Attachment 4-QASP-VISN 7 Virtual Pharmacy Services.docx

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VISN 7 Virtual Pharmacy Services
Solicitation number
36C24726Q0605
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This is a Quality Assurance Surveillance Plan (QASP) for the VISN 7 Virtual Pharmacy Services contract with the Department of Veterans Affairs. The QASP establishes the framework for monitoring contractor performance in delivering remote pharmacy services across Georgia, Alabama, and South Carolina within the Veterans Integrated Service Network 7. The contractor must provide licensed pharmacists, technical support personnel, medical equipment, and a secure web-based system to process pending clinic and outpatient prescription orders and support inpatient pharmacy services. The Contracting Officer is identified as Leonard Robinson (leonard.robinson@va.gov), while the Contracting Officer's Technical Representative and contractor Program Manager are to be designated.

The QASP defines five primary performance standards: RX Processing (maintaining backlog under 72 hours at 100% compliance), Non-Formulary Processing (95% compliance without approval), Drug Information Source evaluation (99% compliance for reviewing lab data and drug interactions), Medication Error Reporting (99% accuracy in processing with appropriate error investigation), and Customer Service (99% compliance in responding to inquiries within 24 hours). Surveillance methods include direct observation, periodic inspections, user surveys, validated customer complaints, and random sampling. The contractor must submit daily reports for medication errors, property damage, security incidents, and theft; monthly reports on prescriptions processed; and quarterly training reports. Performance ratings will be documented as acceptable or unacceptable, with unacceptable performance triggering a Contract Discrepancy Report and corrective action plan requirements. Quarterly performance assessment meetings between the COTR and contractor are mandated.

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QUALITY ASSURANCE SURVEILLANCE PLAN

VISN 7 Virtual Pharmacy Services

QUALITY ASSURANCE SURVEILLANCE PLAN

For: VISN 7 Virtual Pharmacy Services

Contract Number: TBD

Contract Description: The Contractor shall provide professional virtual pharmacy services to complete pending clinic and outpatient prescription orders for the Department of Veterans Affairs, VISN 7 located in Georgia, Alabama, and South Carolina. Contractor shall provide enough licensed Pharmacists to perform remote prescription order review/order entry services for inpatient pharmacy services. This includes the professional review and problem solving needed to ensure safe and appropriate medication processing. The contractor shall provide pharmacists, technical support personnel, medical and telecommunication equipment, supplies, and supervision necessary to perform and implement virtual pharmacy services to meet the needs of VINS 7. The contractor must be a U.S. based corporation capable of providing remote pharmacy services to be completed via secure web-based system provided by the contractor.

Contractor’s name: TBD

1. PURPOSE

This Quality Assurance Surveillance Plan (QASP) provides a systematic method for evaluating performance under the stated contract. This QASP explains the following:

· What will be monitored.

· How monitoring will take place.

· Who will conduct the monitoring.

· How monitoring efforts and results will be documented.

This QASP does not detail how the contractor accomplishes the work. Rather, the QASP is created on the premise that the contractor is responsible for management and quality-control actions to meet the terms of the contract. It is the Government’s responsibility to be objective, fair, and consistent in evaluating performance.

This QASP is a “living document,” and the Government may review and revise it regularly. However, the Government shall coordinate changes with the contractor. Copies of the original QASP and revisions shall be provided to the contractor and Government officials implementing surveillance activities.

2. GOVERNMENT ROLES AND RESPONSIBILITIES

The following personnel shall oversee and coordinate surveillance activities.

a. Contracting Officer (CO) - The CO shall ensure performance of all necessary actions for effective contracting, ensure compliance with the contract terms, and safeguard the interests of the United States in the contractual relationship. The CO shall also ensure that the contractor receives impartial, fair, and equitable treatment under this contract. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance.

Assigned CO: Leonard Robinson @ leonard.robinson@va.gov Organization or Agency: Department of Veterans Affairs, Office of Acquisition and Materiel Management

b. Contracting Officer’s Technical Representative (COTR) - The COTR is responsible for technical administration of the contract and shall assure proper Government surveillance of the contractor’s performance. The COTR shall keep a quality assurance file. The COTR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government’s behalf.

