’s notification that the correction has been made, the COR may re-inspect the facility and/or equipment. Based upon the COR’s findings, he/she will recommend that the CO continue to withhold a proportionate share of the payment until the correction is made, or accept the correction as final and release the full amount withheld for that issue. The COR will maintain a record of all open and resolved CDRs.

8. COMPLAINTS

Any complaints made known to the COR will be logged and forwarded to the Contractor for remedy. Upon notification, the Contractor will be given a pre-specified number of hours after verbal notification from the COR to address the issue. The Contractor shall submit documentation to the COR regarding the actions taken to remedy the situation. If the complaint is found to be invalid, the Contractor shall document its findings and notify the COR.

9. ATTACHMENTS

Attachment 1—Performance Requirements Summary (PRS)

SURVEILLANCE

2. Quality of Preventive Maintenance

3. Timely Reschedule Requests

4. Timely and Accurate Web-based tracking

5. Inventory management

· Equipment Validation Report

· Annual review of Preventive Maintenance Program based on the PWS Section C.5.1. following the Contract Performance Monitoring Tool format (see Attachment 3)

· Annual Client Satisfaction Survey

· Monthly Preventive Maintenance Reports

· Maintenance Logs and Records

· Inoperable Equipment Report

· Site inspections

· Contractor employee interviews

· Review of Contractor’s Quality Control Plan monitoring reports

· Cost savings through use of warranties

· CDRs and Monthly review of corrective action plan results.

· Ad-hoc reviews as needed

A rating of At-Risk on any of the evaluation factors will result in a 5.0% deduction in the next monthly invoiced amount until compliance with the evaluation factor is established.

SURVEILLANCE

2. Quality repairs

3. Inventory management

· Equipment Validation Report

· Annual review of Preventive Maintenance Program based on the PWS Section C.5.1. following the Contract Performance Monitoring Tool format (see Attachment 3)

· Annual Client Satisfaction Survey

· Monthly Preventive Maintenance Reports

· Maintenance Logs and Records

· Inoperable Equipment Report

· Site inspections

· Contractor employee interviews

· Stock control lists

· Review of Contractor’s Quality Control Plan monitoring reports

· Cost savings through use of warranties

· CDRs and Monthly review of corrective action plan results.

· Ad-hoc reviews as needed

A rating of At-Risk on any of the evaluation factors will result in a 5.0% deduction in the next monthly invoiced amount until compliance with the evaluation factor is established.

SURVEILLANCE

Administration and Management / 20%

(Addresses general administration, organizational and management requirements)

1. Monitor Quality Control

2. Web-based tracking system/CMMS

· Annual Health and Safety Plan

· Annual Subcontractor Management Plan

· Annual review of Quality Control Plan conducted based on the PWS Section C.5.1. following the Contract Performance Monitoring Tool format (see Attachment 3)

· Annual Client Satisfaction Survey

· Weekly and Monthly Progress Reports/Meetings Hosted (including ad hoc reviews)

· Ease of use of web-based system

· Cost savings through use of warranties

· CDRs and Monthly review of Corrective Action Plan results.

A rating of At-Risk on any of the evaluation factors will result in a 3.0% deduction in the next monthly invoiced amount until compliance with the evaluation factor is established.

SURVEILLANCE

Personnel / 10%

(Addresses Contractor responsibility in areas of hiring and retention, competency, promptness, appearance, behavior and integrity)

1. Employee conduct standards

2. Performance of project team, including subcontractors

3. Timeliness of Background Investigation Processing

· Annual Management Plan

· Annual review of Preventive Maintenance Program based on the PWS Section C.5.1. following the Contract Performance Monitoring Tool format (see Attachment 3)

· Annual Client Satisfaction Survey

· Hiring and attrition rates

· CDRs

· Ad-hoc reviews as needed

A rating of At-Risk on any of the evaluation factors will result in a 2.0% deduction in the next monthly invoiced amount until compliance with the evaluation factor is established.

Attachment 2 – Contract Discrepancy Report (CDR)

DATES

CONTRACTOR NOTIFICATION:

4. DISCREPANCY OR PROBLEM (Describe in Detail: Include reference in PWS / Directive: Attach continuation sheet if necessary.)

5. SIGNATURE OF CONTRACTING OFFICER’S REPRESENTATIVE (COR):

6. TO: (COR)

7. FROM: (Contractor)

8. CONTRACTOR RESPONSE AS TO CAUSE, CORRECTIVE ACTION AND ACTIONS TO PREVENT RECURRENCE. ATTACH

CONTINUATION SHEET IF NECESSARY. (Cite applicable Q.A. program procedures or new A.W. procedures.)

9. SIGNATURE OF CONTRACTOR REPRESENTATIVE:

10. DATE:

11. GOVERNMENT EVALUATION OF CONTRACTOR RESPONSE/RESOLUTION PLAN: (Acceptable response/plan, partial acceptance of response/plan, rejection: attach continuation sheet if necessary)

12. GOVERNMENT ACTIONS (Payment withholding, cure notice, show cause, other.)

CLOSE OUT

CONTRACTOR

NOTIFIED

COR

CONTRACTING

OFFICER

Attachment 3 – Contract Performance Monitoring Tool

Preventive Maintenance Program

Facility Name: __________________ Month/Year:______

1. Preventive Maintenance

Preventive Maintenance Program

Facility Name: __________________ Month/Year:______

2. Repair Services

Contract Performance Monitoring Tool

Facility Name: _____________ _ Month/Year: _______

Frequency

3. Administration and Management

Contract Performance Monitoring Tool

Facility Name: _____________ _ Month/Year: _______

Frequency

4. Personnel

� D – Daily W – Weekly M – Monthly Q – Quality SA – Semi-Annually A – Annually

� D – Daily W – Weekly M – Monthly Q – Quality SA – Semi-Annually, A – Annually

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