Attachment E- Quality Assurance Surveillance Plan (QASP) (Amd. 0007) 2026.02.23.pdf

Attachment F- Quality Assurance Surveillance Plan (QASP (Amd. 0007)

Quality Assurance Surveillance Plan (QASP) UAC Legal Services

Attachment F- Quality Assurance Surveillance Plan (QASP)(Amd. 0007) (02.23.2026)

1. Purpose

The QASP provides a systematic method to evaluate and monitor performance. It does not detail how the Contractor accomplishes the work. Rather, the QASP is created with the premise that the Contractor is responsible for management and quality control actions to meet the terms of the contract. The QASP discusses what will be monitored, how monitoring will take place, who is responsible for conducting monitoring, and how monitoring results will be documented to provide an assessment of the Contractor’s performance.

In addition, the QASP recognizes that unforeseen and uncontrollable situations may occur. As such, the QASP is a “living document,” and the Government may review and unilaterally revise it as necessary.

The COR will provide the QASP to the Contractor to inform its quality management.

2. Roles and Responsibilities

The following personnel will oversee and coordinate surveillance activities.

Contracting Officer (CO): The CO is responsible for ensuring performance of all necessary actions for effective contracting, ensuring compliance with the terms of the contract, and safeguarding the interests of the United States in its contractual relationships. The CO is responsible for monitoring the Contractor’s performance in accordance with the QASP and other terms and conditions of the contract and making periodic assessments of the Contractor’s performance, with the assistance of the Contracting Officer Representative.

Contracting Officer’s Representative (COR): Appointed by the CO, the COR is responsible for providing continuous technical oversight of the Contractor’s performance and assisting the CO in monitoring the Contractor’s compliance with the performance requirements of the contract. The COR uses the QASP to conduct the oversight/surveillance process. The COR is responsible for maintaining a Quality Assurance file that documents the Contractor’s performance. The purpose of the COR’s surveillance is to monitor contract performance against contractual requirements and standards, monitor the effectiveness of the Contractor’s quality management, identify any non-conformances not self-identified by the Contractor, identify areas of non-conformance and specify corrective action when appropriate (see Attachment 1), and review contract deliverables and supporting documentation provided with invoices.. The COR also provides input to the CO for the Contractor’s performance assessments. The COR may provide technical direction to the Contractor but the COR is not empowered to make any contractual commitments or to authorize any contractual change on the Government’s behalf. The COR may be assisted by Technical Points of Contact (TPOC); program technical experts and managers, and program policy monitors to both inform and assist with surveillance and performance oversight.

Government Program/Project Manager (PM): The PM provides program oversight and supports the COR’s performance assessment activities.

Other Key Government Personnel: This may include performance and policy monitors, inspectors, TPOCs, other technical experts, and others who inform or otherwise assist the COR monitor Contractor performance.

3. Surveillance Matrix:

This QASP guides the surveillance activities associated with each discrete element of the contract. This will be tracked and managed using a separate spreadsheet or application-based surveillance schedule developed and maintained post award. The surveillance schedule will illustrate the planned frequency and method of the Government surveillance of contract requirements and deliverables.

4. Continuous Assessment:

It is the Contractor’s responsibility to provide the overall management and quality control actions to meet the terms of the contact. It is the responsibility of the Government through quality assurance activities to monitor Contractor performance and the conformance of tasks/services and contract deliverables. The Government also evaluates Contractor performance in an objective, fair, and consistent manner. Through its surveillance, the Government will continuously assess the Contractor’s performance.

The Government assesses surveillance-based contract performance using a rating system aligned with the Contractor Performance Assessment Reporting System (CPARS) ratings.

The Government’s surveillance-based assessments use CPARS-aligned ratings: Exceptional, Very Good, Satisfactory, Marginal, and Unsatisfactory as follows:

Rating Score Definition* Problems Corrective Actions

Exceptional

Surveilled item / service performance meets contractual requirements and exceeds many to the Government’s benefit.

Few Minor

Highly Effective

Very Good performance meets contractual requirements and exceeds some to the Government’s benefit.

