Amendment_2_-_Attachment_J.5.A.1__Eastern_Region_Site_Verification_Services_TO_SOW_Attachment_1_QASP.docx

Quality Assurance Surveillance Plan (QASP)

Eastern Region Site Verification Services

03/22/2018 Version 1.0

Quality Assurance Surveillance Plan (QASP)

Eastern Region Site Verification Services 1 Vision

This task order will be utilized as a part of the overall Provider Enrollment and Oversight, Indefinite Delivery, Indefinite Quantity Contract (PEO-IDIQ) to detect, prevent, and proactively deter fraud, waste and abuse in the Medicare and/or Medicaid programs. Specifically, the contractor will be conducting site verifications for providers / suppliers in the Eastern Region of the United States.

2 Purpose This Quality Assurance Surveillance Plan (QASP) is a Government-developed document used to determine if the contractor's performance meets the performance standards contained in the contract. This QASP establishes procedures on how this assessment/inspection process will be conducted. Below provides the detailed process for a continuous oversight process:

· What will be monitored? – The Western Region Site Verification Services Contractor Performance.

· How monitoring will take place? – The QASP evaluations will be conducted using Random Sampling.

· Who will be conduct the monitoring? – Provider Enrollment Oversight Group (PEOG) / Division of Compliance and Appeals (DCA) / Compliance Team.

· When will the monitoring occur? – The QASP evaluations will be conducted once a year throughout the contract.

· Where will the monitoring take place? – The QASP evaluations can be conducted at CMS headquarters or the contractor’s facilities.

· How will monitoring efforts and results will be documented? – Results will be tabulated by CMS and contractors will receive notification of QASP evaluation results from CMS.

The contractor is responsible for implementing and delivering performance that meets contract standards using its Quality Control Plan. The QASP provides the structure for the Government's surveillance of the contractor's performance to assure that it meets contract standards. It is the Government's responsibility to be objective, fair and consistent in evaluating contractor performance.

The QASP is not part of the contract nor is it intended to duplicate the contractor's quality control plan. This QASP is a living document. Flexibility in the QASP is required to allow for an increase or decrease in the level of surveillance necessary based on contractor performance.

Authority for issuance of this QASP is provided under Part 46 of the Federal Acquisition Regulation, Inspection of Services clauses, which provides for inspection, acceptance and documentation of the service called for in the task order. This acceptance is to be executed by the contracting officer or a duly authorized representative.

3 Roles and Responsibilities The following personnel shall oversee and coordinate surveillance activities:

3.1 Business Function Lead

Technical lead for individual task orders. Works closely with the COR to monitor the day to day operations of the Contractor and assist in the evaluation of the Contractors overall success in meeting the Task Order requirements. A BFL does not have the authority to issue technical direction to the contractor.

3.2 Contracting Officer (CO)

The CO will monitor the contractor’s ability to meet the regulatory and contractual terms of the task order. The CO will also determine and document the final assessment of the contractor's performance in the Government’s past performance system.

3.3 Contracting Officer's Representative (COR)

The COR is responsible for providing continuous technical oversight of the contractor's performance. The COR uses the QASP to conduct the oversight/surveillance process. The COR shall keep a Quality Assurance file that accurately documents the contractor's actual performance. The COR is responsible for reporting early identification of performance problems to the CO.

The COR is required to provide an annual performance assessment to the CO which will be used to document past performance in the Government’s past performance system. The QASP is the primary tool for documenting contractor performance. The COR is not empowered to make any contractual commitments or to authorize any contractual change on the Government's behalf.

3.4 Other Key Government Personnel

This may include performance monitors, inspectors, technical experts, or others who provide information that helps the COR monitor contractor performance. Other Government personnel may be used to assist in performance monitoring.

4 Performance Requirements and Method of Surveillance The Eastern Region Site Verification Services’ contractor’s performance will be monitored using the Random Sampling surveillance method which is detailed below in section 5.1 Surveillance Matrix.

5 Contract Surveillance The goal of the QASP is to ensure that contractor performance is effectively monitored and documented. The foundation of this relationship is built upon objective, fair, and consistent COR evaluations of contractor performance against contract requirements.

The COR will use the methods contained in Section 5.1 of this QASP to ensure the contractor is in compliance with contract requirements. This QASP is based on the premise that the contractor, not the Government, is responsible for management and Quality Control/Quality Assurance actions to successfully meet the terms of the contract.

5.1 Surveillance Matrix

The Surveillance Matrix is the list of performance objectives and standards that must be performed by the contractor. This matrix details the method of surveillance the COR will use to validate and inspect these performance elements. Inspection of each element will be documented in the COR file.

Performance objectives define the desired outcomes. Performance Standards define the level of service required under the contract to successfully meet the performance objective. The inspection methodology defines how, when, and what will be assessed in measuring performance. The Government performs surveillance, using this QASP, to determine the quality of the contractor's performance as it relates to the performance element standards. The SOW and Performance Standards should be used to form the foundation of the COR's inspection checklist.

