Att_2 DRAFT PM KBS QASP.pdf

DRAFT

F-35 JOINT PROGRAM OFFICE (F-35 JPO) / SERVICES ACQUISITION TEAM (SAT)

PROGRAM SECURITY KNOWLEDGE BASED SERVICES

Single Award Indefinite Delivery / Indefinite Quantity (SA ID/IQ)

Quality Assurance Surveillance Plan

COMPLIANCE WITH THIS DOCUMENT IS MANDATORY

1.0 SCOPE. The Quality Assurance Surveillance Plan (QASP) is applicable to personnel performing contract surveillance audits in accordance with (IAW) Federal Acquisition Regulation (FAR) Part 46, Quality Assurance; Department of Defense FAR Supplement (DFARS) Subpart and PGI 201.602-2, Contracting Officer Responsibilities. It is designed to provide the Contracting Officer’s Representative (COR) a systematic surveillance method for each service identified in the Performance Work Statement (PWS) for each contract. The COR develop the methods for administering and evaluating contract performance. The Contracting Officer Representative (COR) and Program Manager (PM) or Contracting Manager (CM), will review these methods, which are then accepted or rejected by the Contracting Officer (CO).

1.1 Purpose. This document defines the surveillance policy, procedures, and associated methods used by the COR for planning, preparing, performing, analyzing, and reporting Contractor performance. This QASP provides a systematic surveillance method to evaluate the services received from the Contractor, and NOT to address the details of how the Contractor accomplishes the work.

1.2 Application: This QASP is used by all parties involved with assessing Contractor performance and is for the use of PMs, Technical Point of Contact (TPOC), CORs and CO. The Contractor may receive a courtesy copy in order to further enhance communications with the Contractor, but shall not be considered as part of the contract.

2.0 MANAGEMENT LOCATIONS AND KEY PERSONNEL.

2.1 The address for Contracting Management is:

F-35 Joint Strike Fighter Program Services Acquisition Team (SAT) https://hub.jsf.mil/sites/OCIO/win10 https://hub.jsf.mil/sites/OCIO/win10�

200 12th Street South Arlington, VA 22202

2.2 Program/Contract Management Team.

2.2.1 Contracting Officer (CO). CO duties are detailed in FAR subpart 1.602-2. The CO is the only Government agent authorized to award or modify contracts; therefore, the CO is the only person authorized to contractually obligate the Government. The CO (Patrick Walsh) can be reached at 703-601-1327.

2.2.2 Program Manager (PM). The PM assists customers with requirements development and definition, PWS modifications, deficiency resolution, and portfolio management. The PM (Lucille Balite) can be reached at (703) 602-8045.

2.2.3 Contracting Officer Representative (COR). The COR is ultimately responsible for implementing all QA matters and procedures. COR(s) should be at a level where other duties don’t prevent proper oversight of Contractor performance. The COR must maintain both technical competency and evaluation proficiency in Contractor surveillance procedures. The COR cannot assume duties until assigned by the requiring agency, completed COR required training (CO led training), and appointed by the CO. The COR (Lucille Balite) can be reached at 703-602-8045.

3.0 CONTRACT SURVEILLANCE. The COR function is responsible for a wide range of surveillance requirements that effectively measure and evaluate Contractor performance. The Contractor, not the Government, is responsible for task order management and Quality Control (QC) actions to meet the terms of the contract. However, because of the non-commercial nature of the work performed by the Contractor, the Government cannot rely solely on the Contractor’s quality program but must have a method to oversee the entire contracting process. The Government does this through the QASP and can inspect or test all services called for by the contract, to the extent practicable, at all times and places, during the term of the contract. The COR’s contribution is comprised of professional, non-adversarial relationships, which include positive and open communications with the CO, PM, COR, and the Contractor. The foundation of this relationship is built upon regular, objective, fair, and consistent COR evaluations of Contractor performance against contract requirements, and the ability to discuss inspection results, trends, and items of mutual interest with the Contractor. The COR uses the methods in this QASP and the respective requirement documents to achieve this goal.

3.1 Surveillance Methods. Three primary methods of surveillance are normally used: one hundred percent inspection, periodic audits, and customer complaints. Other methods of surveillance may be implemented based on contractor performance. Information obtained from these activities may be used to ascertain whether or not Contractor performance is compatible with contract and mission objectives, and by the CO for actions relating to the Contractor.

3.1.1 One Hundred Percent Inspection. This method will be used for Contractor submissions, products, and deliverables (tangible items). The COR will use the one hundred percent inspection method to evaluate all reports delivered under paragraph 7.0 of the PWS. The COR, in conjunction with the CO and PM, accepts or rejects these products based on the criteria and performance standards as outlined in the Services Summary. The COR also documents all results of inspection actions, and subsequent Contractor re-performance taskings, if applicable.

3.1.2 Periodic Audit. This type of surveillance consists of evaluating products/services not surveilled via one hundred percent inspection or by customer survey, and is implemented at a pre-defined frequency. An example of periodic audit is performing monthly inspections of class training conducted by the Contractor or weekly inspection of a Contractor’s process in developing training manuals.

3.1.3 Customer Survey or Customer Complaint. Although usually not a primary method, this is a valuable supplement to other, more systematic methods of surveillance. For example, in a case where random sampling indicates unsatisfactory service, customer complaints can be used as substantiating evidence. In certain situations, where customers complain consistently when the quality of performance is poor (e.g., dining facilities, custodial services), customer surveys and customer complaints may be a primary surveillance method, and customer satisfaction is an appropriate performance standard. In all cases, complaints will be documented, preferably on a standard form. All customer complaints will be forwarded to the COR. Information obtained from customer complaint activities may be used by the CO for actions relating to the Contractor.

3.2 Surveillance Documents.

3.2.1 Deliverables. All deliverables captured in PWS paragraph 7.0 and resulting deliverable defined at the task order level will be reviewed for timeliness, accuracy, and format.

3.2.2 Services Summary. The Services Summary is a list of critical tasks that must be performed by the Contractor, the performance threshold, and the method of surveillance the COR will use to validate/inspect these tasks. Inspection of each task will be documented in the COR folder or the Contractor Management System (CMS). This includes the Services Summary captured in the ID/IQ PWS Attachment 4 and any additional services summaries prescribed at the task order level.

3.2.3 Contractor’s Quality Control Plan (QCP). A Contractor's internal actions, in the form of a QCP, are usually written to satisfy task order requirements for written procedures or to provide direction on how Contractor employees are to perform. Any deviations will be treated as deficiencies/non-conformances and handled IAW paragraph 3.3.2. The COR will review the QCP IAW requirements of the solicitation and subsequent awarded task order.

3.3 Assessing Performance. The COR must document Contractor performance on each contract. The COR will assess Contractor performance based on contract requirements. The results will be the foundation of the Contractor Performance Assessment Report (CPAR), which is completed by the PM and CO.

3.3.1 Inspections. The COR may perform inspection/surveillance at any time during contract performance IAW FAR 252.246-2 through 5, as applicable. The COR will retain all audit and inspection documentation until contract closeout, unless otherwise approved by the CO.

3.3.2 Non-Conformances and Deficiencies. Audit or Inspection results that fall below contractual standards shall be identified as non-conformances or deficiencies. The COR will track all non-conformances in the non-conformance log (para 3.3.2.2.3.)

3.3.2.1 Types of Non-Conformance.

3.3.2.1.1 Minor Non-Conformance: A minor non-conformance is a non-conformance, which by itself does not adversely impact mission, safety of personnel and/or equipment, performance (quality), schedule (delivery), or cost. A minor non-conformance normally does not increase risk to the Government.

3.3.2.1.2 Major Non-Conformance: A major non-conformance is a non-conformance that adversely impacts mission, safety of personnel and/or equipment, performance (quality), schedule (delivery), or cost. A major non-conformance also increases risk to the Government.

An example of increasing risk would be significant number of recurring non-conformances, which indicates inadequate preventive measures or actions, thus lowering the Government’s confidence that quality services will be provided on time and at cost.

3.3.2.2 Non-Conformance Notification. If a non-conformance is found during inspection of the Contractor’s performance, the COR will determine the type of notification based on the category of the non-conformance (see table below) and pursue non-conformance resolutions.

3.3.2.2.1 First or Second Notices. First and Second Notices provide written notification from the Government to the Contractor of minor non-conformances. Initial minor non-conformances should be addressed with a First Notice to the applicable Contractor representative. The COR may coordinate with the PM prior to delivering the notice to the Contractor for action. The First and Second notices will be issued with a suspense date for the contractor’s reply (typically 10 business days). If the Contractor fails to respond by the suspense date, the COR will follow-up with the Contractor and may issue a second notice. If the Contractor fails to resolve the issue as documented in the Notice, the COR should elevate the issue to the next level (Second Notice or CAR). Corrective/preventive actions initiated and/or completed by the Contractor will be verified by the COR on the scheduled inspection and documented accordingly (typically on the CAR form). The notice will include: date of notice, requirement reference, actions that should have been performance in accordance with reference, description of non-conformity, and date response is due from Contractor

3.3.2.2.2 Corrective Action Requests (CAR). A CAR provides written notification from the Government to the Contractor of significant performance discrepancies. The COR will draft the CAR and coordinate with the PM/Multi-Functional Team (MFT) for review as necessary. Once the review is final, the CAR will be sent to the CO. The CAR will be routed NLT ten (10) duty days after the event to the CO for review and signature, as the CO is the only person who has authority to issue a CAR to the Contractor.

