Attachment_3_-_QASP.pdf

CABRILLO NATIONAL MONUMENT

CUSTODIAL SERVICES CONTRACT

Quality Assurance Surveillance Plan

Dec 2022

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1.0 INTRODUCTION

2.0 GENERAL

2.01 METHODOLOGY

2.02 SERVICE PROVIDER RESPONSIBILITY

2.03 GOVERNMENT RESPONSIBILITY

2.04 SERVICE PROVIDER NON-CONFORMANCE

2.05 CONTRACT PERFORMANCE REQUIREMENT

2.06 GOVERNMENT REMEDIES

3.0 QUALITY ASSURANCE REQUIREMENTS

4.0 QUALITY ASSURANCE METHODS

4.01 REQUIRED PERIODIC REPORTS

4.02 COMBINING METHODS

4.03 PERFORMANCE REQUIREMENTS SUMMARY

5.0 QUALITY ASSURANCE SURVEILLANCE SCHEDULE

5.01 QUALITY ASSURANCE EVALUATOR SCHEDULE

5.02 ACTUAL SURVEILLANCE

5.03 SURVEILLANCE DOCUMENTATION

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The Quality Assurance Surveillance Plan (QASP) is designed to assist the Government in monitoring the quality and quantity of services that may be provided by a government or a contractor organization. The plan must comply with the requirements of the contract.

The QASP consists of four sections:

Section 2.0, General, contains an overview of the quality assurance (QA) methodology, an outline of contractor and government responsibilities, a definition of non-conformance with quality requirements, and a discussion of remedies available to the Government.

Section 3.0, Quality Assurance Requirements, contains an overview and general description of the elements relating to the quantity and quality of the services required by the contractor. This section references contractual functional and performance requirements.

Section 4.0, Quality Assurance Methods, describes planned methods for monitoring compliance with the performance requirements. The Contracting Officer (CO) will use information from this section to decide on the level of quality assurance resources which can be supported.

Section 5.0, Quality Assurance Surveillance Schedule, provides a method for scheduling, conducting, and documenting quality assurance activities.

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This QA has been developed to provide the governmental Quality Assurance Evaluators (QAEs) and Contracting Officer Representatives (CORs) an effective and systematic method for surveying selected functions described in the contract. The QASP is also intended to help the QAEs understand the significance of each requirement and its associated assurance procedure.

2.01 METHODOLOGY

This QASP provides a systematic method to evaluate the contractor's delivery of required services. The contractor's performance is evaluated on a variety of factors, including quality, quantity, timeliness, etc. This document identifies the various surveillance methods that, when properly utilized, assure the Government of satisfactory contractor performance. The QASP is not designed to provide the details of how the contractor accomplishes its work.

2.02 SERVICE PROVIDER RESPONSIBILITY

This QASP is based on the premise that the contractor, not the Government, is responsible for employing management and quality control activities to ensure the contractor meets the terms of the contract. The performance requirements and measures outlined in the contract reflect the fact that contractor’s performance will not be perfect and that unforeseen and uncontrollable problems do occur. Good management and the use of an adequate quality control plan (QCP), however, will allow the contractor to operate successfully within specified performance requirements.

2.03 GOVERNMENT RESPONSIBILITY

The Government's intention is to minimize the level of the Government’s involvement and give the contractor the responsibility to perform to, or exceed, contract standards. If the contractor’s performance is not satisfactory, and it appears that the contractor's quality control (QC) process has not produced the desired result, the QAE(s) has the option to increase the frequency of quality assurance surveillance to protect the Government's rights.

The contractor is the owner of the QC process and will institute procedures that, if followed, will produce the desired outcomes. The contractor is responsible for developing, implementing, and modifying this quality control process. The QAEs will vary the level of surveillance depending on the contractor's conformance to quality levels. The QAEs will use statistically valid samples to ensure that the contractor’s process is accomplishing the desired performance standards of the contract.

QAE(s) may base the level of contractor quality on the Standards Rating table:

Table 1: Standards Rating Table

Quality Level Explanation

Substantially Above Standards

Contractor exceeds most standards in performing required tasks and work is highly professional. Contractor solves problems with very little, if any, government involvement. Contractor is proactive and takes an aggressive approach in identifying problems and their resolution.

Above Standards Contractor exceeds some standards in performing required tasks. Contractor resolves problems with only minimal government supervision and assistance. Contractor does not wait to be told about problems before resolving.

Meets Standards Contractor meets standards in performing required tasks. Contractor is able to solve basic problems. Contractor only seeks government assistance on complex unusual problems. Contractor shows initiative in problem resolution.

Below Standards Contractor does not meet requirements. Contractor is unable to solve problems and seeks government assistance for problem resolution.