Surveillance Matrix

Criteria 1 Site Visit Contractor Timeliness – 30 Day IDTF Visit

Criteria 2 Site Visit Contractor Timeliness – 15 Day IDTF Visit

Criteria 3 Site Visit Contractor Timeliness – 30 Day Site Visit

Criteria 4 Site Visit Contractor Timeliness – 15 Day Site Visit

Criteria 5 Site Visit Contractor Accuracy – 30 Day IDTF Visit

Criteria 6 Site Visit Contractor Accuracy – 15 Day IDTF Visit

Criteria 7 Site Visit Contractor Accuracy – 30 Day Site Visit

Criteria 8 Site Visit Contractor Accuracy – 15 Day Site Visit

Criteria 1, Site Visit Contractor Timeliness – 30 Day IDTF Visit

GOAL: 95%

Standard Language: Site visits for Independent Diagnostic Testing Facilities (IDTFs) described in the Task Order SOW will be considered timely when completed within the 30 day timeliness standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed 30 Day IDTF Visits.

Review Sample Size: CMS will randomly select 10% of all completed 30 Day IDTF Visits from the evaluation period.

Performance Percentage Calculation: Number of timely IDTF visits/Total number of IDTF visits reviewed during the Evaluation Period.

Summary Table: Criteria 1

Example: 48 timely IDTF visit/50 total IDTF visits review = 96%, this metric is met.

Criteria 2, Site Visit Contractor Timeliness –15 Day IDTF Visit

GOAL: 95%

Standard Language: Site visits for Independent Diagnostic Testing Facilities (IDTFs) described in the Task Order SOW will be considered timely when completed within the 15 day timeliness standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed 15 Day IDTF Visits.

Review Sample Size: CMS will randomly select 10% of all completed 15 Day IDTF Visits from the evaluation period.

Performance Percentage Calculation: Number of timely IDTF visits/Total number of IDTF visits reviewed during the Evaluation Period.

Summary Table: Criteria 2

Example: 72 timely IDTF visit/80 total IDTF visits review = 90%, this metric is not met.

Criteria 3, Site Visit Contractor Timeliness – 30 Day Site Visit

GOAL: 95%

Standard Language: Site visits for providers and suppliers described in the Task Order SOW will be considered timely when completed within the 30 day timeliness standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed 30 Day Site Visits.

Review Sample Size: CMS will randomly select 1% of all completed provider and supplier 30 Day Site Visits from the evaluation period.

Performance Percentage Calculation: Number of timely site visits/Total number of site visits reviewed during the Evaluation Period.

Summary Table: Criteria 3

Example: 48 timely site visit/50 total site visits review = 96%, this metric is met.

Criteria 4, Site Visit Contractor Timeliness – 15 Day Site Visit

GOAL: 95%

Standard Language: Site visits for providers and suppliers described in the Task Order SOW will be considered timely when completed within the 15 day timeliness standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed 15 Day Site Visits.

Review Sample Size: CMS will randomly select 1% of all completed 15 Day Site Visits from the evaluation period.

Performance Percentage Calculation: Number of timely site visits/Total number of site visits reviewed during the Evaluation Period.

Summary Table: Criteria 4

Example: 26 timely site visit/30 total site visits review = 86%, this metric is not met.

Criteria 5, Site Visit Contractor Accuracy –30 Day IDTF Visit

GOAL: 95%

Standard Language: Site visits for Independent Diagnostic Testing Facilities (IDTFs) described in the Task Order SOW will be considered accurate when completed within the 30 day accuracy standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed 30 Day IDTF Visits.

Review Sample Size: CMS will randomly select 10% of all completed 30 Day IDTF Visits from the evaluation period.

Performance Percentage Calculation: Number of accurate IDTF visits/Total number of IDTF visits reviewed during the Evaluation Period.

Summary Table: Criteria 5

Example: 48 accurate IDTF visit/50 total IDTF visits review = 96%, this metric is met.

Criteria 6, Site Visit Contractor Accuracy –15 Day IDTF Visit

GOAL: 95%

Standard Language: Site visits for Independent Diagnostic Testing Facilities (IDTFs) described in the Task Order SOW will be considered accurate when completed within the 15 day accuracy standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed IDTF 15 Day Site Visits.

Review Sample Size: CMS will randomly select 10% of all completed IDTF 15 Day IDTF Visits from the evaluation period.

Performance Percentage Calculation: Number of accurate IDTF visits/Total number of IDTF visits reviewed during the Evaluation Period.

Summary Table: Criteria 6

Example: 48 accurate site visit/50 total site visits review = 96%, this metric is met.

Criteria 7, Site Visit Contractor Accuracy – 30 Day Site Visit

GOAL: 95%

Standard Language: Site visits for providers and suppliers described in the Task Order SOW will be considered accurate when completed within the 30 day accuracy standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed 30 Day Site Visits.

Review Sample Size: CMS will randomly select 1% of all completed provider and supplier 30 Day Site Visits from the evaluation period.

Performance Percentage Calculation: Number of accurate site visits/Total number of site visits reviewed during the Evaluation Period.

Summary Table: Criteria 7

Example: 48 accurate site visit/50 total site visits review = 96%, this metric is met.

Criteria 8, Site Visit Contractor Accuracy – 15 Day Site Visit

GOAL: 95%

Standard Language: Site visits for providers and suppliers described in the Task Order SOW will be considered accurate when completed within the 15 day accuracy standards in the TO SOW.

Methodology: This standard will be considered met if the contractor completes 95% of the reviewed 15 Day Site Visits.

Review Sample Size: CMS will randomly select 1% of all completed 15 Day Site Visits from the evaluation period.

Performance Percentage Calculation: Number of accurate site visits/Total number of site visits reviewed during the Evaluation Period.

Summary Table: Criteria 8

Example: 26 accurate site visit/30 total site visits review = 86%, this metric is not met.