Attachment 2 - Quality Assurance Surveillance Plan (QASP).pdf

Quality Assurance Surveillance Plan

(QASP)

Office of the Administrative Assistant (OAA) to the Secretary of the Army, Equal

Employment Opportunity (EEO) Equal Employment Opportunity (EEO)

On-Call Sign Language Interpreting (SLI) Services

January 28, 2025

Table of Contents

1. Introduction

2. Purpose

3. Performance Management Strategy

4. Roles and Responsibilities

5. Contracting Officer

6. Identification of Services to Be Performed

7. Methodologies to Monitor Performance

8. Quality Assurance Reporting

9. Analysis of Quality Assurance Monitoring Results

10. Failure to Perform

11. Attachments

Attachment 1 - Performance Requirements Summary

Attachment 2 - Contractor Discrepancy Report

Attachment 3 - Contractor Complaint Form

Attachment 4 - COR Monthly Report

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

Equal Employment Opportunity (EEO)

Sign Language Interpreting (SLI) Services

1.0 INTRODUCTION

This Quality Assurance Surveillance Plans (QASP) is pursuant to requirements listed in the performance-based Performance Work Statement (PWS) entitled On- Call Sign Language Interpreting (SLI) Services. This performance-based plan sets forth the procedures and guidelines the Office of the Administrative Assistant to the Secretary of the Army (OAA) will use in evaluating the technical performance of the contractor.

1.1 PURPOSE

This Quality Assurance Surveillance Plan (QASP) written for Sign Language Interpreting service provided to the Equal Employment Opportunity (EEO) is to ensure service meets the contract requirements. The surveillance plan is based on the contract's Performance Work Statement (PWS) and the submitted Quality Control Plan (QCP) which form the basis for the performance objectives selected to surveil in the Performance Requirements (PRS). The contract requirements ensure that the Equal Employment Opportunity (EEO) is compliant with Section 501, 504 and 508 of the Rehabilitation Act of 1973 as amended and Army Regulation 690-12.

1.1.1 The role of the Government in quality assurance (QA) is to ensure contract standards are achieved. The purpose of the QASP is to identify the methods and procedures the Government will use to evaluate contractor actions while performing the requirements in the PWS. It is designed to provide an effective surveillance method by monitoring contractor performance for each listed performance objective in the Attachment 1 Performance Requirements Summary (PRS).

1.1.2 The QASP provides a systematic method to evaluate the services the contractor is required to perform as specified in the PWS and the Contract.

1.1.3 The QASP has been developed by the requiring activity. It is designed to provide direction to personnel performing contract surveillance activities. Personnel surveying the contract terms and conditions and PWS requirements will periodically review the QASP throughout the life of the contract.

1.1.4 The 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 PERFORMANCE MANAGEMENT STRATEGY

1.2.1 The contractor's Quality Control Plan (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 their performance to the designated Government representative.

1.2.2 The Contracting Officer Representative (COR) will monitor performance and review performance reports furnished by the contractor to determine how the contractor is performing against communicated performance objectives. The Government will make decisions based on performance measurement metric data and notify the contractor of those decisions. The contractor will be responsible for making required changes in processes and practices to ensure performance is managed effectively.

2.0 ROLES AND RESPONSIBILITIES

2.1. Contracting Officer Representative. The COR is responsible for quality assurance guidance and to ensure that contract quality requirements, provisions, standards, and thresholds are defined, practical, enforceable, necessary, and verifiable.

2.1.1. The COR evaluates and documents contractor performance in accordance with the QASP and PWS.

2.1.2. The COR shall notify the Contracting Officer (KO) of any significant performance deficiencies using a Contractor Discrepancy Report (CDR) (Attachment 2) with supporting documentation.

2.1.3. The COR will upload copies of ALL surveillance documentation to the Procurement Integrated Enterprise Environment (PIEE) Joint Appointment Module/Surveillance and Performance Monitoring (JAM/SPM) modules, unless otherwise directed by the KO.

