Attachment 0013 Quality Assurance Surveillance Plan (QASP).pdf

AMCOM Combined Logistics Command

(ACLC)

Quality Assurance Surveillance Plan (QASP)

RFP:W58RGZ-26-R-0026

Version 1.0

ACLC QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

FORT RUCKER AVIATION MAINTENANCE CONTRACT (FRAM II) RFP:W58RGZ-26-R-0026

IAW FAR Part 46 quality assurance, Subpart 46.402, this plan meets requirements for Government quality surveillance plan on contract __________ and supersedes any previous versions of the QASP.

Effective Date: 16 January 2028

COL, AV

Commanding

Contracting Officer

DISTRIBUTION:

Contracting Officer ACLC Command Group ACLC Primary and Special Staff

- Property Administrator (PA)

- Facilities

- Safety

- Security

- Information Technology/ Information Management Office (IT/IMO)

- Environmental

ACLC FMX RUCKER (AIR)

- Cairns Army Airfield (CAAF)

- Hanchey Army Heliport (AHP)

- Knox AHP

- Lowe AHP

- Shell AHP

- MEDEVAC

- Consolidated Phase Maintenance (CPM)

- Aircraft Component Repair Branch (ACRB)

TABLE OF CONTENTS

1. PURPOSE

1.1. INTENT

1.2. AUTHORITY

2. GOVERNMENT ROLES AND RESPONSIBILITIES

3.0. CONTRACTOR ROLES AND RESPONSIBILITIES

4.0. OVERVIEW OF QASP

5.0. QA AUDITS

5.1. SCHEDULED AUDITS

5.2. OBSERVATIONS

5.3. EVALUATION AND GRADING CRITERIA

5.3.1 NON-CONFORMANCE CLASSIFICATION

5.3.2 AUDIT GRADING CRITERIA

6.0. MONTHLY QA AUDIT VALIDATION

7.0. QA AUDIT RECORDS MANAGEMENT SYSTEM (QARMS)

8.0. CORRECTIVE ACTION REQUESTS (CARs)

9.0. OTHER INSPECTED AREAS

9.1. PROPERTY ADMINISTRATION

9.2. INFORMATION MANAGEMENT

9.3. SECURITY

9.4. FACILITIES

9.5. AVIATION PROGRAM TEAM (APT)

10.0. OTHER INSPECTED AREAS SURVIELLANCE SCHEDULE

11.0. COR STATUS REPORTS

12.0. SERVICE CONTRACT REPORTING (SCR):

13.0. CONTRACTOR PERFORMANCE ASSESSMENT (CPARS)

14.0 COR/Quality Assurance Surveillance Files

15.0 APPENDIXES

1. PURPOSE

The purpose of this Quality Assurance Surveillance Plan (QASP) is to identify the methods and procedures the Government will use to ensure it receives the services under this contract as identified in the Performance Work Statement (PWS). This Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate performance for the stated contract. This QASP explains the following:

a. What will be monitored?

b. How monitoring will take place.

c. Who will conduct the monitoring?

d. How monitoring efforts and results will be documented.

e. When and how often monitoring will take place.

Monitoring provides a means for evaluating whether the Contractor is meeting the performance standards/quality levels identified in the contract, Contractor's Quality Management System (QMS), Quality Control Plan (QCP), and regulatory guidance.

This QASP 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. It is the Government’s responsibility to be objective, fair, and consistent in evaluating performance. This QASP recognizes that unforeseen and uncontrollable situations may occur.

The Contractor is responsible for implementing and delivering performance that meets and/or exceeds 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.

This QASP is a "living document" and the Government retains the unilateral right to revise the QASP as required to verify the quality of services received. 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. The Government will review the QASP at least annually to ensure it remains a valid, useful, and objective document. Copies of the original QASP and revisions shall be provided to Government officials implementing surveillance activities.

Name or position changes listed in this plan will be considered “pen and ink” changes until the next annual revision is released.

1.1. INTENT

The intent of this QASP is to: 1) ensure Contractor performance meets or exceeds contract terms, conditions and specifications; 2) hold the Contractor accountable for quality control; and 3) encourage the Contractor to take appropriate steps to control and improve quality. Accordingly, the Government will perform surveillance on the contract in accordance with this QASP but reserves the right to monitor the contract in any manner necessary, at any time necessary, and at all places necessary to ensure that the rendered services conform to contract requirements. The Government also reserves the right to perform quality assurance at the Subcontractor level and perform quality assurance at the contractor's place of business, if applicable. Resolution of non-conforming services discovered at the Subcontractor level will be addressed with the prime Contractor.

1.2. AUTHORITY

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 contract. This acceptance is to be executed by the Contracting Officer or a duly authorized representative.

2. GOVERNMENT ROLES AND RESPONSIBILITIES

The following personnel shall oversee and coordinate surveillance activities.

a. ACLC Commander: Provide the necessary surveillance resources to ensure

Government receives the level of product and services required in the PWS.

b. Contracting Officer (KO): The KO is the only person with the authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the Government. The KO shall ensure performance of all necessary actions for effective contracting, ensure compliance with the contract terms, and shall safeguard the interests of the United States in the contractual relationship.

