Attachment 2 - QASP.pdf

OFFICE OF THE COMPTROLLER OF THE CURRENCY

BEQ QASP

FOR THE EXAMINATION AND SUPERVISORY SURVEY OF

NATIONAL BANKS AND THRIFTS PERFORMANCE WORK

STATEMENT

1 INTRODUCTION

This quality assurance surveillance plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS) entitled Examination and Supervisory Survey of National Banks and Thrifts. This plan sets outlines the parameters and guidelines the Contracting Officer’s Representative (COR) will use in ensuring the contractor achieves the required performance standards or services levels.

2 MISSION

This is a five-year contract (one 12-month base year and four 12-month option years). The contract provides survey support services for a web-based survey sent to the Office of Comptroller of the Currency (OCC) supervised institutions following the issuance of a report of examination for a Federal Deposit Insurance Corporation Insurance Act (FDICIA) certified examination. The contract also requires monthly, semi-annual, and annual reports analyzing survey responses.

3 PURPOSE

The role of the Government in Quality Assurance (QA) is to ensure contract performance standards are achieved. This QASP is a Government-developed document used to determine if the Contractor’s performance meets the performance standards in the contract.

The QASP establishes procedures and measures on how this assessment/inspection process will be conducted, and provides details for continuous oversight process including:

What will be monitored;

How monitoring will take place;

Who will conduct monitoring; and How monitoring efforts and results will be documented.

The Contractor is responsible for implementing performance and delivering contract items that meet contract standards using its own organizational quality plans. This QASP provides the structure for the Government’s surveillance of the Contractor’s performance to assure that it meets task order performance requirements. It is the Government’s responsibility to be objective, fair and consistent in evaluating Contractor performance.

This QASP is not 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 may provide a copy of the QASP to the Contractor to facilitate open communication. In addition, the QASP should recognize that unforeseen or uncontrollable circumstances might occur that are outside the control of the Contractor and how those potential situations will be managed. The goal of this QASP is to ensure early identification and resolution of performance issues to minimize impact on mission performance.

4 AUTHORITY

Authority for issuance of this QASP is provided under Part 46 of the Federal Acquisition Regulation, Quality Assurance and Inspection of Services clauses, which provides for inspection, acceptance, and documentation of the services called for in the contract. This acceptance is to be executed by the contracting officer or designated COR.

5 ROLES AND RESPONSIBILITIES

The following personnel shall oversee and coordinate surveillance activities.

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 contract relationship. The CO shall also ensure that the Contractor receives impartial, fair, and equitable treatment under this contract.

The CO will determine the final assessment of the Contractor’s performance.

Assigned CO: John R. Baumert Organization or Agency: OCC Email: John.Baumert@occ.treas.gov

Contracting Officer’s Representative (COR) - The COR is responsible for providing continuous technical oversight of the Contractor’s performance. The COR uses the QASP to conduct the oversight/surveillance process. The COR shall keep a Quality Assurance file that accurately documents the Contractor’s actual performance. The purpose is to ensure that the Contractor meets the performance standards contained in the contract. The COR is responsible for reporting early identification of performance problems to the CO. The COR is required to provide an annual performance assessment to the CO which will be used in documenting past performance. The QASP is the primary tool for documenting Contractor performance. The COR is not empowered to make any contractual commitments or to authorize any contractual change on the Government’s behalf. Any contractual change is solely the CO's responsibility.

Assigned COR: Idalia Zuniga Organization or Agency: OCC Email: Idalia.Zuniga@occ.treas.gov

Contractor Representatives – The following employees of the Contractor serve as the Contractor’s Program Manager for this contract. (This section will be completed after contract award.)

6 PERFORMANCE REQUIREMENTS AND METHOD OF SURVEILLANCE

Performance measure and objectives in Table 1 define the desired performance outcomes for the requirements they represent. The target metric or performance standards define the level of acceptable service required under the contract to meet the performance objective. The surveillance methods define 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 Contractor will propose a quality assurance effort for tasks and deliverables described in the PWS. The COR will use Table 1 below to measure the performance against the surveillance metrics using the

PWS.

6.1 SURVEILLANCE METRICS

Table 1 details the method of surveillance the COR will use to validate and inspect performance elements. Inspection of each element will be documented in the COR file. The below listed methods of surveillance shall be used in the administration of this QASP.

