Attachment 2 QASP.doc

Attachment 2 Quality Assurance Surveillance Plan Solicitation No.: 86615624R00007

HECM Loan Comparison and Underwriting Tool

Quality Assurance Surveillance Plan (QASP)

HECM Loan Comparison and Underwriting Tool (HLCUT)

06/20/2024 Version 1.1 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) HECM Loan Comparison and Underwriting Tool (HLCUT)

1 Vision

For The Office of Housing Counseling to have a well-maintained, regularly updated, and secure Home Equity Conversion Mortgage (HECM) Loan Comparison and Underwriting Tool (HLCUT) that is 508 compliant. It should provide quality loan product calculations including cost of origination, servicing, mortgage insurance premium, amortization schedules, total annual loan cost, and track required questions used in the HECM loan counseling session. The HLCUT would also include a component for financial assessments and should link to other HECM counselor HUD designated required online tools. The HLCUT shall be available in both English and Spanish.

1 Introduction

This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the Performance Work Statement (PWS) entitled Home Equity Conversion Mortgage (HECM) Loan Comparison and Underwriting Tool (HLCUT). This plan sets forth the procedures and guidelines The Office of Housing Counseling 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 Housing Counseling 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 a 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

The following personnel shall oversee and coordinate surveillance activities.

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 method of surveillance is Periodic Inspection - The COR typically performs the periodic inspection monthly.

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.

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 COR will prepare a written report 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

Deliverables:

A001 Draft Project Management Plan A002 Final Project Management Plan

a) Deliver a draft Project Management Plan within 10 business days after contract award, addressing all items outlined in this task.

AQL: Five business day deviation from standard.

b) Deliver the Final PMP to the to the COR within 5 business days after COR request for corrections or approval of the Draft PMP.

AQL: Five business day deviation from standard

What: Deliverables

How: Review the Deliverable

Frequency: After receipt

Who: The COR

Standard(s): Inspection applies to all standards.

5.2 HECM Loan Comparison and Underwriting Tool (HLCUT)

Deliverables:

A003 HLCUT

a) The HLCUT is implemented with full function and available to HECM housing counselors within 60 calendar days of award.

AQL: Zero deviation.

b) HECM counselors' access is added or removed as required within 5 business days of contractor’s notice.

AQL: Two business days deviation from standard.

c) Translation is 95% accurate as determined by HUD.

AQL: Zero deviation.

What: Deliverable

How: Review the Deliverable

Frequency: After receipt

Who: The COR

Incentive: HUD will apply a 1% reduction from the associated monthly contract LIN price for each day performance falls below the standard even if it meets or exceeds the Acceptable Quality Level (AQL).

Standard(s): This inspection applies to Standard a)

What: Deliverable

How: Review the Deliverable

Frequency: After receipt

Who: The COR

Incentive: HUD will apply a 0.5% reduction from the associated monthly contract LIN price for each day performance falls below the standard even if it meets or exceeds the Acceptable Quality Level (AQL).

Standard(s): This inspection applies to Standard b) and c).

5.3 HLCUT Support, Updates, and Reporting

5.3.1 HLCUT Support

Deliverables:

A004 HLCUT Online Training

a) On-demand technical assistance (phone or chat support) provided for the HLCUT users as described in this task.

AQL: Zero Deviation

b) At implementation of the tool, the Contractor provides online initial training, videos, handouts, or other materials describing the use of the HLCUT for counseling agencies, their HECM counselors, and HUD OHC staff in accordance with the timeframes provided and approved in the Project Management Plan.

AQL: Zero Deviation What: Deliverable

How: Review the Deliverable

Frequency: After receipt

Who: The COR

Incentive: HUD will apply a 0.5% reduction from the associated monthly contract LIN price for each day performance falls below the standard even if it meets or exceeds the Acceptable Quality Level (AQL).

5.3.2 HLCUT Updates

Deliverables:

A005 Update Plan A006 HLCUT Update

a) Updates are applied as outlined within this task.

AQL: Zero Deviation

b) No update removes access to the tool during normal business hours as outlined in this task.

AQL: Zero Deviation

What: Deliverable

How: Review the Deliverable

Frequency: After receipt

Who: The COR

Incentive: HUD will apply a 0.5% reduction from the associated monthly contract LIN price for each day performance falls below the standard even if it meets or exceeds the Acceptable Quality Level (AQL).

5.3.3 Reporting

Deliverables:

A007 HLCUT Monthly Report A008 Meeting Minutes

a) Reports conform to the minimum standards outlined in this task and contain all sections as described.

AQL: Zero Deviation

b) Reports are delivered by the 5th day of the month following the reported month.

AQL: Two business days deviation from standard.

c) Minutes of monthly meetings delivered by the 5th business day following the meeting.

AQL: Two business days deviation from standard.

What: Deliverable

How: Review the Deliverable

Frequency: After receipt

Who: The COR

Incentive: HUD will apply a 0.5% reduction from the associated monthly contract LIN price for each day performance falls below the standard even if it meets or exceeds the Acceptable Quality Level (AQL).

5.4 Transition Services

Deliverables:

A009 Transition Out Plan

a) The Contractor performs all duties noted in the PWS to the outlined standards at the completion of the Transition-In Services with no interruption of service.

AQL: Zero Deviation

b) The incumbent Contractor provides support to the incoming new contractor as described in this section during the entire Transition-Out period.

AQL: Zero Deviation

c) Standard: The Contractor provides the Transition Out Plan within 20 business days after the start of the fourth option period of the contract.

AQL: Five business day deviation from standard.

What: Deliverable

How: Review the Deliverable

Frequency: After receipt

Who: The COR

Incentive: HUD will apply a 1% reduction from the associated monthly contract LIN price for each day performance falls below the standard even if it meets or exceeds the Acceptable Quality Level (AQL).

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