ATTACHMENT 11 QASP.pdf

ATTACHMENT 11

US Department of Agriculture (USDA)

Quality Assurance Surveillance Plan

Contents Project Name

Solicitation / Contract Number

Section 1: Introduction

1.1 Purpose

1.2 QASP Relation to the Contract

1.2.1 QASP Revisions

1.2.2 Surveillance of Performance Progression

1.3 QASP Relation to the Quality Control Plan (QCP)

Section 2: Performance Description

2.1 Performance Standards and Acceptable Quality Levels (AQLs)

2.1.1 Allowable Deviation

2.1.2 Substantially Complete

2.2 Non-Performance

2.2.1 Documentation

2.2.2 Remedial Actions

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

3.2.2 Contracting Officer Representative (COR)

3.2.3 Customers

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods

4.2 Analysis and Results

Appendix A: Example Performance Requirement Summaries

Appendix B: Example Discrepancy Report

Appendix G: Example Surveillance Activity Checklist

Project Name The Use of Microsimulation In Supplemental Nutrition Assistance Program (SNAP) Policy Analysis Services

Solicitation / Contract Number Solicitation Number: 123198-25-R-0002

Section 1: Introduction This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS) entitled The Use of Microsimulation In Supplemental Nutrition Assistance Program (SNAP) Policy Analysis. This plan sets forth the procedures and guidelines that the USDA, Food and Nutrition Service, Evidence, Analysis, and Regulatory Affairs Office will use in ensuring the required performance standards or services levels are achieved by the contractor.

1.1 Purpose

The purpose of the QASP is to describe the systematic methods used to measure performance and to identify the reports required and the resources to be employed. The QASP provides a means for evaluating whether the contractor is meeting the performance standards identified in the Performance Work Statement (PWS). This QASP is designed to define roles and responsibilities, identify the performance objectives, define the methodologies used to monitor and evaluate the contractor’s performance, describe quality assurance reporting, and describe the analysis of quality assurance monitoring results.

1.2 QASP Relation to the Contract

1.2.1 QASP Revisions

The Contracting Officer Representative (COR) may make revisions or changes to the QASP procedures and surveillance methods or increase or decrease the degree of surveillance methods at any time during the contract performance period. Changes to the Metric must be incorporated into the PWS, Performance Requirement Summary (PRS) and QASP by a bilateral modification to contract that is issued by the Contracting Officer (CO). A copy of the QASP is provided to the contractor to enable the contractor to enhance its Quality Control (QC) program to perform in accordance with its Quality Control Plan (QCP).

1.2.2 Surveillance of Performance Progression

As the performance period progresses, the levels of surveillance may be altered for service areas where performance is either consistently excellent or unsatisfactory. If consistently good performance, then the amount of surveillance may be reduced. If observations reveal consistent deficiencies, increased surveillance may be implemented.

1.3 QASP Relation to the Quality Control Plan (QCP)

The QCP is a required element of contract, and the Contractor shall adhere to its established quality control processes and procedures in managing and performing work as described in the contract. While the QCP represents the way in which the Contractor will ensure its quality and timeliness of services, as defined in the PWS, the QASP represents the way in which the Government personnel specified in Section 3: Contractor and Government Responsibilities, Paragraph 3.2, Government Responsibilities will evaluate the contractor’s performance. The contractor’s QC program and the residual organization’s QASP should be complementary programs that ensure successful contractor performance.

Section 2: Performance Description Performance of the contractor will be monitored through the surveillance methods described in Section 4: Surveillance Methods to Perform Quality Assurance to assess the Contractor’s performance against PWS requirements.

2.1 Performance Standards and Acceptable Quality Levels (AQLs) For selected activities in the PWS, the PRS provides a performance standard and an AQL. A performance standard is the expected level of contractor performance. An AQL defines the level of performance that is satisfactory. Depending on the service evaluated and the evaluation method selected, performance standards and AQLs may be stated as a number of occurrences or as a percentage. Performance standards and AQLs for random sampling and 100 percent inspection are generally stated as percentages. For periodic inspections, performance standards may be stated as either percentages or as absolute numbers.

The contract requires the Contractor to perform all work as specified. Any inaccuracies or omissions in services or products are referred to as “defects” on the part of the Contractor. The Contractor shall be responsible for all identified defects and may be required to perform the work at no cost to the government. The AQLs take into account that in some instances an allowable level of deficiencies (deviations) is possible while overall performance continues to meet the government’s desired level of service.

2.1.1 Allowable Deviation

The AQLs define the level or number of performance deficiencies the Contractor is permitted to reach under this contract. AQLs take into account the difference between an occasional defect and a gross number of defects. AQLs can be expressed as a percentage of or as an absolute number (e.g., three per month). There may be instances where 100 percent compliance is required, and no deviation is acceptable (e.g., where safety is involved).

2.1.2 Substantially Complete

In some cases, service outputs are evaluated using subjective values (e.g., excellent, satisfactory, unsatisfactory). The criteria for acceptable performance and for defects must be defined for these service outputs. The concept of “substantially complete” should be the basis for inspections based on subjective scales. Work is considered “substantially complete” where there has been no significant departure from the terms of the contract and no omission of essential work. In addition, the Contractor has performed the work required to the best of its ability and the only variance consists of minor omissions or deficiencies.

2.2 Non-Performance

Non-performance occurs when the contractor’s performance does not meet the AQL for a given requirement.

Requirements may contain multiple performance elements, and therefore, deficiencies may occur in one or more aspects of performance (e.g., timeliness, accuracy, completeness, etc.) or subject areas of effort.

When surveillance indicates that the contractor's service output is not in compliance with the contract requirements, the Contracting Officer’s Representative (COR) must determine whether the Contractor or the Government caused the deficiency. If the cause of the defect rests with the Government, corrective action must be taken through Government channels. If the cause of the defect is due to action or inaction by the contractor, the contractor is responsible for correction of the problem at no additional expense to the Government.

2.2.1 Documentation

Documentation of work non-performed or unacceptable work is essential for tracking Contractor performance. The COR will document deficient work by compiling facts describing the inspection methods and results and to substantiate nonconformance with the contract. A sample documentation reporting form is provided in Appendix A, Discrepancy Report. The documentation, with any recommendations, will be forwarded to the CO. In the case of the Contractor, the COR will decide whether to elevate the problem to the CO for corrective action.

2.2.2 Remedial Actions

The Federal Acquisition Regulation allows for penalties in the event that the Contractor fails to perform the required services. Penalties are defined as those actions taken under the direction of the CO against the contractor within the general provisions of the contract for nonconformance to the PWS and PRS.

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

The Contractor is responsible for delivering products or services in accordance with the contract. Implementing its QCP, which describes the Contractor’s methods for ensuring all products and services under the contract meet established performance standards and AQLs. Maintaining, and providing for audit, quality control records and reports and all records associated with the investigation and complaint resolutions. Appointing a single quality control point-of-contact to act as a central recipient of communication from the COR or CO.

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

The CO is responsible for administering and monitoring contract compliance, contract administration, and cost control and for resolving any differences between the observations documented by COR and the contractor’s performance. The CO may delegate various day-to-day contract administration duties to an Administering ACO (ACO) and/or the COR for performance management and administrative actions such as invoice approval and issuance of Contract Discrepancy Reports may be, and normally are, delegated by the CO to the COR. The CO shall approve any revisions to the QASP processes or standards.

3.2.2 Contracting Officer Representative (COR)

The COR, is designated in writing, by the CO. The COR will ensure that the QA function is properly executed, plays a key role in contract administration and performs the contract surveillance and monitoring. Some key contract administration duties include, but are not limited to, performs surveillance as required by this QASP; make recommendations to the CO for issuance of Contract Discrepancy Reports or letters of commendation and acceptance or rejection of completed work and for administrative actions based on unsatisfactory or non-performed work, and revisions or changes to the QASP;

and assists the CO in identifying necessary contract modifications and preparing reports of Contractor performance and cost.

The COR may use the form(s) included in the Appendices to perform the inspection or other forms as approved by the CO. The Contractor overall guidance is also provided by FAR clause of the contract.

3.2.3 Customers

Customers or organizations/offices that the Contractor provided support may be requested to assist the COR in conducting QA to provide information relating to the Contractor’s performance through Customer Feedback.

Information gained from the Customer Feedback may be used in conjunction with other methods of observation to rate the performance of the Contractor.

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods

The surveillance methods used in the QA process are the Government’s tools to monitor the Contractor’s products and services. The best means of determining whether the Contractor has met all contract requirements is to inspect the Contractor’s service products and analyze the results. Further, documented inspection results are an effective tool in contract administration that can confirm the successful achievement of all performance requirements or highlight areas where defects exist, and improvements are necessary.

4.1.1 100 Percent Inspection The Government will inspect 100 percent of deliverables described in the PWS and specified in the approved schedule of deliverables.

4.1.1.1 Performance Standards and AQLs

PERFORMANCE

MEASURE

PERFORMANCE STANDARD Acceptable Quality Level (AQL)

Quality of Products or

Services

Complete per approved study plan 95 percent

Accurate per approved study plan 99 percent

Revised drafts reflect FNS’s feedback on prior drafts

99 percent

Based on state-of-the-art research methods according to peer review

95 percent

Well-written with proper grammar 99 percent

Schedule On time 99 percent

Business Relations Professional and respectful of all parties 99 percent

Management of Key

Personnel

• Personnel have appropriate expertise for the work involved

• Personnel with appropriate expertise attend scheduled meetings

• Personnel are available for ad-hoc meetings as necessary for contractual concerns

95 percent

4.1.1.2 Evaluation Procedures

Observed defects for a service monitored by 100 percent inspection is compared to the performance standard and AQL.

4.2 Analysis and Results

When the inspections and validations have been completed, the COR will perform an analysis of the Contractor’s performance. The purpose of the analysis is to ensure Government is receiving high-quality products and services from the Contractor. The COR will review the results, rate the Contractor’s compliance with the performance standards and AQLs, and characterize the Contractor’s overall performance. Analysis of all types of contract monitoring will result in one of the following outcomes:

4.2.1 Outstanding Performance

Outstanding performance is the result of the Contractor substantially exceeding the performance standards with significant achievements and no significant deficiencies. The Government may reduce its level of surveillance when the COR determines that the Contractor provides sustained performance that significantly exceeds the requirements with no significant deficiencies.

4.2.2 Very Good Performance

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 was effective.

4.2.3 Satisfactory Performance

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

4.2.4 Marginal Performance

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.

4.2.5 Unsatisfactory Performance

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 contains a serious problem(s) for which the contractor’s corrective actions appear or were ineffective.

Appendix A: Example Performance Requirement Summaries

PERFORMANCE REQUIREMENTS SUMMARY

Performance Measure

Performance Standard

Performance Deliverable Monitored

Surveillan ce Methodol ogy

Surveillance Frequency

Monitoring Performed

Quality of Products or Services

• Complete per approved study plan

• Accurate per approved study plan

• Revised drafts reflect FNS’s feedback on prior drafts

• Based on state-of-the-art research methods according to peer review

• Well-written with proper grammar

All deliverables as described in the PWS and specified in the approved Schedule of Deliverables

100% inspection

Per contract’s approved schedule of deliverables

Acceptance or rejection of each deliverable is noted via a government transmittal sheet attached to the deliverable

Schedule On time All deliverables as described in the PWS and specified in the approved Schedule of Deliverables schedule of deliverables

Contractor Performance and Rating System (CPARS)

Cost Control According to the FFP listed in the approved budget per task in the schedule of deliverables

All deliverables as described in the PWS and specified in the approved Schedule of Deliverables schedule of deliverables and each deliverable’s accompanying invoice

Contractor Performance and Rating System (CPARS)

Business Relations

Professional and respectful of all parties

Regular and ad-hoc meetings between contractor and Government; the details of which is reflected in the monthly progress report

Semiannua l performan ce evaluation

Semiannual Contractor Performance and Rating System (CPARS)

Management of Key Personnel

• Appropriate expertise for the work involved

• Attends scheduled meetings

• Available for ad-hoc meetings as necessary for contractual concerns

• Time is scheduled per the staff loading chart in the contractor’s proposal

Regular and ad-hoc meetings between contractor and Government; the details of which is reflected in the monthly progress report

Semiannua l performan ce evaluation

Semiannual Contractor Performance and Rating System (CPARS)

Appendix B: Example Discrepancy Report

DISCREPANCY REPORT 1. DISCREPENCY REPORT NO.

2. TO: (Contractor / Project Manager Name) 3. FROM: (Name of COR)

CONTRACT NUMBER: D ATE:

PREPARED ORAL NOTIFICATION RETURNED BY CONTRACTOR ACTION COMPLETE

4. DISCREPENCY OR PROBLEM (Describe in Detail. Include PWS references. Attach Continuation Sheet if Necessary)

5. SIGNATURE OF COR

6. TO: (Name of COR) 7. FROM: (Contractor / Project Manager)

8. CONTRACTOR RESPONSE AS TO CAUSE, EFFECT, CORRECTIVE ACTION AND ACTIONS TO PREVENT RECURRENCE (Attach Continuation Sheet if necessary. Cite applicable Contractor QC program procedures or new QC procedures)

9. SIGNATURE OF CONTRACTOR REPRESENTIVE 10. DATE

11. GOVERNMENT EVALUATION (Acceptance, partial acceptance, or rejection. Attach Coordination Sheet if necessary)

12. GOVERNMENT ACTIONS (Cure notice, show cause, other)

CLOSE OUT

KTR NOTIFIED

NAME AND TITLE SIGNATURE DATE

COR

Appendix C: Example Surveillance Activity Checklist

Requirement

Performance Standard

Method of Measurement

Metrics

Method of Surveillance

Date Accomplished

Compliance (Exceed, Met, Partial Met)