The KO shall also ensure that the Contractor receives impartial, fair, and equitable treatment under this contract. The KO is ultimately responsible for the final determination of the adequacy of the Contractor's performance. Current KOs are as follows:

(1) (Name, telephone, email)

c. Lead Contracting Officer’s Representative (COR): Performs coordination and assists CORs in performing appointed duties. Coordinates and communicates with Contracting Officers and performs COR duties as described in the paragraph below.

Mentors and trains other CORs documenting contract performance. Reviews and provides tasking to the maintenance contractor. Coordinates input and rolls up the annual Contractor Performance Assessment Report (CPAR) as Assessing Official Representative (AOR). Assists ACLC Commander and FMX Rucker (Air) Chief in executing ACLC contract surveillance mission.

(1) Lead COR: Wade Pasquarella, wade.pasquarella.civ@army.mil (334)255-1923 mailto:wade.pasquarella.civ@army.mil

d. Contracting Officer's Representative (COR): CORs will be identified and designated by the KO on a separate COR appointment letter. The COR appointment letter will detail scope and functions the COR is required to perform. The COR monitors all technical aspects of the contract and assists in contract administration. The COR may be appointed to perform the following functions: assure that the Contractor performs the technical requirements of the contract: perform inspections necessary in connection with contract performance: maintain written and oral communications with the Contractor concerning technical aspects of the contract: monitor Contractor's performance and reporting early identification of performance problems to the Contracting Officer and Contractor; coordinate availability of Government furnished property, and provide site entry of Contractor personnel. The COR shall keep a surveillance file in Procurement Integrated Enterprise Environment – Surveillance and Performance Monitoring Application (PIEE-SPM) that accurately documents the contractor’s performance.

(1) Appointed CORs: See Appendix 15.3 COR Matrix

e. Property Administrator (PA): An authorized representative of the KO appointed in accordance with agency procedures (ACC CPM 715-2), responsible for administering the contract requirements and obligations relating to Government property in the possession of a Contractor. The primary objective of conducting a Property

Management System Analysis (PMSA) is to provide the KO with the sufficient and appropriate evidence required to make a reasonable determination as to the acceptability of a Contractor’s property management system based on contractual and regulatory requirements.

(1) Property Administrator: (Name, telephone, email)

f. Government Flight Representative (GFR): Appointed by the KO and is an authorized representative to administer the terms and conditions of the contract relating to AR 95-20, Flight Operations, Ground Operations, and Government Flight Risk Clause (GFRC). The GFR mitigates risk to the command footprint by measuring contractor compliance against every applicable paragraph of the AR 95-20, PWS, and service guidance.

(1) GFR: (Name, telephone, email)

g. Surveillance Support Personnel: Personnel in multiple functional specialties provide surveillance and technical support for CORs in monitoring Contractor's performance. Roles of these personnel include Equipment Specialists (ES), Safety Managers, Environmental Managers, Security Managers, Information Management Office, Quality Assurance Representatives (QAR), Industrial Property Management Specialists (IPMS), and Logistics Management Specialists (LMS).

3.0. CONTRACTOR ROLES AND RESPONSIBILITIES

a. Contract Manager: (Name, telephone, email)

b. Project Manager: (Name, telephone, email)

c. Quality Manager: (Name, telephone, email)

4.0. OVERVIEW OF QASP

a. Performance Areas are identified as a location or a distinct work/functional element. An Evaluation Area is defined as an audit scope topic. Each are identified as part of the surveillance schedule. Each evaluation area is an individual report and not combined, overlapped, or mixed. The QA program is reviewed by the KO and used in conjunction with the contract, PWS, contract attachments, and applicable references.

b. Periodic audits have a specified minimum monthly, quarterly or annual frequency for planning purposes as defined in the Surveillance Schedule. When scheduling QA audits, planning is concentrated on specific areas of interest or concern. Performance areas will provide recommended changes to the surveillance schedule to the ACLC QASP Program Manager prior to the start of the Quarterly rating period for consolidation. The Government reserves the right to adjust the number of Performance areas and Evaluation areas. Changes to the published Quarterly surveillance schedule will be forwarded to the COR's for concurrence and incorporated in the QASP once approved.

c. Notification of minimal scheduled evaluation amounts will be provided to the Contractor at the beginning of the Quarter. If decreases are required to the scheduled monthly amounts, the Contractor will be notified prior to the start of the performance month which the adjusted audits will take place. If the Government does not notify the Contractor of a decrease to number of audits scheduled, the projected numbers given at the start of the Quarter will remain the minimum required amount.

d. In addition to the purpose of determining technical compliance and locating systemic problems, every ACLC auditor will document all matters relative to the scope of the contract to include matters of fraud, waste, abuse, and inefficiency. The ACLC Brigade S3 oversees the ACLC QA through an Internal Compliance Auditing (ICA) program. Brigade S3 will schedule ICAs to be conducted, focus areas and feedback to the executing entity. This program encompasses every facet of surveillance on this contract.

e. To assist in the execution of surveillance, the Government Flight Representative (GFR) shall notify the ICA Manager of changes to approved Flight Operating Procedures (FOPs) and Ground Operating Procedures (GOPs) and the implementation date of any approved changes to procedures that would impact these audits/surveys.