2.1.4. The COR will submit a monthly report to the KO concerning performance of services rendered under this contract.

2.1.5. The COR recommends improvements to the QASP and PWS throughout the life of the contract.

2.2. Contracting Officer. The KO is responsible for safeguarding the interests of the United States Government in contractual relationships. Only the KO is authorized to bind the Government and then, only to the extent of the authority delegated to them through the issuance of a warrant.

2.2.1. The KO delegates authority for inspection and/or acceptance in accordance with the terms of the contract.

2.2.2. The KO informs the contractor of the names, duties, and limitations of authority for all quality assurance personnel assigned to the contract.

3.0 IDENTIFICATION OF SERVICES TO BE PERFORMED

The contractor shall provide services in accordance with the PWS. The performance standards are established in the paragraph of the PWS that covers the specific category of work. The acceptable level of performance is set in the acceptable quality level related to that paragraph as found in the PRS.

4.0 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 In an effort to minimize the contract administration burden, simplified methods of surveillance techniques shall be used by the Government to evaluate contractor performance. The primary methods of surveillance are random checks, observations, inspections, complaints and review of those records and files that are required to be maintained and delivered under this PWS.

4.2 The contractor is expected to establish and maintain professional communication between its employees and customers. The primary objective of professional communication between employees and customers 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 addressing customer complaints and investigating the issues and/or problems.

NOTE: The customer always has the option to communicate complaints to the COR as opposed to the contractor. The COR will accept the customer complaints and will investigate using the Contractor Complaint Form (Attachment 3).

4.3 The acceptable quality levels (AQL) located in the PRS (Attachment 1) for contractor performance are structured to allow the contractor to manage how the work is performed while providing negative incentives for performance shortfalls.

For certain critical activities such as those involving facility environment, security, chemical biological, radiological, and toxin activities, and accident control, the desired performance level is established at one hundred percent (100%). Other levels of performance are keyed to the relative importance of the task to the overall mission performance at the Program Office.

5.0 QUALITY ASSURANCE REPORTING

5.1 The performance management feedback loop begins with the communication of expected outcomes. Performance standards are expressed in the PWS and measured by the required performance metrics in PRS (Attachment 1).

5.2 The Government's QA monitoring, accomplished by the COR, will be reported using the COR Monthly Report (Attachment 4). This form, when completed, will document the COR's understanding of the contractor's performance under the contract to ensure that the PWS requirements are being met.

5.2.1 The COR will complete this form in the PIEE JAM/SPM and retain a copy of the report in their COR file.

6.0 ANALYSIS OF QUALITY ASSURANCE MONITORING RESULTS

6.1 The Government shall use the observation methods cited to determine whether the AQLs have been met. The Government will evaluate the results that then will be translated into the specific Incentives/Reductions of the PRS (Attachment 1). The monthly evaluation results may cause adjustments to the contractor's monthly payments, should performance not meet the AQL's.

6.2 At the end of each month, the COR will prepare a written report for the KO summarizing the overall results of the quality assurance monitoring of the contractor's performance. This written report that consists of the Contractor's submitted monthly report and the completed COR Monthly Report (Attachment 4) which will become part of the contract QA documentation.

6.3 The KO may require the contractor's Program Manager, or a designated alternate, to meet with the KO, COR, and other Government personnel as deemed necessary to discuss performance evaluation. The KO will define a frequency of in- depth reviews with the contractor, however if the need arises, the contractor will meet with the KO as often as required or per the contractor's request. The agenda of the reviews may discuss:

• Monthly performance measured by the metrics and trends

• Issues and concerns of both parties

• Projected outlook for upcoming months and progress against expected trends

• Recommendations made by the Quality Assurance Specialist (QAS) based on contractor information

• Issues arising from independent reviews and inspections

6.4 In addition to QA monitoring, the COR will use the information contained in the contractor's monthly report to assess the contractor's level of performance for each objective measured in the QASP (detailed in Attachment 1). The KO/COR must coordinate and communicate with the contractor to resolve issues and concerns of marginal or unacceptable performance. The contractor will discuss with the KO/COR satisfaction ratings receiving as a "less than acceptable" rating.