Some Minor

Effective

Satisfactory 3 Surveilled item / service performance meets contractual requirements.

Some Minor Satisfactory

Marginal performance does not meet some contractual requirements.

Serious;

Recovery Still Possible

Marginally Effective

Unsatisfactory 1 Surveilled item / service performance does not meet most contractual requirements

Serious;

Recovery Not Likely

Ineffective

* See FAR 42.1503 Procedures, Table 42-1 for full description and for notes to assist with rating justifications

5. Performance Standards

The Performance Requirements Summary (PRS), contract Section F6, in combination with the tasks and standards defined within the contract, define performance standards and acceptable quality levels (AQLs).

The Contractor is responsible for ensuring all contractual requirements and standards are met. The Government performs surveillance in accordance with the QASP and the post-award surveillance matrix.

The Government uses these standards and the requirements defined within this contractor to assess project and contract performance.

Definitions:

• Performance standard: See the Contract, Section F6.

• Acceptable Quality Level (AQL): See the Contract, Section F6.

6. Surveillance Methods and Frequency

The COR will be responsible for coordinating and monitoring the Contractor’s performance in accordance with this QASP and the Contractor’s Quality Management Plan. The CO will assist the COR as needed and provide approvals as required in the contract. Regardless of the surveillance method, when the COR identifies a non-conformance/contract deficiency, the COR and the Contractor will follow the procedures at Appendix A, Non-Conformance Reporting.

The Government may use a variety of surveillance methods to evaluate the Contractor’s performance.

These include, but are not limited to

• Random sampling of contract deliverables and/or performance of tasks/services.

• 100% of some or all contract deliverables and/or performance of tasks/services.

• Surveillance of the Contractor’s quality control program and project management.

• Review customer satisfaction feedback from internal and external stakeholders. Stakeholder feedback can be obtained through multiple approaches, such as direct observation, general complaints, satisfaction surveys, etc.

• ORR monitoring of statute, regulation, or ORR policy compliance.

Surveillance may be in person or virtual. The Contractor is afforded the opportunity to rebut any surveillance finding within seven days of notification by the COR. The post-rebuttal determination is the final determination after either the Government has responded to the Contractor’s rebuttal or the Contractor declines to submit a rebuttal.

Specific surveillance methods and frequency for contract deliverables and the performance of tasks/services will be determined by the COR and ORR. Risk to the delivery of deliverables and services and overall contract performance will in-part inform surveillance methods and frequency. See Section 9 of this

QASP.

7. Documenting Performance

The Government will document performance. Any report may become part of the supporting documentation for non-conformance reporting and Government remedies for performance issues, fixed price payments, CPAR, or other actions.

8. Mandatory or regulatory compliance items

The Contractor will be monitored to ensure compliance with statutory or regulatory compliance items that are part of the contract such as combating trafficking in persons, EEO, wage determinations, intellectual property, subcontracting plan compliance, etc. The COR will notify the Contracting Officer if there are any potential or actual noncompliance issues with federal statues, laws, or regulations.

9. Risk Assessment.

Risk assessment to inform government surveillance is a continual methodical process involving the informed subjective comparison of likelihood of a contract non-conformance vs. consequence. The intersection of these variables determines the risk from very low to very high. Many factors may influence the COR’s assessment of likelihood of a future non-conformance including but not limited to past performance, past surveillance results, history of non-conformances and the effectiveness of corrective action, stakeholder feedback, the Contractor’s project and quality control management, and mitigations in-place to reduce and eliminate risk. This risk assessment process is used to separately determine the risk of a non-conformance negatively impacting, 1) the performance of a single requirement, and 2) overall contract performance.