The approved procedures will be posted for access by all surveillance personnel.

f. Contractor self-disclosure is highly encouraged in performance of contractual requirements. If the Contractor self-identifies a noncompliance, the Government will immediately document the event provided in an Observation and determine if additional actions are required.

g. IAW PGI 222.17 and FAR 52.222-50, the KO will be notified immediately of any information from any source that alleges a Contractor employee, subcontractor and/or subcontractor employee has engaged in conduct that violates the United States Government "zero" tolerance policy regarding trafficking in persons.

h. There are multiple types of surveillance performed on this contract. The Government will use the audit outcomes of all surveillance performed to focus future audits and identify trends. We will utilize a continuous loop surveillance system bringing different surveillance techniques together for a focused reduction in risk improving the product provided to the Army pilots. Outcomes of external audits performed by AMCOM or other Government entities can guide our surveillance focus areas.

i. Documentation of Observations and audits shall be performed in an objective and professional manner. Use of subjective words and standards should be avoided.

5.0. QA AUDITS

5.1. SCHEDULED AUDITS

a. Scheduled audits are conducted in evaluation areas used to determine the Contractor's compliance with the PWS and Contractor procedures and PWS IAW the surveillance schedule. The original Surveillance Activity Report (SAR) form will be prepared within the auditing database including supporting documents and audit evidence not already available to the Contractor in folders. The Performance Area Lead will review all documents and validate whether the overall evaluation is satisfactory or unsatisfactory. The completed audits will be sent electronically to the Contractor immediately and annotated with a suspense date for return with a corrective action. The Contractor remains responsible for routing, handling, and returning of all completed forms within the auditing database. Deficiencies annotated on the SAR form require Contractor corrective actions to be corrected within 10-calendar day suspense and document updated in the auditing database. ACLC Form 502 will be used to document this process.

(1). Aircraft Safety of Flight, Critical Safety Item, and Government directed mandatory QA stops: In addition to the scheduled QA audits, the Government QA shall conduct inspections and tests throughout the work processes [e.g., disassembly, reassemble, area closing, completion of work (final), Critical Safety Item (CSl)/Safety of Flight (SOF) characteristics, breaks of inspection (BOls) or after Maintenance Test Flights (MTFs)/Functional Check Flights (FCFs)]. While the QA may not normally inspect work that has not been inspected and accepted by the Contractor's quality inspector, the Government always retains the right to inspect the contractor's work at any point in the work process. The Contractor records their work accomplishments in the aircraft maintenance records, or other appropriate forms, and the QA will document his/her inspection and acceptance, or rejection of the work performed, by placing an entry within the appropriate points in the maintenance records. In addition to the maintenance records providing documentation of the audits, the QA will document and maintain copies of all scheduled, unscheduled and observations in the auditing database.

(1) When auditor finds deficiencies possibly resulting in an unsafe work environment, the auditor will bring the deficiency to the immediate attention of the Contractor's Management Staff for resolution and notify ACLC Safety, Performance Area Lead and cognizant COR.

b. SAR Extensions: All extensions must be requested through the Performance Area Lead prior to suspense date. This request shall contain the control number of the audit, suspense date, and the reason for delay. The Performance Area Lead may approve up to a three-calendar day extension based on reason for delay. All approvals and disapprovals must be kept in a file for record. If a second extension or an extension longer than the three days is requested, the Contractor must submit a letter to the Lead COR with reason for delay and date requested for return. Once approved this letter will then be sent to the QASP Program Manager to be filed and the date mortified for the extension.

c. Inadequate Corrective Actions: When the Contractor returns the completed audit with corrective actions annotated, it will be reviewed to ensure the response is satisfactory. Inadequate corrective action responses to scheduled audits will be returned to the Contractor by the Performance Area Lead with a three-calendar day suspense. The following actions will take place:

(1). The SAR will remain open until satisfactory corrective action is received.

(2). It will be documented on an observation form and submitted as a non-compliance to the Contractor.

(3). The performance area COR will have a discussion with the corrective action submitter, management, and/or PM.

(4). May be elevated to a CAR if appropriate.

d. Re-audit: A follow-up audit will be conducted to ensure prompt and effective corrective action has been taken on reported deficiencies. SAR re-audits of Contractor’s corrective action will be conducted within five business days of receiving adequate response to validate compliance.

(1). Failed Re-Audit: Re-audits finding the Contractor not in compliance with their stated corrective action will be documented as an Unsatisfactory audit. In this case, the Performance Area Lead will open a new line on the ACLC 501 and document accordingly as a scheduled audit. Continued failure to correct discrepancies or trends could escalate to a CAR.

(2) SAR forms returned by the Contractor with a satisfactory / unsatisfactory corrective action and satisfactory / unsatisfactory re-audit will be retained within the auditing database.

5.2. OBSERVATIONS

Observations are used for faults/findings, on-the-spot corrections found outside of scheduled evaluations or to note exceptional findings of improvement or performance.

This action will be documented in the auditing database 601 process. Documentation of discrepancies found outside of scheduled evaluations is of vital importance to show problems in specific areas. No response is required unless specified by the Government on the Observation. The Contractor will have 10 calendar days to provide a response, if required. The Contractor may choose to respond when not requested by the Government to ensure all pertinent information related to the Observation is documented. Inadequate responses to observations will be returned to the Contractor by the Performance Area Lead with three business day suspense.

ACLC Form 511 will be used to document this process. The following actions will take place:

(1). The observation will remain open until satisfactory corrective action is received.

(2). It will be documented on another observation form and submitted as a non-compliance to the Contractor.

(3). The performance area COR will have a discussion with the observation response submitter, management, and/or PM.

(4). May be elevated to a CAR if appropriate.

5.3. EVALUATION AND GRADING CRITERIA

5.3.1 NON-CONFORMANCE CLASSIFICATION

Quality systems will be evaluated upon the standardized criteria based on faults found and the compliance to the PWS, AS9100D Army Regulations, Technical Manuals, Contractor's Quality Control Plan and Procedures. Each non-conformance will be classified using the following guidelines:

a. Critical nonconformance: Non-conformances that include, but are not limited to, the following items:

(1). All nonconformities that create a hazardous or unsafe environment or product.

(2). Any Management or Quality failure which, may cause injury, major property damage, or major system damage that will result in major downtime in maintenance, loss of supplies or services, or is likely to prevent performance of the mission and causes monetary impact to the Government.

(3). Discrepancies which would result in failure or materially reduce the usability of the product for the intended purpose.

(4). Discrepancies for Contractual, Regulatory or Procedural non-compliance or performance that are likely to affect the usability of an item or require rework to make item usable for the intended services.

(5). Repetitive management system failure which may cause major delay to customer or contractual compliance.

(6). Non-conformities that result in records inaccurately representing the actual airworthiness status of an aircraft.

(7). Discrepancies that create non-conformance with PWS or contractual requirements.

b. Major nonconformance: Non-conformances that include, but are not

(1). May cause property damage.

(2). Minor system damage that will result in minor downtime in maintenance.

(3). The loss of supplies or services or is likely to prevent performance of the mission and could cause monetary impact to the Government.

(4). Discrepancies which would reduce the usability of the product for the intended purpose.

(5). Discrepancies for Regulatory or Procedural compliance or performance that are likely to affect the usability of an item or require minor rework to make item usable for the intended services.

(6). Management system failure which is repetitive and may cause minor delay to the customer or regulatory and procedural compliance.

(7). Discrepancies that create non-conformance with PWS or contractual requirements.

c. Minor nonconformance: Non-conformances that include, but are not

(1). Does not adversely affect the performance, use or operation of the item.

(2). Discrepancy that would not cause property damage, downtime in maintenance, loss of supplies or services, and likely to prevent performance of the mission causing no monetary impact to the Government.

(3). Discrepancies for Procedural compliance that affects the usability of an item or require no rework to make item usable for the intended services.

(4). Management system failure which is non-repetitive which may cause a delay to the customer or lead to procedural non-compliance.

(5). Discrepancies that create non-conformance with PWS or contractual requirements.

5.3.2 AUDIT GRADING CRITERIA

Grading Criteria: Criteria used allows four points before audit is considered Unsatisfactory. A Critical finding is rated as four points, a Major finding is rated as two points and a minor finding is rated as one point.

The overall QA assessment of Satisfactory or Unsatisfactory Contractor compliance is based upon the audit results. The measurement system relies on standards of conformance within established guidelines and contractual requirements.

a. Satisfactory: The inspected area maintains a fair and reasonable level of compliance that is acceptable established criteria. The inspected area may have major and/or minor nonconformance(s), but will rate satisfactory overall, scoring less than four points.

b. Unsatisfactory: The inspected area is found to contain a level of noncompliance that is unacceptable within the established criteria. The inspected area has critical non-conformance or accumulated major and/or minor nonconformance(s) that rate unsatisfactory totaling four or more points.

6.0. MONTHLY QA AUDIT VALIDATION

The 503 and 504 process timelines below are based on a performance month occurring from the 16th to the 15th ( i.e. 16 JAN-15 FEB). If contract award is delayed and the performance month period changes the calendar due dates will be adjusted to match the new performance month period.

6.1. 503 Process (Performance Area review)

a. The Contractor may request a monthly review with the Performance Area COR of specific QA audits where the technical validity of findings is inaccurate. The review will be requested by the Contractor through the Performance Area Lead/COR and documented in the auditing database 503 process. If the Contractor chooses not to submit items for reassessment, the Contractor will notify the Performance Area Lead/COR stating the Contractor requests no items for reassessment that month, which closes the opportunity for consideration. Contractor requests submitted after the dates below without an approved extension will not be considered.

(1) The Contractor will provide the control number of the QA audit, specific faults for technical review, substantiating documentation, and justification in writing to the Performance Area Lead/COR NLT the 1st calendar day of the month.

(2) The COR will review the submitted data and meet in person with the Contractor to discuss NLT the 10th calendar day of the month.

(3) The COR will annotate the final determination within the database and complete ACLC Form 503 NLT two business days after the meeting.

6.2. 504 Process (BN/BDE level review)

a. The Contractor Quality Director will identify any monthly 503 determinations for the previous performance month where new evidence or information is available to the QASP Program Manager NLT the 15th calendar day of the month for final determination by a BN/BDE level COR. This action will be documented in the auditing database 504 process. Any faults not discussed during the 503 process ARE NOT ELIGIBLE for the 504 process. BN/BDE level CORs include the FMX Rucker (Air) Chief, BAMO, or SPO and the BDE Lead COR and S3.

(4) The designated COR will review the documentation and evidence submitted by the Contractor and discuss with Performance Area Leads and Subject Matter Experts (SMEs) as necessary. Once all facts are reviewed and a decision is made, the designated BN/BDE level COR shall provide final determination to the Contractor within 10 calendar days after receipt. Feedback will be provided to the Performance Area Leads and SMEs.

b. Any requests received by the QASP Program Manager later than established suspense dates will not be considered unless an extension was approved by the FMX Rucker (Air) Chief or Lead COR.

503/504 Timeline

Date Event

16 January-15 February Performance month period covered

1 March Contractor submits any items for 503 process

10 March COR holds meeting with Contractor

10 March + 2 business days

COR completes ACLC Form 503 with decision

15 March Contractor submits any items for 504 process

25 March Designated BN/BDE level COR provides final decision.

7.0. QA AUDIT RECORDS MANAGEMENT SYSTEM (QARMS).

a. ACLC records and stores all surveillance records under the QA program within iACLC or approved system Each performance area will maintain a file of all evaluations performed in their original format and provide a copy of this file to the COR for inclusion in required documentation. This file is maintained on a contract year basis and serves as a master record of all evaluations performed. All CORs must utilize the Procurement Integrated Enterprise Environment (PIEE) to upload copies of all unclassified contract surveillance documents required by the KO IAW DoDI 5000.72, DFARS PGI 201.602-2, AR 70-13 paragraph 2-2g and ACC Instructions.

b. PDREP Process:

(1) All CARs will be entered into PDREP by Brigade S3. This is an Army Federal Acquisition Regulation Supplement (AFARS) requirement to allow more visibility to the CARs processed by ACLC.

(a) All information will be entered from the iACLC surveillance database into

PDREP as necessary for processing the CAR.

(b) Once entered, it will be processed to the Contract Specialist team for their review and editing as required.

(c) Once the review is completed, it will be forwarded to the KO’s to issue the CAR to the Contractor. The PDF fillable version of the CAR will be attached to the

PDREP CAR.

(d) Once a CAP is received from Contractor, will enter all applicable information into PDREP.

(e) When the CAP is accepted or rejected, Brigade S3 will enter all applicable information into PDREP.

(f) Once Re-Audit is completed, Brigade S3 will enter all applicable information into PDREP.

(g) Once the Follow-up (Level 2 CARs and above) is completed, Brigade S3 will enter all applicable information into PDREP.

(h) Once all steps are completed in the CAR process, Brigade S3 will inform the KOs to email the Contractor and close the CAR.

(2) iACLC surveillance database will contain all information and audit evidence for every CAR submitted to the Contractor.

8.0. CORRECTIVE ACTION REQUESTS (CARs)

A Corrective Action Request (CAR) is used as a notice to the contractor to document a nonconformance, notify the contractor of Government rejection of supplies or services not conforming to contract requirements, and to require contractor corrective action. The purpose is to provide the contractor an opportunity to correct or replace nonconforming supplies and services when this can be accomplished within the required delivery schedule IAW FAR 46.407, contract terms and conditions. This action will be documented in the auditing database 801 process.

a. The DoD has four (4) levels of CARs. The level depends on the severity of the non-conformance. The levels are:

(1) Level I CAR may be issued when:

(a). Non-conformance is not likely to materially reduce the usability of services for their intended purpose;

(b). Is a departure from established standards related to the requirement;

(c). Minor non-conformances can usually be corrected on the spot, doesn’t affect aircraft worthiness, doesn’t involve elevated risk and no significant damage to Government property.

(d). A root cause and corrective action plan are required.

(2) Level II CAR may be issued when:

(a). Non-conformance is likely to result in failure of the services to meet contract requirements;

(b). Reoccurring non-conformances;

(c). Escalation of level I CARs with ineffective corrective actions;

(d). Trends indicating failure of the Contractor’s QCP;

(e). Affects aircraft airworthiness;

(f). Elevated risk to the Government or significant damage to Government property.

(g). A root cause and corrective action plan are required.

(h). A Level II CAR does not require prior submission of a lower-level CAR.

(3) Level Ill CAR may be issued when:

(a). Non-conformance is likely to result in hazardous or unsafe conditions due to the way the services are performed, prevent or impact a vital agency mission as a result of performance;

(b). Escalation of level I or level II CARs with ineffective corrective actions;

(c). Trends indicating failure of the Contractor’s QMS, Safety Of Flight (SOF) impacts;

(d). Failure to correct elevated risk to the Government and damage resulting in loss of Government equipment.

(e). A root cause and corrective action plan are required.

(f). A Level Ill CAR does not require prior submission of a lower-level CAR.

(g). May require ACC-RSA SCO approval before issuance.