NON-CONFORMANCE NOTIFICATIONS

Non-Conformance Category Notification Type Minor

Step 1: First Notice Step 2: Second Notice

Major Corrective Action Request (CAR)

3.3.2.2.2.1 To satisfactorily close-out a CAR, the following criteria must be met: the Contractor must meet the suspense; the corrective action must have already begun; and the Contractor's actions must correct the non-conformance and, if applicable, be within specified standards. If the corrective action is deemed UNSATISFACTORY by the COR/MFT, an *estimate* of the Government's loss due to the deficient performance (if applicable) will be forwarded to the CO for review. Once the review is complete, the CAR will be annotated with the USG’s estimated loss and be sent to the CO for action.

*The estimate may account for loss or destruction of property, supplies, or equipment, and hours lost to re-perform the task. If the task cannot be re-performed, indicate the number of hours it ordinarily would have taken to do the task, if known.

3.3.2.2.3 The COR will maintain a non-conformance log documenting all First and Second Notices and CARs. Please review the log for required fields. If a field header has a red triangle in it, click on the triangle and instructions will be provided. The COR log is maintained in the Government file plan.

3.3.3 COR Report. A report will be provided based on the SS requirements. CDRLs will be reviewed IAW due dates, the QCP will be reviewed upon delivery, and then the Contractors QC activities will be reviewed. The report will consist of the results of the SS review and a memo (as part of the e-mail that includes the checklist) detailing any concerns or areas where the contractor exceeded requirements. Minor and major non-conformances shall be submitted immediately (instead of delivering with the report). In addition, any significant concerns shall be up-channeled immediately.

4.0 Invoices Receipt Acceptance and Property Transfer ((iRAPT) formerly (WAWF).

The COR will review and recommend acceptance or rejection of contractor submitted Receiving Reports to the PM within seven (7) days of contractor submission in iRAPT. To access the receiving report, log into IRAPT, select the Government, Acceptor, Acceptance Folder tab and then type in the contract and delivery order (task order) number. The Shipment Number column in IRAPT is the Receiving Report number.

4.1 Validating Receiving Reports (RR). The COR will review and validate all IRAPT receiving reports (Shipment Number in IRAPT) ensuring that:

• The Contractor submitted a combination invoice/receiving report

• The report reflects the correct contract and TO number

• Beginning and ending dates being billed are stated and accurate

• The correct CLIN(s) is(are) charged for billing period

• A description of the services is provided (Labor Costs, Labor Hour, Travel, Materials)

• The correct amount is charged, to include applicable handling rates

• Invoiced travel was pre-approved

• Back-up documentation is attached that includes a Contractor invoice with current and cumulative hours and amounts

• A breakout of any other charges, as agreed to by the CO or required by the TO, is attached in IRAPT.

4.2 Certifying and Accepting RRs.

4.2.1 Certification of services is performed by the appointed COR. After validation of services is performed, the COR will forward to the PM for their review and acceptance. Once again, the COR will verify the RR, and the PM will accept.

4.3 Rejecting Receiving Reports. If during the COR review, a RR is found to be incomplete, incorrect, etc., the COR will reject and annotate the rejection details in the Miscellaneous Info tab in the comments block as follows:

• List details regarding all unsatisfactory services or incorrect invoice information; and

• Instruct the Contractor to contact DFAS to have the invoice rejected back to the

Contractor; this will allow the Contractor to make the same correction on both the receiving report and invoice, since combination invoices/receiving reports are required.

The rejecter will then return to the Header tab and click the “Reject to Initiator” block. Anyone other than the COR may reject receiving reports in IRAPT. After rejecting the receiving report, e-mail the PM and CO the contract number, receiving report number, and reason for rejection.

5.0 *COR FOLDER. The Primary COR will establish and maintain a COR folder for each task order; an electronic version of the folder may be kept. The COR folder will contain the information outlined below in Table 4. Documentation is kept for the life of the contract and provides necessary continuity should COR duties transition during the course of the contract.

The COR will receive instructions from the CO on disposition or archival procedures upon contract completion.

*These files may be incorporated into the CO’s or PM’s file plan (or CMT) and are not required to be maintained as a separate entity.

TABLE 4 – COR FOLDER TABS & CONTENTS

Tab Title Items to Include

1 General Correspondence 2 COR Appointment Letter(s) Assignment/nomination letter(s), appointment letter(s) and Government/Contractor relationships guidance 3 COR Training COR certificates for DAU, QAPC and CO Led training 4 Contract/Task Order, Modifications, PWS, Pricing Contract for current level of effort, any modifications and most current PWS/amendment on contract, and Contractor’s contract/task order pricing

5 Quality Assurance Surveillance Plan, Surveillance Checklist

Contract/task order QASP, approved surveillance checklist, and completed surveillance checklists

6 Contractor’s Quality Control Plan If applicable 7 First & Second Notices, Corrective

Action Reports (CAR) Non-conformance log, First and Second Notices and CARs issued to Contractor

8 Contractor Deliverables CDRLs, deliverable specified in contract/task order, reports, etc.