Attachment 1 - Quality Assurance Surveillance Plan.pdf

Quality Assurance Surveillance Plan (QASP)

The contractor will be evaluated in accordance with the following:

1. PURPOSE

This Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate performance for the stated contract. This QASP explains the following:

• What will be monitored?

• How monitoring will take place.

• Who will conduct the monitoring?

• How monitoring efforts and results will be documented.

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 is a “living document” and the Government may review and revise it on a regular basis. However, the Government shall coordinate changes with the contractor through contract modification. Copies of the original QASP and revisions shall be provided to the contractor and Government officials implementing surveillance activities.

2. GOVERNMENT ROLES AND RESPONSIBILITIES

The following personnel shall oversee and coordinate surveillance activities.

a. Contracting Officer (CO) – The CO 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 CO shall also assure that the contractor receives impartial, fair, and equitable treatment under this contract. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance.

Assigned CO: Andrew Schoenecker

Organization or Agency: Network Contract Office 23, St. Paul, MN

b. Contracting Officer’s Representative (COR) – The COR is responsible for technical administration of the contract and shall assure proper Government surveillance of the contractor’s performance. The COR shall keep a quality assurance file. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government’s behalf.

Assigned COR: Kathy Kriener-Klink, Jennifer Miner (alt POC)

Organization or Agency: VA-Central Iowa Health Care System (VA-CIHCS) Health Care for Homeless Veterans (HCHV).

3. CONTRACTOR REPRESENTATIVES

The following employee(s) of the contractor serve as the contractor’s program manager(s) for this contract:

Primary:

Alternate:

4. PERFORMANCE STANDARDS

The contractor is responsible for performance of ALL terms and conditions of the contract. CORs will provide contract progress reports quarterly to the CO reflecting performance on this plan and all other aspects of the resultant contract. The performance standards outlined in this QASP shall be used to determine the level of contractor performance in the elements defined. Performance standards define desired services. The Government performs surveillance to determine the level of Contractor performance to these standards.

The Performance Requirements are listed below in Section 6. The Government shall use these standards to determine contractor performance and shall compare contractor performance to the standard and assign a rating. At the end of the performance period, these ratings will be used, in part, to establish the past performance of the contractor on the contract.

5. METHODS OF QA SURVEILLANCE

Various methods exist to monitor performance. The COR shall use the surveillance methods listed below in the administration of this QASP.

a. DIRECT OBSERVATION. 100% surveillance: (if this method is used, define how surveillance will be accomplished.)

b. PERIODIC INSPECTION. Inspections scheduled and reported quarterly per COR delegation or as needed.

(Define what and how often it will be inspected. For example, ten (10) randomly selected patient files will be reviewed per inspection period. All inspections and reports will be conducted in compliance with VA Privacy and Information security standards.)

c. VALIDATED USER/CUSTOMER COMPLAINTS. If this method is used, explain how data will be collected and reported.

d. RANDOM SAMPLING. If this method is used, define what and how often it will be sampled. (For example, ten

(10) randomly selected patient files will be reviewed per quarter. All reviews and reports will be conducted in compliance with VA Privacy and Information security standards.)

e. Verification and/or documentation provided by Contractor. Review PWS and if this method of surveillance is selected, define how documentation will be verified and how assessment will be conducted. (For example, off-site contracts may require the contractor to provide information on services provided to patients).

6. SAMPLE QASP PERFORMANCE REPORT DATE:__________________

Measures PWS

Reference

Performance

Requirement

Standard Acceptable Quality Level

Surveillance

Method

Met AQL/DID NOT MEET AQL-

CPAR RATING/ADD COMMENTS

Key Personal Qualifications and Training

8.1., 8.2., 8.5.1., 8.5.3., 11.1.3.

All Contractor staff are trained on time per VA policy. Designated staff available 24/7 for same day Veteran referral.

All of required training is complete on time by contractor’s employee(s) with documentation available upon request by VA representative (para. 8.5.3.).

95% Ongoing periodic reviews/ inspections (quarterly and annually) under this contract.

Referral and Veteran Access 2.1.1., 3.1.3., 8.1.1., 11.1.4.2.

The Contractor is able to provide housing to eligible homeless Veterans on the same day, 24/7 as outlined in the PWS (Para.

2.1.1., 3.1.3., 8.1.1.).

All referred Veterans able to placed in housing within 24 hours of opening/ availability in the CERS program.

95% Ongoing periodic reviews/ inspections (quarterly and

Provide Basic Services Quality Performance

2.1., 11.1.4.3.

Provide basic services to include (para. 2.1.):

housing, room and board, and laundry for all referred Veterans under the contract.

All services meet standards.

95% Ongoing periodic reviews/ inspections (quarterly and

Provide Therapeutic and Rehabilitative/ Transportation Services

2.2., 2.3., 2.4., 2.5., 2.6., 11.1.4.4.

Contractor will provide Case Management and Therapeutic and Rehabilitative Services to address housing issues per Individualized care plan documented in Veteran’s case record.

(para 2.2., 2.3., 2.4., 2.5, 2.6.): Services may involve: Collaboration, Supportive Services, Case Management, Life Skills, Supportive Substance

All services meet standards.

95% Ongoing periodic reviews/ inspections (quarterly and annually) under this contract.

Documentation in the Veteran’s Case Record. Veteran’s report.

Collaboration with the VA. Evaluation will be based upon contractor ability to

Free Living Environment, Resources for Mental Health and Substance Disorder Issues, and Community Interaction.

provide the following elements (para 2.2., 2.3., 2.4., 2.5., 2.6.)

Life Safety Code Compliance/ Veteran Safety

3.2.4., 4.2., 4.3., 6.1., 6.2., 11.1.4.5.

Facilities shall meet required Life and Safety Codes of the NFPA, and all required state and local codes/ standards. Patient safety incidents shall be reported to the VA within 24 hours and submitted in writing within 48 hours.

All (100%) of patient safety incidents are reported in writing to the VA within 24 hours of incident.

100% Direct Observation.

Ongoing periodic reviews/ inspections (quarterly and annually) under

Patient report.

Documentation and Invoicing 10.1., 10.2., 13.2.1., 13.2.3.1., 11.1.4.6.

Complete required documentation for monthly invoicing. Submit invoices within 30 days of the charge becoming payable.

All (100%) invoice(s) must have all required documentation and correct information.

Must be submitted within 30 days of becoming payable.

100% Review (monthly) invoices and IPPS history.

Privacy, Confidentiality and

HIPAA

2.4., 2.5., 13.4, 11.1.4.7.

Comply with assigned Privacy, Confidentiality, and HIPAA training per contract/VA requirements.

All (100%) contractor’s employees comply with all laws, regulations, policies and procedures relating to Privacy, Confidentiality, and

HIPAA

100% Periodic Sampling;

Contractor shall keep records in employee’s file of trainings required by VAMC, and provide to VA COR upon request.

Reports violations per VA Directive 6500.6.

7. CPAR RATINGS ASSIGNED TO QASP ITEMS:

Metrics and methods are designed to determine rating for a given standard and acceptable quality level. The following ratings shall be used (Reference: CPARS User Manual https://www.cpars.gov/pdfs/CPARS-Guidance.pdf p. A2-1):

EXCEPTIONAL: Performance meets contractual requirements and exceeds many to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with few minor problems for which corrective actions taken by the contractor were highly effective.

Note: To justify an Exceptional rating, you should identify multiple significant events in each category and state how it was a benefit to the GOVERNMENT. However a singular event could be of such magnitude that it alone constitutes an Exceptional rating. Also there should have been NO significant weaknesses identified.

VERY GOOD:

Performance meets contractual requirements and exceeds some to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor were effective.

Note: To justify a Very Good rating, you should identify a significant event in each category and state how it was a benefit to the GOVERNMENT. Also there should have been NO significant weaknesses identified.

SATISFACTORY:

Performance meets contractual requirements. The contractual performance of the element or sub-element contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory.

Note: To justify a Satisfactory rating, there should have been only minor problems, or major problems the contractor recovered from without impact to the contract. Also there should have been NO significant weaknesses identified.

MARGINAL:

Performance does not meet some contractual requirements. The contractual performance of the element or sub-element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented.

Note: To justify Marginal performance, you should identify a significant event in each category that the contractor had trouble overcoming and state how it impacted the GOVERNMENT. A Marginal rating should be supported by referencing the management tool that notified the contractor of the contractual deficiency (e.g. Management, Quality, Safety or Environmental Deficiency Report or letter).

UNSATISFACTORY:

Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The contractual performance of the element or sub-element being assessed contains serious problem(s) for which the contractor’s corrective actions appear or were ineffective.

Note: To justify an Unsatisfactory rating, you should identify multiple significant events in each category that the contractor had trouble overcoming and state how it impacted the GOVERNMENT.

However, a singular problem could be of such serious magnitude that it alone constitutes an unsatisfactory rating. An Unsatisfactory rating should be supported by referencing the management tools used to notify the contractor of the contractual deficiencies (e.g. Management, Quality, Safety or Environmental Deficiency Reports, or letters).

https://www.cpars.gov/pdfs/CPARS-Guidance.pdf

8. DOCUMENTING PERFORMANCE

a. The Government shall document positive and/or negative performance. Any report may become a part of the supporting documentation for any contractual action and preparing annual past performance using

CONTRACTOR PERFORMANCE ASSESSMENT REPORT (CPAR).

b. If contractor performance does not meet the Acceptable Quality level, the CO shall inform the contractor. This will normally be in writing unless circumstances necessitate verbal communication. In any case the CO shall document the discussion and place it in the contract file. When the COR and the CO determines formal written communication is required, the COR shall prepare a Contract Report (CR), and present it to CO. The CO will in turn review and will present to the contractor's program manager for corrective action.

The contractor shall acknowledge receipt of the CR in writing. The CR will specify if the contractor is required to prepare a corrective action plan to document how the contractor shall correct the unacceptable performance and avoid a recurrence. The CR will also state how long after receipt the contractor has to present this corrective action plan to the CO. The Government shall review the contractor's corrective action plan to determine acceptability. The CO shall also assure that the contractor receives impartial, fair, and equitable treatment. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance and the acceptability of the Contractor’s corrective action plan.

Any CRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO.

See Sample CR on the following page.

9. COR AND CONTRACTOR ACKNOWLEDGEMENT OF QASP

COR NAME/TITLE DATE

SIGNATURE

CONTRACTOR NAME/TITLE DATE

SIGNATURE

CONTRACT REPORT

1. CONTRACT NUMBER 2. REPORT NUMBER FOR THIS

DISCREPANCY

3. TO: (Contracting Officer) 4. FROM: (Name of COR)

5. DATES

a. CR PREPARED

b. RETURNED BY

CONTRACTOR:

c. ACTION COMPLETE

6. Issue Identified (Describe in detail. Include reference to PWS Directive; attach continuation sheet if necessary.)

7. SIGNATURE OF COR Date:

8. SIGNATURE OF CONTRACTING OFFICER Date:

9a. TO (Contracting Officer) 9a. FROM (Contractor)

10. CONTRACTOR RESPONSE AS TO CAUSE AND ACTIONS TO PREVENT

RECURRENCE. (Cite applicable quality control program procedures or new procedures. Attach continuation sheet(s) if necessary.)

11. SIGNATURE OF CONTRACTOR REPRESENTATIVE Date:

12. GOVERNMENT EVALUATION.

13. GOVERNMENT ACTIONS

14. CLOSE OUT

NAME TITLE SIGNATURE DATE

CONTRACTOR

NOTIFIED

COR

CONTRACTING

OFFICER