(h). Issuance of Level III / IV CARs require a Serious Incident Report (SIR) or

Commander's Critical Information Requirement (CCIR) submission. The type of report depends on the severity of the nonconformance.

(4) Level IV CAR may be issued when:

(a). Directed by the ACO/KO.

(b). The issue is serious enough in nature to require immediate correction greater than Level III CAR would provide.

(c). The remedies implemented by a lower-level CAR was either ineffective at resolving the issue or preventing it from recurring.

(d). Total QMS failure resulting in loss of life, potential loss of life or total loss

Government property.

(e). A root cause and corrective action plan are required.

(f). Level IV CAR does not require previous submission of a lower-level CAR.

(g). May require ACC-RSA SCO approval before issuance.

b. Instructions in this QASP concerning the issuing of Corrective Action Requests does not prohibit the KO or COR from taking other or additional appropriate corrective actions afforded to them by regulation or appointment authority to remedy nonconformance or unsatisfactory performance.

c. CAR submissions

(1) The CAR submitter will make a storyboard utilizing the ACLC PowerPoint template provided by Brigade S3. The storyboard will contain all relevant facts, audit evidence, and pictures (if required). The FMX Rucker (Air) Chief will be briefed on all CARs prior to submission into PDREP.

d. The Contractor shall have three business days from receipt of any CAR to request reevaluation from the Brigade S3based on validity concerns. The Contractor shall submit a written explanation and supporting evidence. The Contractor may request a meeting to discuss the reevaluation request. The Government will provide a written response NLT seven business days from receipt of the reevaluation request or requested meeting, whichever is later. The original CAR response date is not adjusted for this action without a request through the Brigade S3for approval.

e. The Contractor has a 15-calendar day suspense for all Level I thru IV CARs unless otherwise stated. If the required suspense date falls on a weekend or holiday, the Contractor will be given until the next scheduled workday to submit their response.

The Contractor shall provide a root cause and corrective action plan for correcting the non-conformance with a date of full compliance. All areas identified in the CAR will be re-audited to ensure effectiveness of corrective action. The contractor’s response should focus on both the action in question and long-term prevention of re-occurrences.

The government is not required to accept the contractor’s CAP as written.

f. Upon receipt of the CAR response from the Contractor, the issuer of the CAR will review of contractor submitted CAPs, accept or reject the CAP within 5 business days for Level II, and 10 business days for Level III / IV CARs. .

(1) If accepted, Issuer will sign in appropriate block and send to QSD Chief for processing.

(2) If response is rejected, the QSD Chief will provide an explanation of rejection and new suspense date in a letter of inadequate response to the Contractor. The letter of inadequate response has a five calendar day response requirement. If Contractor fails to resolve corrective action response issues, an escalated corrective action request may be written for failure of the corrective action system.

g. Request for extension of CAR suspense dates must be sent to the Brigade S3 prior to the suspense date. The request must contain the control number, suspense date, reason for delay, and the proposed date of return.

h. Re-audit: A re-audit will be scheduled after date of full compliance within 30 calendar days to 45 calendar days to ensure corrective action plan remedied the non-conformance preventing reoccurrence. Non-conformances of CAP after date of full compliance can qualify as failed re-audit. Facts and audit evidence collected after date of full compliance will be used to determine conformance and will be annotated in the auditing database.

i. Failed Re-Audit: Re-audits finding the Contractor not in compliance with their stated corrective action will be documented in the auditing database. One of the following two steps can be taken:

(1) Adjusted CAP: The contractor will be notified and given five calendar days to provide their plan for compliance to the government. Re-audit procedures will be followed in paragraph 8.i. above.

(2) Escalate CAR Level: Higher-level CAR may be submitted through PDREP.

9.0. OTHER INSPECTED AREAS

9.1. PROPERTY ADMINISTRATION

a. The primary objective of the property administration function is to attain efficient, economic, and uniform management of all Government property required for the performance of the contract. The function is mainly to administer the terms of contract provisions that specify the Contractor's obligation to acquire, control, use, care for, report, and dispose of Government property, and to advise contracting activities and other DoD officials of the known level of efficiency of the Contractor's management of Government property.

b. The PA administers contract provisions to assist the Contracting Officer with approving the Contractor's Property Management System and to perform annual reviews of the Contractor's system to ensure compliance and grant relief of responsibility and liability for loss when applicable.

c. The analysis of the Contractor's Property Management System (PMS) is a critical responsibility assigned to the PA. Through this analysis, the PA determines whether the Contractor is effectively and efficiently complying with the terms and conditions of the contract, regulatory requirements, and other special requirements contractually imposed by the Procuring Activity.

d. The Contractor's PMS and Government oversight are the safeguards established for ensuring that the Contractor exercises adequate care and control of Government property in their custody.

e. The KO and PA are the only Government agents authorized to:

(1) Allow Government property accountable under one contract to be used in the performance of another contract.

(2) Authorize the Contractor to obtain property for use under a contract.

(3) Conduct a PMSA. Support surveillance personnel will be used to perform audits and gather the necessary information.

(4) Relieve Contractor of liability for the Loss of Government Property.