A) Contract Requirement Risk -- Risk of Contractor failing to satisfactorily perform individual requirements due to non-conformance:

Li ke lih oo d of

N on

-C on fo rm an ce

V Near Certain

Low V-A

Medium V-B

High V-C

High V-D

Very High V-E

IV Highly Likely

Low

IV-A

Medium

IV-B

Medium

IV-C

High

IV-D

High

IV-E

III Likely Low

III-A

Low

III-B

Medium

III-C

Medium

III-D

High

III-E

II Unlikely Low

II-A

Low

II-B

Low

II-C

Medium

II-D

Medium

II-E

I Remote Very Low I-A

Low I-B

Low I-C

Low I-D

Low I-E

Negligible Minor Marginal Critical Catastrophic A B C D E

Consequence to Performance of a Single Contract Requirement, Deliverable, Task/Service

B) Contract Performance Risk -- Risk of overall contract performance failure due to non-conformance:

Li ke lih oo d of

N on

Co nf or m an ce V Near

Certain Low V-A

Medium V-B

High V-C

High V-D

Very High V-E

IV Highly Likely

Low

IV-A

Medium

IV-B

Medium

IV-C

High

IV-D

High

IV-E

III Likely Low

III-A

Low

III-B

Medium

III-C

Medium

III-D

High

III-E

II Unlikely Low

II-A

Low

II-B

Low

II-C

Medium

II-D

Medium

II-E

I Remote Very Low I-A

Low I-B

Low I-C

Low I-D

Low I-E

Negligible Minor Marginal Critical Catastrophic A B C D E

Consequence to Overall Contract Performance

Appendix A: Non-Conformance Reporting to Quality Assurance Surveillance Plan (QASP) UAC Legal Services

1. Definitions

a. Corrective Action Request (CAR): A formal request issued to a contractor to address and correct performance deficiencies.

b. Non-Conformance: A failure to meet specified requirements or standards in contract performance.

c. Performance Deficiency: Inadequate or substandard performance by a Contractor under the terms of the contract.

2. Corrective Actions Requests (CAR)

The Office of Refugee Resettlement (ORR) will document all instances of a Contractor performance deficiency/contract non-conformance on a CAR (Attachment 1). The Contracting Officer’s Representative (COR) creates the CAR, obtains Contracting Officer (CO) approval for Level III and Level IV CARs, and then sends the CAR to the Contractor. Regarding CARs, ORR communicates with the Prime Contractor only – not directly with the subcontractors. The Prime Contractor is responsible for communicating with the relevant subcontractor(s) to resolve a CAR and the underlying deficiency/non-conformance. In a CAR, the Government should not speculate on the underlying cause of a non-conformance when describing the non-conformance.

3. Contractor Identified Deficiency

When the Contractor self-identifies a deficiency in its processes, services, or deliverables and takes appropriate, timely, and effective corrective action, the Government will not issue further corrective action documentation unless the Government determines later the Contractor’s corrective action is ineffective. If the Contractor’s corrective action is ineffective and action to correct nonconformance either is not taken or is not satisfactory within an agreed upon timeframe, the COR will issue a CAR, coordinating with the CO as appropriate.

4. CAR Process

a. The Government will notify the Contractor of the contract deficiency prior to CAR issuance to ensure awareness of the contract noncompliance. This notification may be written or verbal (if verbal, the COR will follow up with written documentation).

b. All CARs will be communicated in writing – CARs will not be verbal.

c. The COR determines the initial deficiency level and will indicate in the CAR whether the deficiency is a minor nonconformance (Level I or II), major nonconformance (Level III), or critical nonconformance (Level IV). The Government makes this determination in consideration of FAR part 46, Quality Assurance.

https://www.acquisition.gov/far/part-46#FAR_46_101 https://www.acquisition.gov/far/part-46#FAR_46_101 https://www.acquisition.gov/far/part-46#FAR_46_101

d. The COR will provide the Contractor with technical direction to immediately address any critical deficiencies that impact safety or ORR mission.

e. Level I CARs do not require the Contractor to prepare a written Corrective Action Plan (CAP). Level II and higher CARs require the Contractor to prepare a written

CAP.

i. CAPs for non-commercial items must include Root Cause and Corrective Action (RCCA). The Legal Services contract is for commercial services; as such RCCA will not be required.