6.1.1 Inspection

Specific characteristics of every performance unit are examined and tested by the Customer and Government subject matter experts to determine conformance with requirements. This surveillance method is preferred for tasks that occur infrequently, as well as for tasks that cannot be randomly inspected.

6.1.2 Random Inspection

The COR shall conduct random surveillance of tasks and deliverables under the contract to determine whether the Contractor’s performance meets the performance requirement based on randomly selected samples of the task or deliverable. This method is the most appropriate for frequently recurring tasks.

6.1.3 Customer Feedback

Customer1 feedback may be obtained from random customer complaints via phone or in writing. The COR shall maintain a copy of each complaint in a documentation file.

1 Customer is a survey recipient.

TABLE 1: PERFORMANCE REQUIREMENTS SUMMARY

Deliverable/ Specification Item

Performance Measure/ Objective

Target Metric/ Performance Standard

Disincentive (D) Surveillance Methods

Frequency

Communications with bank POCs

Survey link is distributed within expected timeframe (i.e.

14 calendar days after receiving a list of bank POCs from the COR), as noted in Section 2.2 Survey Administration Requirements

Weekly survey reminders (emails one, two, & three) per Section 2.2 Survey Administration Requirements are only sent to bank POCs who have not completed the survey

95 percent of monthly bank POCs receive the survey link and weekly reminders (as applicable) within the timeframe defined in the contract year survey schedule.

If the survey link or reminders are not delivered within the established timeframe, there must be no more than a 48-hour delay.

(D) = 3% deduction of monthly invoice amount (for CLIN X001) for late survey links or reminders not meeting requirements in any given month.

An additional 2% deduction of the monthly invoice amount (for CLIN X001) if the 48 hour window is missed for any bank POCs.

100% inspection of Survey Response File

Random inspection of 10 bank POCs listed in the monthly Survey Response file and customer feedback, if any

Monthly

Survey Response File

File format meets specifications provided by the

OCC

Data is error-free

Correct format and error-free data for 100 percent of monthly data files

(D) = 5% deduction of monthly invoice amount for CLIN X001.

100 percent Inspection

Monthly

Specification Item

Performance Measure/ Objective

Target Metric/ Performance Standard

Disincentive (D) Surveillance Methods

Frequency

Monthly Report Report format meets specifications approved by the

OCC

Information is error-free

Correct format and error-free information for 95 percent of monthly reports

(D) = 5% deduction of invoice amount (for CLIN X002) for incorrect information and report format

100 percent Inspection

Monthly

Semi-Annual Report

Correct grammar with minimal typos

No calculation or data errors

Agreed upon analysis criteria and format

No more than five typos

No calculation or data errors

Agreed upon analysis criteria and format used in 100 percent of the reports

(D) = 10% deduction of invoice amount (for CLIN X003) if more than five typos, for any calculation or data errors, and/or if agreed upon analysis criteria and format are not used

100 percent Inspection

Semi-Annually

Annual Report Correct grammar with minimal typos

No calculation or data errors

Agreed upon analysis criteria and format five typos

No calculation or data errors

Agreed upon analysis criteria and format used in 100 percent of the reports

(D) = 10% deduction of monthly invoice amount (for CLIN X004) if more than five typos, any calculation or data errors, and/or if agreed upon analysis criteria and format are not used

100 percent

Annually

Specification Item

Performance Measure/ Objective

Target Metric/ Performance Standard

Disincentive (D) Surveillance Methods

Frequency

Timeliness of Deliverables

Submitted by deadline established in Table 1 Required Contract Deliverables

11 of 12 (or 92 percent) monthly deliverables submitted timely. Any late monthly deliverable is submitted within two business days.

one business day delay in submission of either one of the semi-annual or annual report

(D) = 10% deduction of invoice amount (for CLIN X001 or X002) for every late monthly deliverable after the first allowed instance. An additional 5% deduction of the invoice amount will be charged if the deliverable is submitted after two business days.

(D) = 5% deduction of invoice amount (for CLIN X003 or X004) for every day past the one business day grace period.