(5) Direct Contractor in regards to the disposal or reutilization of GFP.

f. Surveillance of the Contractor during performance will consist of analyses developed from the Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS), Army Regulations, Contractors PMS and locally developed inspections designed to provide insight into more narrowly defined portions of the Contractor's PMS. Annual analyses and audits will be conducted by the Industrial Property Management Specialist (IPMS) at their assigned field/area or the PA.

(1) Property Lifecycle Process Outcomes:

(a) Outcome 1: Acquisition (Including MILSTRIP) – ensures the Contractor documents that all property was acquired consistent with its engineering, production planning, and property control operations.

(b) Outcome 2: Receipt of GP / Identification / Movement – ensures the

Contractor receives Government property and documents the receipt, records the information necessary to meet the record requirements of the FAR, identify as Government owned in a manner appropriate to the type of property (e.g., stamp, tag, mark, or other identification), and manage any discrepancies incident to shipment.

(c) Outcome 3: Records of Government Property – ensures the Contractor creates and maintains records of all Government property accountable to the contract, including Government-furnished and Contractor-acquired property.

(d) Outcome 4: Physical Inventory TDA / Installation Property – ensures the Contractor periodically performs, records, and discloses physical inventory results. A final physical inventory shall be performed upon contract completion or termination. recorded.

(e) Outcome 5: Subcontractor Control – ensures the Contractor awards subcontracts that clearly identify items to be provided and the extent of any restrictions or limitations on their use. The Contractor shall ensure appropriate flow down of contract terms and conditions (e.g., extent of liability for loss of Government property).

(f) Outcome 6: Reports – ensures the Contractor has a process to create and provide reports of discrepancies, loss of Government property, physical inventory results, audits and self-assessments, corrective actions, and other property-related reports.

(g) Outcome 7: Relief of Stewardship, Responsibility and Liability – ensures the Contractor has a process to enable the prompt recognition, investigation, disclosure and reporting of loss of Government property, including losses that occur at subcontractor or alternate site locations.

(h) Outcome 8: Utilization / Storage – ensures the Contractor utilizes, consumes, moves, and stores Government Property only as authorized under this contract. The Contractor shall promptly disclose and report Government property in its possession that is excess to contract performance. stewardship.

(i) Outcome 9: Maintenance – ensures the Contractor properly maintains Government property. The Contractor’s maintenance program shall enable the identification, disclosure, and performance of normal and routine preventative maintenance and repair. The Contractor shall disclose and report to the Property Administrator the need for replacement and/or capital rehabilitation.

(j) Outcome 10: Disposition of Government Property – ensures the Contractor promptly performs and reports to the Property Administrator contract property closeout, to include reporting, investigating and securing closure of all loss of Government property cases; physically inventorying all property upon termination or completion of this contract; and disposing of items at the time they are determined to be excess to contractual needs.

9.2. INFORMATION MANAGEMENT

a. Information technology and automation requirements will be evaluated upon the standardized criteria based on faults found and the compliance to the PWS, Army Regulations, Contractor's Quality Control Plan and Procedures. Periodic audits are conducted and used to determine the Contractor's compliance.

9.3. SECURITY

a. The ACLC Security Manager/COR provides the KO, guidance and oversight of

Contractor's security plans, adherence to security regulations and compliance with Defense Security Service (DSS) policies and procedures in relationship to the Performance Work Statement. The ACLC Security Manager/COR is responsible to ensure the Contract Security Classification Specification, DD Form 254 is prepared, reviewed, and implemented by the Contractor. Periodic audits are conducted and used to determine the Contractor's compliance with Contractor procedures and Performance Work Statement.

9.4. FACILITIES

a. The ACLC Facility Manager advises the CDR, ACLC, on all matters relating to facilities management directly impacting ACLC daily mission requirements. In addition, ACLC Facility Manager provides the KO and PA guidance on contract oversight of Contractor's facility utilization and maintenance of assigned facilities with adherence to AR 420-10 and AR 420-11 and Contractor's policies and procedures. Periodic audits are conducted and used to determine the Contractor's compliance with Contractor procedures and Performance Work Statement.

b. ACLC Facility Manager provides review and approval of Contractor submitted work requests (DA 4283) for repair, construct or renovation to Government furnished facilities. They will coordinate an annual facilities utilization survey to ensure Contractor utilization of Government furnished facilities follow regulatory guidance.

c. ACLC Facility Manager provides project oversight on construction projects, renovation, and major repairs on the ten-year plan for Major Construction Army (MCA) and Unified Minor Military Construction Army. They coordinate with Garrison and 1- 110th Airfield Commanders for approval on communication, physical security, fire prevention, and airspace safety on any facility related work requirements. Lastly, they provide technical review and coordination of all construction plans, contracts, and statements of work to perform repairs or construct Government facilities.

d. ACLC Facility Manager conducts and reviews annual installation status reports for Department of Army and Department of Public Works (DPW). They provide complete review of facilities issues, providing command attention to work orders that directly affect mission, safety, security, or environmental hazard ensuring Service Orders and work requests submitted to DPW are provided in the time required by assigned priorities.

9.5. AVIATION PROGRAM TEAM (APT)

a. Government Flight Representative (GFR) mitigates risk to the command footprint by measuring contractor compliance against every applicable paragraph of the AR 95- 20, PWS and Service Guidance. GFR and Alternate GFR (AGFR) are synonymous.

