Attachment 5 - QASP dtd 6.1.22 - Redline.pdf

ATTACHMENT5: QASP

RFQ 70CMSD22R00000003

QUALITY ASSURANCE SURVEILANCE PLAN

Department of Homeland Security, U.S. Immigration and Customs Enforcement Office of the Principal Legal Advisor

PLAnet Administrative Support Services for the Principle Legal Advisor’s Network (PLAnet)

June 1, 2022

QUALITY ASSURANCE SURVEILANCE PLAN (QASP)

Administrative Support Services

For PLAnet

1. Introduction This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the contract administrative support services for PLAnet. This plan sets forth the procedures and guidelines that the government will use in evaluating the technical performance of the service contractor.

1.1. Purpose

This QASP describes the procedures that Immigration and Customs Enforcement (ICE) will use to monitor and evaluate contractor performance. The QASP focuses on examining the contractor’s service results and not the underlying processes to produce them.

This QASP provides a means to evaluate whether the contractor meets performance standard levels per the Performance Work Statement (PWS) and the contractor’s Quality Assurance (QA) plan and to ensure that the government pays on for the level of service it receives.

1.2. Performance Management Strategy

The contractor is responsible for the quality of all work it performs. The contractor measures that quality through the contractor’s QA plan. The contractor’s QA Plan sets forth staffing and procedures for self-inspecting quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the PWS. This QASP outlines the roles, responsibilities, and surveillance methodologies that the Government will undertake to ensure that the Contractor complies with its QA Plan.

Government representative(s) will monitor performance and review performance reports the contractor furnishes to determine how the contractor is performing against contractual performance objectives.

The contractor will be responsible for making changes in processes and practices to ensure effective performance management.

1.3. Revisions to the QASP

The QASP is a tool for use in Government administration of the contract and remains subject to revision at any time by the Government throughout the contract performance period. Revisions to this surveillance plan are the responsibility of the Contracting Officer (CO) or designee. The Government may make changes to the QASP, via a bilateral modification to the contract.

2. Roles and Responsibilities

The purpose of the QASP is to ensure that the Government receives satisfactory services from the contractor and to ensure that the contractor meets its contractual obligation to ICE. Roles and responsibilities of contractor and Government stakeholders are below.

2.1. Contractor Responsibility

The contractor is responsible for delivering services in accordance with the contract. The contractor is responsible for implementing its QA plan. The QA plan describes the contractor’s methods for ensuring all products and services it provides under the contract meet established performance standards and Acceptable Quality Level (AQL) s.

2.2. Government Responsibility

This section of the QASP briefly defines the duties and responsibilities of key Government personnel involved in contract administration and quality assurance. The key personnel who will be responsible for QASP input is the Contracting Officer’s Representative (COR) and alternate COR.

2.2.1. Contracting Officer

The CO has overall responsibility for ensuring performance of all necessary actions for effective contracting, ensuring compliance with terms and conditions of the contract, and safeguarding the interests of the US Government. The CO has the authority to administer the contract but may delegate many of the day-to-day contract administration duties to the COR. The CO is the only individual with the authority to:

• Negotiate and issue contract modifications

• Resolve contractor claims and disputes

• Issue cure notices

• Issue show-cause letters

• Terminate the contract

• Conduct contract close-out functions

The CO is responsible for monitoring contract compliance, contract administration and cost control. The CO is responsible for resolving any differences between the observations documented by the COR and the Contractor. The CO will designate a COR as the government authority for performance management.

2.2.2. Contracting Officer’s Representative (COR)

The COR is a federal employee the CO designates by name and/or position to act as a liaison between the government and the contractor on all issues pertinent to the daily operation of the contract. The COR represents the CO and, therefore, is the contractor's initial point-of-contact with the government.

• COR executes his/her duties in accordance within the scope and limitations in their written appointment letter

• COR does NOT have authority to make any contractual commitments or to authorize any contractual changes on the Government’s behalf. contractor shall refer any changes that may affect contract price, terms, or conditions to the CO for action

• COR will assist the CO in preparing and negotiating contract modifications

• COR will inform the contractor of any problems and recommend to the CO that adverse contractual actions are appropriate (e.g., cure notice) if the contractor fails to correct the problem

• COR is responsible for technical administration of the project and ensures proper Government surveillance of the contractor’s performance

• COR will have responsibility for completing QA monitoring forms used to document 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 or under the inspection of supplies clause for any fixed price supplies relating to the contract

• COR will verify acceptance of services and validate invoices for payment

3. Performance Description

The PWS outlines performance standards and quality levels. If the contractor does not meet requisite performance levels, the contractor will be asked to re-perform the task.