2.04 SERVICE PROVIDER NON-CONFORMANCE

Any contractor’s non-conformance, in whole or in part, with contract requirements is a “defect.”

The terms “defective” and “discrepancy” are used in reference to a service output that does not meet the output’s associated standard as defined in the contract. If any government action or lack of action causes unacceptable performance which results in a defect, then these defects shall not be counted against the contractor. All costs associated with rework due to contractor defects are the responsibility of the contractor.

2.05 CONTRACT PERFORMANCE REQUIREMENT

When the contractor’s performance does not meet the minimum satisfactory rating, the COR will initiate a contract performance report. If the contractor receives a contract performance report, the contractor shall explain in writing within 14 calendar days why performance was unsatisfactory, how performance will be returned to acceptable levels, and how recurrence of the unsatisfactory performance will be prevented in the future.

If the contractor’s performance does not meet the minimum satisfactory rating within 30 days of issuance of the contract performance report or the performance falls below the minimum satisfactory rating twice within any six month period, the COR will initiate a repeat contract performance report. Just as for the contract performance report, the contractor shall explain in writing within 14 calendar days why performance was unsatisfactory, how performance will be returned to acceptable levels, and how recurrence of the unsatisfactory performance will be prevented in the future.

In addition to any other authority or recourse the CO may have, the CO may take any of the following actions if a contract performance report or a repeat contract performance report is sent to the contractor:

Require the contractor to present a response in person Require additional information or certification before fees are paid Unilaterally modify the Performance Requirement Summary (PRS) or Statement of Work

(SOW)

Perform the work through other means and deduct the cost from the contractor’s invoice Increase compliance inspection to be paid for by the contractor

2.06 GOVERNMENT REMEDIES

The contractor's failure to meet performance measures or failure to comply with regulations may result in other contract remedies. Contract remedies may include suspension or termination for cause, reduced payment, or a decision not to exercise contract options. The CO will determine the appropriate remedy for non-compliance based on his/her judgment and the severity of non-compliance. Contractor negligence will almost certainly result in contract default.

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The contract specifies specific performance requirements that the contractor must meet. The QAE is responsible for knowing and understanding all of these requirements. Although all of the requirements in the contract are important, not all of them are equally critical to assuring the adequacy of the overall performance of the operation. These requirements are grouped below according to the PRS provided in Section 4.03 Performance Requirements Summary.

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This section provides an overview of the methods used to monitor the critical requirements.

Included in this discussion are the risks and benefits of each method and their appropriate usage.

This section also includes the Performance Requirements Summary (PRS), outlined below in paragraph 4.03. This table details where specific performance requirements are referenced in the contract, and defines performance measures, QA procedures, and the minimum satisfactory rating to be achieved by the contractor. The PRS will assist the QAE in ensuring that the appropriate performance standards are being measured and will provide standards against which the contractor will monitor its own performance.

4.01 REQUIRED PERIODIC REPORTS

The contractor shall submit regular, standardized periodic reports to the QAE(s) on the specific performance matters proposed in the QCP and referenced in the PRS. These reports are generally directed at overall program performance and not at the specifics of the PRS. These reports are an important first step in QA and must be received in a timely manner and then monitored closely.

Reviewing these reports will be the first means of monitoring the contractor's adherence to the contract and of measuring its performance against the PRS. The QAE(s) should review these reports when they are submitted and, as appropriate, request supporting or clarifying information. Required periodic reports will also be used to identify performance requirements that may need heightened scrutiny. If additional surveillance is needed, other monitoring methods should be used. The QAE(s) may want to use information gathered from report reviews to identify a special population from which to select files or property inspections for review. The QAE(s) may use information from the reports to select specific files or properties to review or inspect more closely. Similarly, if the contractor has consistently been rated "Substantially Above Standards" or “Above Standards” in its performance, QAE may choose to limit its review of the contractor to post-closing reviews only. The contractor shall comply with FAR 42.15, Contractor Performance Information.

The contractor shall assist the CO in its post competition accountability endeavors by performing the following activities:

1. Collecting statistics about its performance throughout the life of the contract or a letter of obligation

2. Submitting information for use in a Quarterly Report at the request of the CO to the Office of Management and Budget that details in-progress and completed competitions

3. Monitoring performance

4. The contractor shall track actual personnel costs, material and supply costs, and other specifically attributable costs for the purposes of post competition accountability.

4.02 COMBINING METHODS

The COR/QAE will monitor the contractor’s performance on a continuous basis for the full performance period. The sheer volume of service request actions to be provided by the contractor makes 100% inspections impractical. Therefore, the COR/QAE will use a combination of methodologies to monitor the contractor’s performance. The methodologies include random inspections

These various methods of surveillance are not mutually exclusive and, as noted, are intended to be used in conjunction with one another. The PRS will provide the QAE(s) with an effective method to monitor the activities of the contractor. The selection of these surveillance methods is intended to minimize the effort required on the part of the inspector. However, these methods will be reviewed from time-to-time and modified based on actual contractor performance.