IAW AR 95-20, the Primary GFR approves:

(1) Contractor Flight Operating Procedures (FOP),

(2) Contractor Ground Operating Procedures (GOP),

(3) All Contractor flights,

(4) Crewmembers,

(5) Maintenance activities for the contractor ensuring contractor compliance with applicable provisions of AR 95-20,

(6) Contractor Crewmember Status confirming compliance with AR 95-20

(DD2628),

(7) Contractor Qualification or Upgrade Training confirming compliance with AR

95-20 (DD 2627),

(8) Rescinding of Crewmember status as applicable in compliance with applicable provisions of AR 95-20,

(9) The Government’s assumption of risk for aircraft damage, loss or destruction while in possession of the contractor utilizing the DFARS 252.228-7001 Ground and Flight Risk Clause.

b. Aviation Program Team Survey.

(1) The intent of the APT Survey is to validate contractor compliance with the requirements of the contract, AR 95-20 and their Procedures to minimize the risk of loss, and to indicate what management attention is necessary to prevent occurrence/recurrences.

(2) The flight and ground APT survey is an onsite evaluation of the effectiveness of contractor flight and/or ground operations and Procedures protecting Government resources and assets.

(3) The APT is responsible for performing Contract Administration Services (CAS) functions under FAR Subpart 42.302.

(a). APT consists of the GFR, AGFRs, Ground Government Representatives (GGRs), Safety Manager, Quality Assurance Specialist (QAS) and other Subject Matter Experts as required.

(b).Contract Safety Manager (CSS/CSM) and Quality Assurance Specialist

(QAS) where FAR 42.302(a)(38) is assigned.

(4) The schedule of the APT survey will be at least once a year, based on the contract start date. The survey will be contract wide, so all airfields / locations on Fort Rucker will be surveyed. Surveys may be conducted plus or minus two months of the anniversary of the previous survey dates IAW AR 95-20.

(5) The GFR will maintain and adjust the master schedule of the APT surveys for all the current contracts to align with the contract start date. This master schedule will be distributed to the following ACLC personnel: Commander, Deputy Commander, Administrative Contracting Officer (ACO), all Division Chiefs, all Contracting Officer Representatives (COR), and all AGFRs/GGRs.

(6) The GFR will provide a 30-day notification to the contractor IAW AR 95-20.

(7) The GFR will provide formal in brief with the Contractor and Government team providing the setting for the conduct of the survey.

(8) All surveys conducted will be contract wide. The assigned GFR, AGFR, and

GGR will conduct the survey for their respective airfields/locations. As needed, and if available, the other AGFRs and GGR’s can assist the assigned team during the survey and documenting of the survey findings for that airfield/location. The survey team will utilize documented findings from the routine surveillance performed during the period after the last previous conducted APT Survey and will review QASP data for the same period to identify trending areas for the in-progress survey. Trends developed from any of the prior surveillance formed could result in an APT finding or escalate risk for findings also found during the in-progress survey that relate to the trend. The Primary

GFR, with assistance from the AGFRs will conduct the survey of all the Flight

Operations Procedures during the surveillance months and/or during the actual survey.

(9) During the APT survey month, the GFR Team will consolidate all the findings from the surveillance months and trending areas of all the airfields/locations. The GFR will officially schedule the APT out brief to the contractor and post the Executive

Summary and FDS. The Executive Summary and out-brief are completed on or about the 1st day of the month following the survey month.

(10) The auditing database will be utilized to create, document, and store all APT

Surveys and results. The contractor will be required to provide the responses to the findings within the auditing Database. A file folder within the ACLC share drive may be created to assist with storing audit evidence and any other items related to the specific

Survey. It will be stored in the shared drive and labeled (example xx, CY25 XXXX

Annual APT (Active)). Once all findings have a response from the contractor and the

APT Survey officially closed, the file folder created on the share drive will be moved to a historical folder.

(11) The Health Assessment will be utilized to assign level of risk assigned to any finding (APT Survey or routine surveillance) based upon collective input by the APT and or auditor.

(12) Determination of the overall health of the contractor’s operations for adequacy of, compliance with, and effectiveness of the Procedures:

(a). Health of Operations Weight Point deductions: Compliant = 0; Discrepant =

3; Non-Compliant = 5.

(b). Performing operations without Procedures that have not been approved in writing by the GFR place may place the aircraft under unreasonable conditions and will be automatically assessed as non-compliant and assessed at 5 points.

(c). Performance of aircraft APU/engine operations in a non-current status are automatically assessed as non-compliant and are assessed at 5 points.

(d). Mathematical formula determines the basic weight point value for each area, overall scoring is accessed by reducing total weight by points accessed for Discrepant and Non-Compliant areas. For an area to be non-compliant most of an area’s (¾ or 75%) sub-tier paragraphs would have to be non-compliant with the procedures.

(e). Calculated APT Acceptability Score below 75.00 is rated as Not

Acceptable-High (Highest possible Score is 100). Modeled after AR 700-

138 Department of the Army Status Reporting.

(13) GFR will brief the ACLC Command and Division Chiefs to coordinate findings, ensure risk…