For such cases, the contractor should highlight its perspective on factors driving customer satisfaction and present plans to adjust service levels accordingly to bring the satisfaction rating up to an acceptable level.

6.5 The KO/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 convenience of the

KO.

7.0 FAILURE TO PERFORM

7.1 The contractor may receive deductions or even termination based on failure to perform. The following criteria apply for determining appropriate action:

• Notifications. Consistent with FAR Part 49, the KO shall notify the service provider of failure to meet standards through QA monitoring forms, cure notices, or show cause notices (see Attachment 2, Contract Deficiency Report) and shall inform the service provider manager or designated alternate of such notices.

• Deductions. The Government has the right to deduct a specified dollar for failure to meet performance standards. The amount is identified in the Performance Requirements Incentives/Reductions.

• Termination. If the KO determines that the contractor has failed to perform to the extent that a termination for default is justified, the KO shall issue a notice of termination, consistent with FAR Part 49.

7.2 Unacceptable Performance. If the number of complaints/defects exceeds the performance threshold for any objective, the COR will determine the possible cause of this unacceptable performance. Government-caused complaints/defects will not be counted against the contractor. The same applies to any other requirement of the contract when Government-caused complaints/defects are the cause of unacceptable contractor performance. If the contractor's performance is judged unacceptable for any requirement by the COR, the COR will inform the KO for resolution. Significant performance deficiencies must be submitted to the KO using a CDR and include supporting documentation.

ATTACHMENT 1: PERFORMANCE REQUIREMENTS SUMMARY

Overview. This PRS identifies the services required by the PWS over which the Government will exercise surveillance.

Performance Evaluation. Performance of a service will be evaluated to determine whether or not it meets the performance threshold. The contractor shall provide the Government a written response as to why the performance threshold was not met, how performance will be returned to acceptable levels, and how recurrence of the cause will be prevented in the future. When documentation does not meet performance thresholds, revising and resubmitting the documentation at no cost to the Government is the preferred method for correcting unacceptable performance.

Performance Objectives, Indicators, Thresholds, and Surveillance Methods.

The services required by the contractor are summarized into performance objectives and indicators, along with the minimum standards that relate directly to mission essential items. The performance threshold briefly describes the minimum acceptable levels of service required for each requirement. These thresholds are critical to mission success

Note: Meeting or exceeding the expected standards or performance may result in an above average rating in the Contractor's past performance evaluation at the end of the contract performance period. Negative performance will be reflected on the Contractor's past performance evaluation.

PERFORMANCE REQUIREMENTS SUMMARY (PRS)

This Performance Requirements Summary includes performance standards. The Government will use these standards to determine contractor performance and shall compare contractor performance to the Acceptable Quality Level (AQL).

Performance

Objective Standard

Performance

Threshold

Method of

Surveillance

Remedy

PRS #1

Language Use:

Match the language needs of the employees.

PWS Paragraph 5.1.1

Provide interpreting services in compliance with Federal law, Army Regulation and Registry of Interpreters for the Deaf Code of Professional Conduct

Service will be performed at or above certification level: no more than 2 complaints per 25 hours of service or 2 complaints against the same contract interpreter

Periodic

Customer Complaints

Replacement of interpreter and/or fine equal to period of non-performance

PRS#2

Interpretation:

Provide an equivalent interpretation of information.

PWS Paragraph 5.1.2

The interpreter shall interpret the message accurately and within the spirit of the conversation

Service will be performed at or above certification level: no more than 2 complaints per 25 hours of service or 2 complaints against the same contract interpreter

Periodic

Customer Complaints

Replacement of interpreter and /or fine equal to period of non-performance

PRS #3

Timeliness:

Services will be provided on time as per arranged schedule and

IAW PWS

Provide interpreting services in compliance with Federal law, Army Regulation and Registry of Interpreters for the Deaf Code of Professional Conduct

100% on time all the time

Periodic

Customer Complaints

Contractor will not be paid for unrendered services

5.1.4

PRS #4 Notice of Interpreter's Name: Provide interpreter’s name in accordance with

PWS

Provide interpreting services in compliance with Federal law, Army Regulation and Registry of Interpreters for the Deaf Code of Professional Conduct

100% 100% of the time Fine equal to hourly rate stated in contract for the period of non-performance

5.1.3.2

NOTE: CORs should upload Surveillance Checklists/Results in COR SPM Record!