ii. CAPs for commercial items do not require a RCCA. A CAR issued for nonconforming product or service being tendered to the government for acceptance under FAR part 12, Acquisition of Commercial Products and Commercial Services, can only require the Contractor to identify actions taken to correct the specific product and/or service nonconformity.

f. For repeated CARs at any level, the Government will consider elevating the CAR to the next higher level.

g. The Contractor will provide a written response to CO/COR as required by the CAR letter and begin to develop the CAP. The Contractor and the COR/CO will discuss the CAP throughout the CAP development process. COR/CO input during CAP development will ensure Government approval of the final version of the CAP.

h. The Contractor must provide the CAP to the Government within 15 calendar days of receiving the CAR.

i. The COR maintains an internal government CAR log for each contract where CARs have been issued.

5. Contractor’s CAR Response Requirements

The Contractor’s response and CAP must include the following elements:

a. Root cause of the deficiency (not applicable to the Legal Services Contract). ORR does encourage the C to internally perform RCCA as appropriate as a proven quality control and continuous improvement best practice.

b. Actions taken to correct the current specific deficiency

c. Corrective action taken or planned to eliminate the deficiency

d. Action taken to prevent recurrence of the deficiency

e. Determination of whether other processes are affected by the identified root cause

f. Determination of whether other costs, products, and/or services are affected by the identified root cause, including product already delivered to the customer

g. Action taken to correct the weakness that allowed deficient costs, products, and/or services to be provided to the government for acceptance

h. Target date(s) for implementation of planned actions

i. Corrective Action Approved Date (to be provided by the COR/CO)

j. Corrective Action Implementation Date

6. Verifying the Contractor’s Corrective Action https://www.acquisition.gov/far/part-12 https://www.acquisition.gov/far/part-12 https://www.acquisition.gov/far/part-12

The COR and CO will verify the Contractor’s implementation of corrective and preventive actions.

a. If the Government assesses that the Contractor is not implementing corrective actions in accordance with the accepted CAP, the COR will notify the Contractor in writing and request the Contractor submit a revised CAP within 10 calendar days.

b. If the Contractor fails to respond to the request for a revised CAP or the resubmitted response is still insufficient, the Government may escalate the CAR to the next higher CAR level.

7. Validating the Contractor’s Corrective Action

To ensure full resolution of the deficiency, the COR will perform a validation review after the Contractor asserts that it completed the corrective actions.

If objective evidence establishes the Contractor’s corrective action is ineffective, the COR will reject the Contractor’s corrective action response and consider escalation of the CAR level. The rejection notification letter will be in writing and include evidence of the inadequacy.

8. Escalating a CAR to the Next Higher CAR Level

The Government may escalate a CAR to the next higher level when the COR and/or CO determines that the Contractor is unwilling or unable to implement effective corrective action. When the Government escalates a CAR to the next higher level, the Government and Contractor will repeat the process outlined in section 4.

9. Closing a CAR

When the Government is satisfied that the Contractor’s corrective actions resolved and are appropriate to prevent recurrence of the deficiency, the Government will close the CAR and the COR/CO will notify the Contractor in writing. The Contractor must continue any follow-up actions in accordance with the CAP.

Attachment 1: Corrective Action Request Format to Appendix A: Non-Conformance Reporting to Quality Assurance Surveillance Plan (QASP)

UAC Legal Services

CAR required information:

TO: (Contractors Name/POC) THROUGH: (COR Name )

FROM: (CO)

SUBJECT: Corrective Action Request Contract/Order Number

CAR Level Issued: (I, II, II, IV )

Contract number/order:

Date deficiency observed:

Location of Prime Contractor:

Name of Subcontractor (if applicable):

Location of Subcontractor (if applicable):

POC of Subcontractor (if applicable):

Contractual requirement reference(s):

Deficiency/nonconformance description:

Due date for contractor’s response [15 calendar days for initial response unless a different number of days is agreed-to between the COR/CO and the Contractor].

COR Signature CO Signature (Level III and IV CARs)

Disclaimer Statement: Nothing in this CAR changes any terms or conditions of the contract or waives any rights the Government has under the contract or in law.