4.03 PERFORMANCE REQUIREMENTS SUMMARY

Listed below in Table 2 are performance measures associated with specifically identified performance requirements.

Table 2: Performance Requirements Summary

Performance Objective

Performance Standard Acceptable Quality Level

Surveillance Method

Floor cleaning Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Toilet and urinal cleaning

Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Restroom surfaces, fixtures, mirrors, sinks, etc. cleaning

Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Trash, litter & Recycling removal, and liner replacement

Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Spot clean wall surfaces, partitions, and doors.

Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Additional cleanings resulting from toilet floods and similar occurrences.

Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Servicing complaints from building occupants

Accomplish per specifications and frequency schedule

100% Visual inspections

Turn in daily deficiency reports for each site.

Accomplish per specifications and frequency schedule

95% Reports received by COR

Performance Objective

Performance Standard Acceptable Quality Level

Surveillance Method

To maintain a recognizable workforce

Ensure that employees wear the prescribed clothing and are clearly recognizable as employees of the contractor

99%

Visual inspection, visitor complaints, USPP involvement

Administration Breakroom cleaning

Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and NPS staff complaints

Carpeted area cleaning Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Clean spots and marks off walls; dust all surfaces

Accomplish per specifications and frequency schedule

2 defects per month

Random visual inspection and visitor complaints

Special Cleaning Requests

Accomplish per specifications and frequency schedule

100% Visual inspection

To maintain effective communications

The PM or designated personnel are available to meet (in person or by telephone) with the CO or

COR:

within two (2) hours after notification during business hours

Emergency:

98%

Non-emergency:

95%

CO / COR

complaint

To report emergency situations and follow required emergency reporting procedures and to assist the parks in providing a safe and secure environment for visitors

Immediately report acts of vandalism of park resources to Park Dispatch, USPP

98% Visual inspection and visitor complaints

To provide a current listing of POC(s) responsible for responding to emergency operations

Provide the CO a written list of key POC(s) within 30 calendar days prior to performance start date and not later than one (1) business day after changes are implemented

100% COR deliverable documentation

To maintain a current Quality Control Plan

Update the QCP six (6) months after award.

100% COR deliverable documentation

Performance Objective

Performance Standard Acceptable Quality Level

Surveillance Method

To provide a safe working environment for employees and the surrounding environment

Fit equipment with required safety devices and/or require employees to wear the required personnel safety gear

98% Visual inspection

To provide a safe working environment for employees and the surrounding environment

Abide by federal Occupational Safety & Health Administration (OSHA), state, and/or safety requirement

98% Visual inspection based on regulations / guidelines

To provide and maintain a current safety plan

Develop, implement, and execute a safety plan

100% COR deliverable documentation

To provide a safe and controlled working environment to insure the safe flow of traffic, protection of the work area, and the safety of the public

Provide access to visitors at all times.

98% The COR has the right to suspend work in whole or in part until immediate correction is made

Visual inspection based on regulations / guidelines

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5.01 QUALITY ASSURANCE EVALUATOR SCHEDULE

The QAE will develop a monthly surveillance schedule based on the SOW and the methods described in above Section 4.0. Copies of the schedule shall be sent to the CO and to the CO Representative. The schedule shall be marked “FOR OFFICIAL USE ONLY” and shall NOT be provided to the contractor. Changes will be sent to the CO and the COR.

5.02 ACTUAL SURVEILLANCE

Actual surveillance, or inspections, will be comparable to the planned surveillance schedule with any deviations noted in writing. A reduced number of inspections increase the Government’s risk of defective contractor performance. Therefore, it is essential that the number of planned inspections be accomplished to maintain an effective quality assurance system.

5.03 SURVEILLANCE DOCUMENTATION

The QAE(s) will document the results of the surveillance on the appropriate contractor performance checklist. All discrepancies/defects will be annotated in a Contract Discrepancy Report (CDR). The CDR and the accompanying checklists and forms shall be submitted monthly to the Contracting Officer. This documentation will allow for the Government to:

1. Consistently document the progress / regress of the contractor.

2. Objectively survey the contractor. Surveillance of the contractor’s performance of the requirements is subjective in nature. Therefore, consistent documentation allows the evaluator to build more objectivity into the process.

3. Maintain performance documentation that will provide a legal basis to take action.

(Informal anecdotal evidence cannot be used to reward the contractor or to initiate corrective actions).

4. Maintain that the requirements in the contract are properly implemented and executed.