Surveillance Checklists shall be created and submitted in the COR’s contract record in the SPM module of PIEE using the Surveillance Schedule table in the QASP or the Surveillance Checklist SmartForm, along with the COR’s Monthly Status Reports, or, if applicable, by addressing all items in the Surveillance Schedule within the COR’s Monthly Status Report submission.

The evaluation ratings are as follows:

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

Very Good: Performance meets contractual requirements and exceeds some to the Government's benefit. The contractual performance of the task and sub-task being assessed was accomplished with some min or problems for which corrective actions taken by the contractor were effective.

Satisfactory: Performance meets contractual requirements. The contractual performance of the task and sub-task contain some minor problems for which corrective actions taken by the contractor appear or were satisfactory.

Marginal: Performance does not meet some contractual requirements. The contractual performance of the task and sub-task 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.

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

ATTACHMENT 2: CONTRACT DISCREPANCY REPORT (CDR)

CONTRACT DISCREPANCY REPORT

1. Contract Number 2. Report Number For This Discrepancy

3. TO (Contractor and Manager's Name) FROM (Name of QAE)

5. Dates (YYYYMMDD)

a. Prepared b. Returned to Contractor c. Action Complete

6. DISCREPANCY OR PROBLEM (Describe in Detail, include reference to PWS Directive; Attach continuation sheet(s) if necessary

7. SIGNATURE OF CONTRACTING OFFICER

Ba To (Contracting Officer) b. From (Contractor)

9. CONTRACTOR RESPONSE AS TO CAUSE, CORRECTIVE ACTION AND ACTIONS TO PREVENT RECURRENCE (Cite applicable Q.C. program procedures or new Q.C. procedures. Attach continuation sheet.

10. Signature of Contractor Representative Date (YYYYMMDD)

11. Government Evaluation (Acceptance, partial acceptance, reflection. Attach continuation sheet(s) if necessary

12. Government Action (Reduce payment, cure notice, show cause, other)

13 CLOSEOUT

NAME

(1)

TITLE

(2)

SIGNATURE

(3)

DATE (YYYYMMDD)

a. Contractor Notified

b. COR

c. AKO

ATTACHMENT 3: CONTRACTOR COMPLAINT FORM

Date:

Contract Number:

Contractor's Program Manager's Name:

Phone Number:

Name of Contractor Company:

Company POC & Phone Number:

Name of individual filing the complaint:

Names of Individuals Involved in the complaint:

Task Order Number:

Names of individuals that have been notified of complaint (COR, PM, Company, etc): Date the incident occurred:

Describe the incident:

Government Response:

COR Signature Contractor's Signature:

Attach continuation sheet(s) if necessary

ATTACHMENT 4 :

COR Name:

Contract Number:

Task Order:

Contract Period of Performance

COR MONTHLY REPORT

REPORT FOR MONTH ENDING

From: To:

SURVEILLANCE METHOD

100% Inspection

Random Onsite Inspection

Scheduled Periodic Inspection

Contractor Submitted Report

CONTRACTOR'S QUALITY OF WORK

Exceptional

Very Good

Satisfactory

Marginal

Unsatisfactory

Has the Contractor conducted duties in a timely manner? Yes No

Were all the items in the QASP inspected? Yes No

Is the job progressing on schedule? Yes No

Are there any significant issues to report? Yes No

Are there any discrepancies to report? Yes No

Are there any issues for the PCO/KO to be aware of? Yes No

Has the contractor met all contract requirements? Yes No

I certify that this report is in accordance with the Inspection of Services-Fixed- Price Clause at FAR 52.246-4, the Contract Terms and Conditions-Commercial Products and Commercial Services-Inspection/ Acceptance Clause at FAR 52.212- 4(a), the monthly surveillance schedule, and the QASP. I hereby certify that services have been received and accepted.

COR Signature: