Attachment 0002 - QASP.doc

Quality Assurance Surveillance Plan (QASP)

Ginnie Mae Legal Services to Support the Mortgage Backed Securities Program - Acknowledgement Agreement Reviews and Issuer Liquidity Matters

02/01/2024 Version 1.0

31 Vision

1 Introduction

1.1 Purpose

1.2 Performance Management Approach

1.3 Performance Management Strategy

2 Roles and Responsibilities

2.1 The Contracting Officer

2.2 The Contracting Officer's Representative

3 Identification of Required Performance Standards / Quality Levels 4 Methodologies to Monitor Performance

4.1 Surveillance Techniques

4.2 Customer Feedback

4.3 Acceptable Quality Levels

5 Quality Assurance Documentation

5.1 The Performance Management Feedback Loop

5.2 Monitoring Forms

6 Analysis of Quality Assurance Assessment

6.1 Determining Performance

6.2 Reporting

6.3 Reviews and Resolution

6.4 Surveillance Matrix

Appendix 1 - Surveillance Matrix Appendix 2 - Corrective Action Report (CAR) Appendix 3 - Customer Complaint Record Appendix 4 - Performance Assessment Report (PAR)

Quality Assurance Surveillance Plan (QASP) Ginnie Mae Legal Services to Support the Mortgage Backed Securities Program - Acknowledgement Agreement Reviews and Issuer Liquidity Matters

1 Vision

To achieve operational excellence through the attainment of legal services in support of its Mortgage-Backed Securities program, which serves to increase the liquidity of Ginnie Mae MBSs and attract new sources of capital for federally insured or guaranteed loans.

1 Introduction

This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the Performance Work Statement (PWS) entitled Ginnie Mae Legal Services to Support the Mortgage-Backed Securities Program - Acknowledgement Agreement Reviews and Issuer Liquidity Matters. This plan sets forth the procedures and guidelines the Office of the General Counsel and Ginnie Mae will use in ensuring the required performance standards or service levels are achieved by the Contractor.

1.1 Purpose

1.1.1 The purpose of the QASP is to describe the systematic methods used to monitor performance and to identify the required documentation and the resources to be employed. The QASP provides a means for evaluating whether the Contractor is meeting the performance standards/quality levels identified in the PWS and the Contractor's Quality Control Plan (QCP), and to ensure that the Government pays only for the level of services received.

1.1.2 This QASP defines the roles and responsibilities of all members of the Integrated Project Team (IPT), identifies the performance objectives, defines the methodologies used to monitor and evaluate the Contractor's performance, describes quality assurance documentation requirements, and describes the analysis of quality assurance monitoring results.

1.2 Performance Management Approach

1.2.1 The PWS structures the acquisition around "what service or quality level is required", as opposed to "how the Contractor should perform the work" (i.e., results, not compliance). This QASP will define the performance management approach taken by the Office of the General Counsel and Ginnie Mae to monitor and manage the Contractor's performance to ensure the expected outcomes or performance objectives communicated in the PWS are achieved. Performance management rests on developing the capability to review and analyze information generated through performance assessment. The ability to make decisions based on the analysis of performance data is the cornerstone of performance management; this analysis yields information that indicates whether expected outcomes for the project are being achieved by the Contractor.

1.2.2 Performance management represents a significant shift from the more traditional Quality Assurance (QA) concepts in several ways. Performance management focuses on assessing whether outcomes are being achieved and to what extent. This approach migrates away from scrutiny of compliance with the processes and practices used to achieve the outcome. A performance-based approach enables the Contractor to play a large role in how the work is performed, as long as the proposed processes are within the stated constraints. The only exceptions to process reviews are those required by law (federal, state, and local) and compelling business situations, such as safety and health. A "results focus" provides the Contractor flexibility to continuously improve and innovate over the course of the contract as long as the critical outcomes expected are being achieved and/or the desired performance levels are being met.

1.3 Performance Management Strategy

1.3.1 The Contractor is responsible for the quality of all work performed. The Contractor measures that quality through the Contractor's own Quality Control (QC) program. QC is work output, not workers, and therefore includes all work performed under this contract regardless of whether the work is performed by Contractor employees or by subcontractors. The Contractor's QCP will set forth the staffing and procedures for self-inspecting the quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the PWS. The Contractor will develop and implement a performance management system with processes to assess and report its performance to the designated government representative. This QASP enables the Government to take advantage of the Contractor's QC program.

1.3.2 The Government representative(s) will monitor performance and review performance reports furnished by the Contractor to determine how the Contractor is performing against communicated performance objectives. The Contractor will be responsible for making required changes in processes and practices to ensure performance is managed effectively.

2 Roles and Responsibilities

2.1 The Contracting Officer

The Contracting Officer (CO) is responsible for monitoring contract compliance, contract administration, and cost control and for resolving any differences between the observations documented by the Contracting Officers Representative (COR ) and the Contractor. The CO will designate one full-time COR as the government authority for performance management. The number of additional representatives serving as technical inspectors depends on the complexity of the services measured, as well as the Contractor's performance, and must be identified and designated by the CO.

2.2 The Contracting Officer's Representative

The COR is designated in writing by the CO to act as his or her authorized representative to assist in administering a contract. COR limitations are contained in the written appointment letter. The COR is responsible for technical administration of the project and ensures proper government surveillance of the Contractor's performance. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government's behalf. Any changes that the Contractor deems may affect contract price, terms, or conditions, shall be referred to the CO for action. The COR will have the responsibility for completing QA monitoring forms used to document the 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.

3 Identification of Required Performance Standards / Quality Levels

The required performance standards and/or quality levels are included in the PWS and in Appendix 1, "Surveillance Matrix". If the Contractor meets the required service or performance level, it will be paid the monthly amount agreed on in the contract.

4 Methodologies to Monitor Performance

4.1 Surveillance Techniques

In an effort to minimize the performance management burden, simplified surveillance methods shall be used by the Government to evaluate Contractor performance when appropriate. The primary methods of surveillance are:

· 100% Inspection - Each month, the COR shall review the generated documentation and enter summary results into the Surveillance Activity Checklist.

· Periodic Inspection - The COR typically performs the periodic inspection on a monthly basis.

· Customer Feedback

4.2 Customer Feedback

The Contractor is expected to establish and maintain professional communication between its employees and customers. The primary objective of this communication is customer satisfaction. Customer satisfaction is the most significant external indicator of the success and effectiveness of all services provided and can be measured through customer complaints.

Performance management drives the Contractor to be customer focused through initially and internally addressing customer complaints and investigating the issues and/or problems. The customer always has the option to communicate complaints to the CO and/or COR as opposed to the Contractor.

Customer complaints, to be considered valid, must set forth clearly and in writing the detailed nature of the complaint, must be signed, and must be forwarded to the COR.

Customer feedback may also be obtained either from the results of formal customer satisfaction surveys or from random customer complaints.

4.3 Acceptable Quality Levels

The Acceptable Quality Levels (AQLs) included in Appendix 1, "Surveillance Matrix", for Contractor performance are structured to allow the Contractor to manage how the work is performed. For certain critical activities such as those involving Acknowledgement Agreement review and other issuer liquidity matters services, the desired performance level is established at 100 percent. Other levels of performance are keyed to the relative importance of the task to the overall mission performance.

5 Quality Assurance Documentation

5.1 The Performance Management Feedback Loop

The performance management feedback loop begins with the communication of expected outcomes. Performance standards are expressed in the PWS and are assessed using the performance monitoring techniques shown in Appendix 1.

5.2 Monitoring Forms

The Government's QA surveillance, accomplished by the COR, may be reported using the following monitoring forms: Appendix 2 - "Corrective Action Report (CAR)", Appendix 3 - "Customer Complaint Record", and Appendix 4 - "Performance Assessment Report" (PAR). The forms, when completed, will document the Government's assessment of the Contractor's performance under the contract to ensure that the required results are being achieved. The COR will retain a copy of all completed QA surveillance forms.

6 Analysis of Quality Assurance Assessment

6.1 Determining Performance

The Government will use the monitoring methods cited to determine whether the performance standards/service levels/AQLs have been met. If the Contractor has not met the minimum requirements, it may be asked to develop a corrective action plan to show how and by what date it intends to bring performance up to the required levels.

6.2 Reporting

At the end of each month, the Project Manager will prepare a written report for the Contracting Officer's Representative summarizing the overall results of the quality assurance surveillance of the Contractor's performance. This written report, which includes the Contractor's submitted monthly report and the completed quality assurance monitoring forms, will become part of the QA documentation. It will enable the Government to demonstrate whether the Contractor is meeting the stated objectives and/or performance standards, including cost/technical/scheduling objectives.

6.3 Reviews and Resolution

6.3.1 The COR may require the Contractor's project manager, or a designated alternate, to meet with the CO, PM, and/or other Government IPT personnel as deemed necessary to discuss performance evaluation. The COR will define a frequency of in-depth reviews with the Contractor, including appropriate self-assessments by the Contractor; however, if the need arises, the Contractor will meet with the COR as often as required or per the Contractor's request.

The agenda of the reviews may include:

· Monthly performance assessment,

· Data and trend analysis,

· Issues and concerns of both parties,

· Projected outlook for upcoming months and progress against expected trends, including a corrective action plan analysis,

· Recommendations for improved efficiency and/or effectiveness,

6.3.2 The CO and COR must coordinate and communicate with the Contractor to resolve issues and concerns regarding marginal or unacceptable performance.

6.3.3 The COR and Contractor should jointly formulate tactical and long-term courses of action. Decisions regarding changes to metrics, thresholds, or service levels should be clearly documented. Changes to service levels, procedures, and metrics will be incorporated as a contract modification at the discretion of the CO.

6.4 Surveillance Matrix

The Surveillance Matrix (Appendix 1) 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 PRS should be used to form the foundation of the COR's inspection checklist.

In evaluating the quality of contractor’s performance, the following performance ratings may be used.

Performance

Rating Criteria

Appendix 1 - Surveillance Matrix

5.1 Project Management Plan (PMP)

Deliverables:

A001 Project Management Plan

a) Document all support requirements in a Project Management Plan (PMP) outlining the Contractors approach to program management, risk management, and communications for all tasks and deliverables included in the PWS.

AQL: Zero Deviation

What: Project Management Plan

How: The contractor shall provide Ginnie Mae a copy of the plan at the Kick-Off meeting for review and comments. Upon incorporation of Ginnie Mae's comments, the contractor shall revise the plan and re-submit the plan to Ginnie Mae within five (5) business days.

Frequency: Continuous

Who: Project Manager

Incentive: If a Project Management plan is not submitted at the time of the proposal, or in a timely manner following a request from the government, the government will withhold award to the offeror until a plan deemed acceptable by the Government is submitted and accepted.

Standard(s): Applies to All Standards

5.2 Conflict of Interest Resolution

Deliverables:

A002 Conflict Resolution Plan

a) NA AQL: Plan evidencing the contractor's ability to handle identify, and address, potential conflicts of interests surrounding their representation of the government.

b) Entering into and enforcing agreements with all the contractor's attorneys prohibiting such attorneys from representing any parties against the United States, Ginnie Mae, HUD, or any party with respect to matters directly related to, or matters that may have a direct effect on, a specific assignment that is within this contracts scope of work, during and after the contract term.

What: Conflict Resolution Plan

Deliverables

How: The contractor shall submit a conflict resolution plan with their proposal for review and comments. Upon incorporation of Ginnie Mae's comments the contractor shall revise the plan and re-submit the plan to Ginnie Mae in five (5) business days.

Frequency: Continuous

Who: The General Counsel or his/her designee.

Incentive: If a Conflict Resolution Plan is not submitted at the time of proposal, or in a timely manner after a request is made from the government, the government will withhold award to the contractor until a plan deemed acceptable by the Government is submitted and accepted.

5.3 Mortgage-Backed Securities Legal Service: Acknowledgment Agreements and Issuer Liquidity Matters

Deliverables:

A003 Legal Work as Described in the Assignment

a) Competent legal work delivered on or before the due date established in the assignment or as subsequently determined by the Government 100% of the time.

AQL: Zero Deviation

What: Contractor's Performance providing legal assistance for Acknowledgement Agreements and Issuer Liquidity matter

How: Contract performance reviews with the Contractor

Frequency: Continuous

Who: The General Counsel or his or her designee

5.4 Transition In Activities

Deliverables:

A004 Transition-In Plan

a) Evidence of the contractor's ability to handle the an orderly transition of work acceptance and accomplishment such that any impact to the program is minimized.

AQL: Plan detailing the contractor's ability to effectuate an orderly transition of work

What: Transition-In Plan

How: The contractor shall submit a Transition-In plan with their proposal for review and comments. Upon incorporation of Ginnie Mae's comments, the contractor shall revise the plan and re-submit the plan to Ginnie Mae in five (5) business days.

Frequency: Continuous

Who: The General Counsel or his/her designee

Incentive: If a Transition-In plan is not submitted in a timely, or satisfactory manner, the government will withhold award to the contractor until a plan deemed acceptable by the Government is submitted and accepted.

5.5 Transition Out Activities

Deliverables:

A005 Transition-Out Plan

a) Evidence of the contractor's ability to handle the an orderly transition of work acceptance and accomplishment such that any impact to the program is minimized.

AQL: Plan detailing the contractor's ability to effectuate an orderly transition of work

What: Transition-Out Plan

How: The contractor shall submit a Transition-Out plan with their proposal for review and comments. Upon incorporation of Ginnie Mae's comments the contractor shall revise the plan and re-submit the plan to Ginnie Mae in five (5) business days.

Frequency: Continuous

Who: The General Counsel or his/her designee

Incentive: If a Transition-Out plan is not submitted in a timely, or satisfactory manner, the government will withhold award to the contractor until a plan deemed acceptable by the Government is submitted and accepted.

5.6 Right to Audit

Deliverables:

A006 Email or other Electronic confirmation

a) Retention of all records, processes documentation, controls, flowcharts, and accounts related to Acknowledgement Agreement review and other issuer liquidity matters services pertaining to Ginnie Mae's Mortgage-Backed Securities Program under this agreement for a period of at least three (3) years from the completion date of any work.

AQL: Retention of all records for at least three (3) years from the completion date of the work

What: Deliverables

How: Thorough review of the electronic files for completeness.

Frequency: Continuous

Who: The General Counsel or his or her designee

Appendix 2 - Corrective Action Report (CAR)

CORRECTIVE ACTION REPORT (CAR)

(If more space is needed, use reverse and identify by number)

1. CONTRACTOR

2. CONTRACT NUMBER

3. TYPE OF SERVICES

4. FUNCTIONAL AREA

5. SUSPENSE DATE

6. CONTROL NUMBER

7. DEFICIENCY FORMCHECKBOX

MAJOR FORMCHECKBOX

MINOR

FINDING:

FINDING IMPACT:

Please respond with a written corrective action plan that details the corrective action of the cited deficiency, the cause of the deficiency, and actions taken to prevent recurrence by Suspense Date in Block 5. If date was not entered in Block 5, the contractor is not required to provide a response.

8. QUALITY ASSURANCE PERSONNEL (COR)

TYPED NAME AND GRADE

SIGNATURE AND DATE

9. ISSUING AUTHORITY

TYPED NAME AND GRADE

SIGNATURE AND DATE

10. COR RESPONSE TO CONTRACTOR CORRECTIVE ACTION AND ACTION TAKEN TO PREVENT RECURRENCE

11. COR DETERMINATION

FORMCHECKBOX

ACCEPTED FORMCHECKBOX

REJECTED

12. CLOSE DATE

Appendix 3 - Customer Complaint Record

SOURCE OF COMPLAINT

ORGANIZATION

BUILDING NUMBER

INDIVIDUAL

PHONE NUMBER

NATURE OF COMPLAINT

CONTRACT REFERENCE

VALIDATION

DATE/TIME CONTRACTOR INFORMED OF COMPLAINT

ACTION TAKEN BY CONTRACTOR

RECEIVED/VALIDATED BY

Appendix 4 - Performance Assessment Report (PAR)

PERFORMANCE ASSESSMENT REPORT (PAR)

(If more space is needed, use reverse and identify by number)

4. QUALITY ASSURANCE PERSONNEL (COR) SIGNATURE AND DATE

I. PERFORMANCE

7. FORMCHECKBOX

DEFICIENCY (CHECK ALL BOXES THAT APPLY)

FORMCHECKBOX

NEW

FORMCHECKBOX

REPEAT

FORMCHECKBOX

NO DEFICIENCY NOTED

8. SERVICES SUMMARY or PWS PARAGRAPH ITEM REVIEWED

II. CONTRACTOR VALIDATION

11. CONTRACTOR REPRESENTATIVE FORMCHECKBOX

CONCUR FORMCHECKBOX

NON-CONCUR

12. CORRECTIVE ACTION ESTIMATED COMPLETION DATE

13. CONTRACTOR REPRESENTATIVE CORRECTIVE ACTION AND PREVENTION OF RECURRENCE OR REASON FOR NON-CONCURRENCE OF COR CITED DEFICIENCY

III. ACTION CORRECTED

14. FORMCHECKBOX

CONCUR FORMCHECKBOX

NON-CONCUR COR SIGNATURE AND DATE

15. COR REMARKS (REQUIRED)

6. CONTRACTOR REPRESENTATIVE REMARKS