The government will monitor performance of the contractor through various surveillance methods within Section 4: Methods of Surveillance. The Government will evaluate performance data to assess the Contractor performance against contract requirements.

3.1. Performance Standards and Acceptable Quality Levels (AQL)

The contract requires the contractor to perform all work as specified. “Defects” are any inaccuracies or omissions in services by the contractor. The contractor is responsible for all identified defects, and ICE may require the contractor to re-perform the work at no additional cost.

AQLs take into account that in some instances an allowable level of deficiency is possible while overall performance continues to meet ICE’s desired level of service. AQLs define the level of performance deficiencies tolerable under this contract. They take into account the difference between an occasional defect and a gross number of defects. AQLs can be expressed as a percentage of or as an absolute number.

A contract requirement can consist of several subtasks. The government may determine that a contract requirement is partially complete if the contractor satisfactorily completes some, but not all, of the work requirements. In those cases, adjustments may still be taken from the contractor’s invoice. In addition to all of the rights the Government may have, the Government may make adjustments for work that is partially complete.

3.2. Non-performance

Non-performance occurs when the contractor’s performance does not meet the AQL for a given requirement. Requirements may contain multiple performance elements; therefore, deficiencies may occur in one or more aspects of performance (e.g., timeliness, accuracy, completeness) or subject areas of effort.

When surveillance indicates that the contractor’s service output is not in compliance with contract requirements, the COR must determine whether the contractor or government caused the deficiency. If the cause of the defect rests with the government, corrective action must be taken through government channels. If the cause of the defect is due to action or inaction by the contractor, the contractor is responsible for correction of the problem at no increase additional cost to the government. The CO may adjust all amounts associated with such non-performed work from the contractor’s invoice. The CO may afford the contractor an opportunity (subject to CO discretion) to accomplish non-performed work within a reasonable period.

4. Methods of Surveillance

Surveillance methods within the QA process are tools the government uses to monitor contractor services. The best means of determining whether the contractor has met all contract requirements is to inspect the contractor’s service and analyze the results. Further, documented inspection results are an effective tool in contract administration. Inspections either confirm the contractor’s successful achievement of all performance requirements or highlight areas where defects exist and improvements are necessary. In an effort to minimize the performance management burden, the Government will use simplified surveillance methods to evaluate contractor performance when appropriate. The primary methods of surveillance are:

• Customer feedback

• Periodic inspections

• Random observations

• File review

• As required

The government may reduce the number of inspections in those instances where the contractor establishes a record of good performance. In cases of poor performance, ICE may increase the level of surveillance and focus on known problem areas.

5. Analysis of Quality Assurance Assessment

The government will report its QA surveillance using the monitoring form in Attachment 2. The government will document all work activities it observes to include both acceptable performance and non-performance. Thorough documentation of unperformed or poorly performed work is essential for tracking contractor performance throughout the period of performance. The COR will document deficient work by compiling facts describing the inspection methods and results. The COR shall develop documentation to substantiate non-conformance with the contract and shall further decide whether to elevate the problem to the CO for corrective action.

The COR will prepare a written report for the CO which summarizes overall results of the quality assurance surveillances. This written report, which includes the completed quality assurance monitoring forms (Attachment 2), will become part of the QA documentation and will enable the government to demonstrate whether the contractor is meeting performance standards, including cost/technical/ scheduling objectives.

5.1. Reviews and Resolution

Upon completion of the inspections, the COR will perform an analysis of the contractor’s performance.

The purpose of the analysis is to ensure that ICE is receiving high-quality services from the contractor.

Analysis of all types of contract monitoring will result in one of the following outcomes:

• Satisfactory performance

• Marginal performance

• Unsatisfactory performance

5.1.1. Satisfactory Performance

The contractor’s performance is satisfactory when it meets AQLs and deficiencies are correctable without adverse impact to mission accomplishment or activities. Any deficiencies are identified and corrected by the contractor and within the timeframe specified by ICE.

5.1.2. Marginal Performance

The contractor’s performance is marginal when assessment of tasks and sub-tasks reflect a potentially serious problem for which the contractor has not yet identified corrective actions, or its proposed corrective actions appear only marginally effective or were not fully implemented.

5.1.3. Unsatisfactory Performance

The contractor’s performance is unsatisfactory when performance for any service does not meet the AQL. The following responses are available to the COR and CO regarding that task/subtask:

• CO and/or COR meet with the contractor to discuss discrepancies, trends, complaints, and intended corrective measures

• COR increases the level of surveillance until the contractor demonstrates acceptable performance over a period

• COR issues a contract discrepancy report for each service that does not meet its AQL

• Should deficiencies be significant and affect multiple requirements, CO action such as a ‘Cure’ notice may be appropriate

• CO may deduct all amounts associated with such non-performed work from contractor’s invoice.

CO may afford contractor an opportunity (subject to CO discretion) to accomplish non-performed work within a reasonable period

• CO may employ Government personnel or other means (e.g., reducing the price under this contract to fund another contractor) to perform the services

5.1.4. Remedial Action

The Federal Acquisition Regulation (FAR) allows for remedies if the contractor fails to perform the requisite services. The FAR regulations that detail those remedies can be found in the following section of the FAR: 52.212-4–Contract Terms and Conditions-Commercial Items, Alternate 1 (Jan 2017).

The CO must coordinate and communicate with the contractor to resolve issues and concerns regarding marginal or unacceptable performance. The CO will give the contractor written or verbal notice (followed up with a written notice) of deficiencies prior to deducting for non-performance or unsatisfactory work.

6. Performance Requirements Summary

The Performance Requirements Summary (PRS) table summarizes specific work scope that the contractor performs under this contract.

Attachment 1: Performance Requirement Summary

Performance Requirements Summary

Assessment Frequency A – Annually

M – Once per month W – Once per week

R – As required

Method of Surveillance PI – Periodic Inspections

RO – Random Observations FR – File Review

CF – Customer Feedback R – As Required

Assessment Rating Rating with Description Percent Rating

Satisfactory:

The Contractor demonstrates a level of performance and quality that meets all performance objectives and standards. QC Plan is acceptable; however, there have been some discussions of management and quality control. Customer needs are predominantly met. 90 to 100

Marginal:

The Contractor demonstrates a level of performance and quality that meets most but not all performance objectives and standards. Periodic input required from the Government to initiate corrective action. QC Plan is adequate with Government reminders. Customer needs are usually met. 80 to 89.9

Unsatisfactory:

The Contractor demonstrates a level of performance and quality that fails to meet many performance objectives and standards and/or those that have a substantial impact on quality. The Contractor’s performance is inadequate or inferior with an excessive number of inconsistencies. Substantial input is required from the Government to acquire corrective actions. QC plan documentation and preventive actions are inadequate. Customer feedback indications are unsatisfactory. Below 80

Performance Objective Performance Standard Acceptable Quality Level Method of

Surveillance Frequency Assessment Rating

1.6.1. Mail

Management: Tasks shall be accurately completed the same day they are received.

Paragraph 1.6.1 All incoming and outgoing mail shall be processed the same day it is received.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

FR, PI, RO

& CF R

1.6.1.(a) Receive, open, date stamp, sort, and distribute in-bound mail.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

FR, PI, RO

& CF R

1.6.1. (b) Handle out-bound mail.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

FR, PI, RO

& CF R

1.6.1. (c) Reroute misdirected mail.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

FR, PI, RO

& CF R

1.6.1 (d) File correspondence in case files.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

FR, PI, RO

& CF R

1.6.1 (e) Create mailing labels using appropriate commercial accounts.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

FR, PI, RO

& CF R

1.6.2. File

Management.

Tasks in this section shall be completed within the specified time frame unless otherwise requested.

1.6.2. (a) Shelve/re-shelve files as appropriate

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

FR, PI, RO

& CF R

1.6.2. (b) Route files as appropriate.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

Surveillance Frequency Assessment Rating

1.6.2. File

Management (Cont.).

Tasks in this section shall be completed within the specified time frame unless otherwise requested.

1.6.2. (c) Request, obtain, and deliver files from other units, sections, and/or offices.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. (d) Respond to internal and external file requests.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. (e) Pull and sort files upon request.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. (f) Prepare files upon request in accordance with established office procedures.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. (g) Utilize RAILS to locate files and for internal and external file transfers.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. (h) Conduct searches for files as needed.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. (i) Assist with file audits.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. (j) Assist with Freedom of Information Act (FOIA) requests.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.2. File

Management (Cont.).

1.6.2. (k) Receive, process, and return files from/to other DHS agencies.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.3. Records

Management.

Tasks in this section require compliance with the appropriate regulation.

1.6.3. (a) Per local office procedures, route or file materials that concern legal or specialized matters (e.g., briefs, correspondence, exhibit packets).

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.3. (b) Comply with ICE and NARA (National Archives and Records Administration) General Records Schedule document retention standardization policy and procedures.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.4. Clerical

Support.

Tasks in this section shall be completed within three business days unless otherwise requested.

1.6.4. (a) Research, identify, review, and select relevant documents and other materials – including electronic data and records; organize documents;

number documents; create box or file level indices; capture document images; copy documents; prepare documents for production; develop and document procedures; and perform quality control.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.4. (b) Enter/upload data into PLAnet (OPLA’s electronic alien file repository), including but not limited to the recording

1.6.4. Clerical

Support. (Cont.)

Tasks in this section shall be completed within three business days unless otherwise requested.

of receipt of motions, notices of appeal, briefing schedules, court decisions.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

& CF

R

1.6.4. (c) Download information from databases upon request (e.g., docket information, case status information, etc.).

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.4. (d) Create and prepare Microsoft Excel spreadsheets, logs, and Microsoft PowerPoint presentations related to PLAnet.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.4. (e) Perform other administrative duties as assigned.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.5. E-Service.

Tasks in this section shall be completed same day as received.

1.6.5. (a) Check E-Service daily for incoming documents.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.5. (a)(1) Review attachments for correct identification criteria.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.5. (a)(2) Save to PLAnet.

100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.5. (a)(3) Route to appropriate Deputy or other

POC.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

Surveillance Frequency Assessment Rating

1.6.5. E-Service.

(Cont.)

1.6.5. (b) Create and prepare Microsoft Excel spreadsheets, logs, and Microsoft PowerPoint presentations related to PLAnet.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.6.6. Document

Scanning.

Tasks shall be completed within three business days.

1.6.6. (a) Scans shall be clear, accurate, and correct orientation.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.7. Management

Reports

1.7. (a) The Contractor shall be responsible for reporting progress on tasks. The COR will require a variety of monthly progress reports and status reports.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.7. (b) All reports must be generated in a timely fashion.

Report deadlines will be specified by the COR. Face to face Meetings may be required to discuss reports and project status. Fiscal reporting must conform to the government’s fiscal year.

90% accuracy and correctable to 100% accuracy. Any deficiencies

1.7. (c) All reports described in this section are considered part of overall project management.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.7. (d) The Contractor shall establish and maintain appropriate tracking systems which shall enable it to prepare

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.7. Management

Reports and submit the management reports required.

1.7. (d) (1) Monthly recruiting – this report will identify each candidate and their status in the recruitment process. Key dates shall be noted on the report.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.7. (d) (2) Monthly retention report – this report will identify all Contractors working on the contract, entry on duty date, departure date for anyone who terminated employment during the month, and any anticipated dates of long-term absences.

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

1.7. (d) (3) Monthly contract status report – this report will be prepared by the project manager and provide monthly updates on areas of concerns or problems in the contract, if any; personnel conflicts, replacements, accolades, etc. This report may include suggestions for improving productivity or performance.

100% accuracy. Any deficiencies

1.7. (d) (4) Bi-weekly communication dashboard report – this report will be prepared by the project manager and provide a bi-weekly update on any significant events or changes the current status report

90% accuracy and correctable to 100% accuracy. Any deficiencies shall be corrected and resubmitted by the contractor.

ATTACHMENT 2: SAMPLING GUIDE/QUALITY ASSURANCE

MONITORING FORMS/INSPECTION CHECKLIST

SERVICE or STANDARD: _____________________________________________________________

SURVEY PERIOD: ___________________________________________________________________

SURVEILLANCE METHOD: ____________________________________________________________

LEVEL OF SURVEILLANCE (Check):

Monthly Quarterly As needed

PERCENTAGE OF ITEMS SAMPLED DURING SURVEY PERIOD: ______ %

ANALYSIS OF RESULTS:

NOTE:

S = Satisfactory Performance M = Marginal Performance U = Unsatisfactory Performance N/A = Not Applicable Performance

PRS Requirements Timeliness Quality of Work Comments

Narrative of performance during survey period: __________________________________________

Prepared by: __________________________________________ Date: _________________

Contractor Signature: ___________________________________ Date: _________________