Assigned COTR: TBD

c. Other Key Government Personnel – TBD

3. CONTRACTOR REPRESENTATIVES

The following employees of the contractor serve as the contractor’s program manager for this contract.

a. Program Manager – TBD

4. PERFORMANCE STANDARDS

Performance standards define desired services. The Government conducts surveillance to determine whether the contractor meets, exceeds, or does not meet these standards.

Paragraph 7 of the Performance Requirements Summary Matrix in the Performance Work Statement (PWS) includes performance standards. The Government shall use these standards to determine contractor performance and compare it to the Acceptable Quality Level (AQL).

TASK
INDICATOR
STANDARD
ACCEPTABLE LEVEL
METHOD OF SURVEILLANCE
ACTION
RX Processing
Process Outpatient Rx’s in queue in a timely manner
Process Rx’s to extent to keep backlog in queue less than 72 hours
100%
Monthly report of Rx’s processed by pharmacist
If less than 100% a plan of action required or a CDR.
Does not process non-formulary Rx’s without approval
No non-formulary Rx’s processed without approval
95%
Review by exception
If less than 95% a plan of action required or a CDR.
Drug Information Source
Evaluates lab data, drug interactions, adverse drug events, and screens for allergies when processing Rx
Review of appropriate patient safety monitors when processing Rx
99%
Review by exception
If less than 99% a plan of action required or a CDR.
Med Error reporting
Rx’s will be processed accurately (correct drug, dose, sig, comments copied appropriately, etc.) and errors reported and investigated
99%
Review by exception
If less than 99% a plan of action required or a CDR.
Customer Service
Provides excellent customer service to field and site POC
Will respond to inquiries/questions timely (usually within 24 hours)
99%
Review by exception
If less than 99% a plan of action required or a CDR.

5. INCENTIVES

There are no incentives pertaining to this contract.

6. METHODS OF QA SURVEILLANCE

Various methods exist to monitor performance. The COTR shall use the surveillance methods listed below in the administration of this QASP.

a. DIRECT OBSERVATION. Direct observation is required periodically for compliance to contract of contractor facility, services, documentation, invoices, and other listed in the administration of this QASP

b. PERIODIC INSPECTION. Scheduled and unscheduled Inspections will be conducted by the COR/CO or designated personnel to ensure contract compliance.

c. USER SURVEY. Complaints received from customers will be reported to the contractor, and VA will be logged and submitted to the contractor for immediate resolution/corrective action. The contract will monitor complaints monthly and report to the Virtual Pharmacy Coordinator quarterly.

d. VALIDATED USER/CUSTOMER COMPLAINTS. VA beneficiaries' complaints reported to the contractor and VA will be logged and submitted to the contractor for immediate resolution/corrective action. The contractor will monitor complaints monthly and report to the COR.

e. RANDOM SAMPLING. Option to be utilized by the COR and CO in reviewing vendor employee training records and VA beneficiaries’ folders to ensure contract compliance.

8. RATINGS

Metrics and methods are designed to determine if performance exceeds, meets, or does not meet a given standard and acceptable quality level. A rating scale shall be used to determine a positive, neutral, or negative outcome. The following ratings shall be used:

PERFORMANCE RATINGS

9. DOCUMENTING PERFORMANCE

a. ACCEPTABLE PERFORMANCE

The Government shall document positive performance. Any report may become a part of the supporting documentation for any contractual action.

b. UNACCEPTABLE PERFORMANCE

When unacceptable performance occurs, the COTR shall inform the contractor. This will normally be in writing unless circumstances necessitate verbal communication. In any case, the COTR shall document the discussion and place it in the COTR file.

When the COTR determines formal written communication is required, the COTR shall prepare a Contract Discrepancy Report (CDR) and present it to the contractor's program manager.

The contractor shall acknowledge receipt of the CDR in writing. The CDR will specify if the contractor is required to prepare a corrective action plan to document how the contractor shall correct the unacceptable performance and avoid a recurrence. The CDR will also state how long after receipt the contractor has to present this corrective action plan to the COTR. The Government shall review the contractor's corrective action plan to determine acceptability.

Any CDRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO.

REQUIRED REPORTS AND DOCUMENTS

DAILY REPORTS

REPORT DESCRIPTION
SEND REPORT TO:
Med Error Reporting
COR/CO
Property Damage Report
COR/CO
Incident Report (Security. Privacy Incident)
COR/CO/ VA OIT
Theft or Break in Report
COR/CO/ VA OIG

MONTHLY REPORTS

REPORT DESCRIPTION
SEND REPORT TO:
Monthly Rx's Processed by Pharmacist
COR/designee

QUARTERLY REPORTS

REPORT DESCRIPTION
SEND REPORT TO:
Contractor / Sub-Contractor Training Report
COR/CO

10. FREQUENCY OF MEASUREMENT

a. Frequency of Measurement.

During contract performance, the COTR will periodically analyze whether the negotiated frequency of surveillance is appropriate for the work being performed.

b. Frequency of Performance Assessment Meetings.

The COTR shall meet with the contractor QUARTERLY to assess performance and shall provide a written assessment.

Signature – Contractor Program Manager

Signature – Contracting Officer’s Technical Representative

CONTRACT DISCREPANCY REPORT

1. CONTRACT NUMBER
2. REPORT NUMBER FOR THIS DISCREPANCY
3. TO: (Contracting Officer)
4. FROM: (Name of COR)

5. DATES

a. CDR PREPARED

b. RETURNED BY CONTRACTOR:
c. ACTION COMPLETE

6. DISCREPANCY OR PROBLEM (Describe in detail. Include reference to PWS Directive; attach continuation sheet if necessary.)

7. SIGNATURE OF COR
Date:
8. SIGNATURE OF CONTRACTING OFFICER
Date:
9a. TO (Contracting Officer)
9a. FROM (Contractor)

10. CONTRACTOR RESPONSE AS TO CAUSE, CORRECTIVE ACTION AND ACTIONS TO PREVENT RECURRENCE. (Cite applicable quality control program procedures or new procedures. Attach continuation sheet(s) if necessary.)

11. SIGNATURE OF CONTRACTOR REPRESENTATIVE
Date:

12. GOVERNMENT EVALUATION. (Acceptance, partial acceptance, reflection. Attach continuation sheet(s) if necessary.)

13. GOVERNMENT ACTIONS (Acceptance, partial acceptance, reflection. Attach continuation sheet(s) if necessary.)

14. CLOSE OUT

NAME
TITLE
SIGNATURE
DATE

a. CONTRACTOR NOTIFIED

b. COR

c. CONTRACTING OFFICER

SUBMIT QUARTERLY / END OF CONTRACT REPORT TO CONTRACTING OFFICER (90C)

CONTRACTOR / SUB-CONTRACTOR TRAINING REPORT

Note: If any of the training below is not applicable to subject Contract, the COR will notate N/A, add initials and date each line.

Course / Training Requirement
COR /Contractor add Initials -- Certificate Attached as Applicable
Date Completed

VA Privacy and Information Security Awareness and Rules of Behavior (VA 10176) Target audience: This course is for all VA staff, contractors and volunteers who use a computer to perform their job.

Privacy and HIPAA Training (VA 10203) Target audience: Any VA employee or non-VA employee with access to Protected Health Information (PHI)

Integrity and Compliance Awareness Training for all Staff -

(VA 43790)

Emergency Preparedness / Disaster Policy and Procedures (location specific)

Initial competence assessment/employee competencies

Area / Program / Unit Specific Orientation

Specific MCM requirements:

NEW PROVIDERS

NAME DATE STARTED
PRIVILEGED
BACKGROUND

PROVIDERS NO LONGER PROVIDING SERVICES

NAME
LAST DAY OF WORK

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