100 percent

Monthly

7 PERFORMANCE REPORTING

7.1 PERFORMANCE ASSESSMENT REPORT

The COR will perform quarterly assessments of Contractor performance and will file an annual assessment via the Contractor Performance Assessment Reporting System (CPARS). The Performance Assessment Report (PAR) provides the Government and the Contractor the ability to track the progress of Contractor performance in a formalized way to assist in the annual assessments submitted via CPARS. The PAR will be used to report all minor discrepancies and will be generated by the COR and provided to the CO to be sent to the Contractor for corrective action. Contractors will be given ten (10) days to correct the items stated in the PARs, unless they have requested an extension and the extension has been granted. If three (3) or more minor discrepancies are found, the COR will combine them and process a Corrective Action Report

(CAR).

Although the COR prepares the PAR quarterly, the Contractor’s performance will be monitored continuously and submitted to the CO via monthly reports. The COR will assist the CO in monitoring contract performance per the COR appointment letter provided to the COR by the CO. The following is the PAR Form that will be used quarterly for evaluation of activities during the period of performance.

PERFORMANCE ASSESSMENT REPORT (PAR)

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

1. CONTRACT/TASK ORDER NUMBER 2. CONTRACTOR 3. TYPE OF SERVICES

4. QUALITY ASSURANCE PERSONNEL (COR) SIGNATURE AND DATE 5. COR PHONE 6. SUSPENSE DATE

I. PERFORMANCE

7. DEFICIENCY (CHECK ALL BOXES THAT APPLY)

NEW

REPEAT

NO DEFICIENCY NOTED

8. SERVICES SUMMARY or PWS PARAGRAPH ITEM REVIEWED

9. BRIEF DESCRIPTION OF DEFICIENCY (IF DEFICIENCY BOX WAS

CHECKED)

10. DETAILED PERFORMANCE ASSESSMENT

II. CONTRACTOR VALIDATION

11. CONTRACTOR REPRESENTATIVE CONCUR 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. CONCUR NON-CONCUR COR SIGNATURE AND DATE

15. COR REMARKS (REQUIRED)

6. CONRACTOR REPRESENTATIVE REMARKS

Quarterly assessments will be utilized to determine the Annual assessment with the following evaluation factors:

a. Schedule and Timeliness of Deliveries – The COR will assess the Contractor’s adherence to the required project schedule by assessing the Contractor’s efforts during the assessment period that contribute to or affect schedule variance. This will take into consideration the significance of scheduled events and assess the effectiveness of corrective actions taken by the Contractor. The Contractor will be rated on the responsiveness to the contract tasks and their timely submissions of required support services and system features, as required by the contract. In addition, the Contractor will be rated on their conduct of scheduled reviews and their timely submission of review materials, per the agreed upon process and associated timelines as required by the contract.

b. Quality of Product or Service (Technical Performance) – The COR will assess the Contractor’s effort to transform operational needs and requirements into an integrated solution. Areas of focus may include the planning and management of program tasks, the quality of support provided throughout all phases of contract execution, and the management of a totally integrated effort of all program management concerns to meet cost, performance, and schedule objectives. The Contractor will be evaluated quarterly with respect to the quality of the required support services and system enhancements using the standards and monitoring methods as outlined in this document. The COR will document and archive the evaluations in the surveillance folder. The Contractor’s contribution in meetings and reviews, quality of technical reports, productivity level, and the overall quality of technical support will be assessed within the evaluations.

Business Relations or Management – The COR will assess the turnaround, completeness, and quality of problem identification, corrective action plans, the cooperativeness of the Contractor, and customer satisfaction. The Contractor’s ability to identify and apply resources required to meet schedule requirements, assign responsibility for tasks/actions required by the PWS, and communicate appropriate information to affected program elements in a timely manner will also be assessed. The COR will assess the Contractor’s program management and identified technical risks and the associated risk mitigation plans to determine if there are any impacts to project objectives. Contractor management should put adequate systems in place to most efficiently perform the contract and protect Government interests. For example, the Contractor should have approved Government property management, quality control, and accounting systems in place.

7.2 CORRECTIVE ACTION REPORT (CAR)

The CAR will be used to report a situation when there are three or more minor discrepancies, or any major discrepancies documented. The CAR will be generated by the COR and forwarded to the CO for action. A copy will be provided to the Contractor representative by the CO.

CARs are required to be corrected within 30 calendar days. Depending on the complexity of the finding, the Contractor may be allowed up to six (6) months to correct a CAR. The COR will request that the Contractor provide the status of CARs monthly. The COR will keep an electronic log of all CARs and will keep a hard copy of CARs in the contract surveillance file.

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 MAJOR 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

ACCEPTED REJECTED

12. CLOSE DATE