Attachment 4 Quality Assurance Surveillance Plan JC Clinical Support Services Collbran.pdf

US Department of Agriculture (USDA)

Attachment 4 - Quality Assurance Surveillance Plan

Contents Project Name

Solicitation / Contract Number

Section 1: Introduction

1.1 Purpose

1.2 QASP Relation to the Contract

1.2.1 QASP Revisions

1.2.2 Surveillance of Performance Progression

1.3 QASP Relation to the Quality Control Plan (QCP)

Section 2: Performance Description

2.1 Performance Standards and Acceptable Quality Levels (AQLs)

2.1.1 Allowable Deviation

2.1.2 Substantially Complete

2.2 Non-Performance

2.2.1 Documentation

2.2.2 Remedial Actions

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

3.2.2 Contracting Officer Representative (COR)

3.2.3 Customers

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods

4.2 Analysis and Results

Appendix A: Example Performance Requirement Summaries ................................................................... Error! Bookmark not defined.

Appendix B: Example Discrepancy Report .................................................................................................. Error! Bookmark not defined.

Appendix C: Customer Feedback Record

Appendix D: Example Guide / Inspection List ............................................................................................. Error! Bookmark not defined.

Appendix E: Example Quality Assurance Monitoring

Appendix F: Example Customer Complaint Investigation

Appendix G: Example Surveillance Activity Checklist ................................................................................. Error! Bookmark not defined.

Project Name Job Corps Clinical Support Services

Solicitation / Contract Number 12318726Q0159

Section 1: Introduction This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS). The purpose of this contract is to provide the Centers with a simplified method of obtaining Temporary Clinical Services for vacant federal positions. This plan sets forth the procedures and guidelines that the USDA, Job Corps National Office will use in ensuring the required performance standards or services levels are achieved by the contractor.

1.1 Purpose

The purpose of the QASP is to describe the systematic methods used to measure performance and to identify the reports required and the resources to be employed. The QASP provides a means for evaluating whether the contractor is meeting the performance standards identified in the PWS. This 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 QASP Relation to the Contract

1.2.1 QASP Revisions

The Contracting Officer Representative (COR) may make revisions or changes to the QASP procedures and surveillance methods or increase or decrease the degree of surveillance methods at any time during the contract performance period. Changes to the Metric must be incorporated into the PWS, Performance Requirement Summary (PRS) and QASP by a bilateral modification to contract that is issued by the Contracting Officer (CO). A copy of the QASP is provided to the contractor to enable the contractor to enhance its Quality Control (QC) program to perform in accordance with its Quality Control Plan (QCP).

1.2.2 Surveillance of Performance Progression

As the performance period progresses, the levels of surveillance may be altered for service areas where performance is either consistently excellent or unsatisfactory. If consistently good performance, then the amount of surveillance may be reduced. If observations reveal consistent deficiencies, increased surveillance may be implemented.

1.3 QASP Relation to the Quality Control Plan (QCP)

The QCP is a required element of contract and the Contractor shall adhere to its established quality control processes and procedures in managing and performing work as described in the contract. While the QCP represents the way in which the Contractor will ensure its quality and timeliness of services, as defined in the PWS, the QASP represents the way in which the Government personnel specified in Section 3: Contractor and Government Responsibilities, Paragraph 3.2, Government Responsibilities will evaluate the contractor’s performance. The contractor’s QC program and the residual organization’s QASP should be complementary programs that ensure successful contractor performance.

Section 2: Performance Description Performance of the contractor will be monitored through the surveillance methods described in Section 4: Surveillance Methods to Perform Quality Assurance to assess the Contractor’s performance against PWS requirements.

2.1 Performance Standards and Acceptable Quality Levels (AQLs) For selected activities in the PWS, the PRS provides a performance standard and an AQL. A performance standard is the expected level of contractor performance. An AQL defines the level of performance that is satisfactory. Depending on the service evaluated and the evaluation method selected, performance standards and AQLs may be stated as a number of occurrences or as a percentage. Performance standards and AQLs for random sampling and 100 percent inspection are generally stated as percentages. For periodic inspections, performance standards may be stated as either percentages or as absolute numbers.

The contract requires the Contractor to perform all work as specified. Any inaccuracies or omissions in services or products are referred to as “defects” on the part of the Contractor. The Contractor shall be responsible for all identified defects and may be required to perform the work at no cost to the government. The AQLs take into account that in some instances an allowable level of deficiencies (deviations) is possible while overall performance continues to meet the government’s desired level of service.

2.1.1 Allowable Deviation

The AQLs define the level or number of performance deficiencies the Contractor is permitted to reach under this contract. AQLs take into account the difference between an occasional defect and a gross number of defects. AQLs can be expressed as a percentage of or as an absolute number (e.g., three per month). There may be instances where 100 percent compliance is required, and no deviation is acceptable (e.g., where safety is involved).

2.1.2 Substantially Complete

In some cases, service outputs are evaluated using subjective values (e.g., excellent, satisfactory, unsatisfactory). The criteria for acceptable performance and for defects must be defined for these service outputs. The concept of “substantially complete” should be the basis for inspections based on subjective scales. Work is considered “substantially complete” where there has been no significant departure from the terms of the contract and no omission of essential work. In addition, the Contractor has performed the work required to the best of its ability and the only variance consists of minor omissions or deficiencies.

2.2 Non-Performance

Non-performance occurs when the contractor’s performance does not meet the AQL for a given requirement.

Requirements may contain multiple performance elements, and therefore, deficiencies may occur in one or more aspects of performance (e.g., timeliness, accuracy, completeness, etc.) or subject areas of effort.

When surveillance indicates that the contractor's service output is not in compliance with the contract requirements, the Contracting Officer’s Representative (COR) must determine whether the Contractor or the Government caused the deficiency. If the cause of the defect rests with the Government, corrective action must be taken through Government channels. If the cause of the defect is due to action or inaction by the contractor, the contractor is responsible for correction of the problem at no additional expense to the Government.

2.2.1 Documentation

Documentation of work non-performed or unacceptable work is essential for tracking Contractor performance. The COR will document deficient work by compiling facts describing the inspection methods and results and to substantiate nonconformance with the contract. A sample documentation reporting form is provided in Appendix Proposal

Evaluation Criteria

The documentation, with any recommendations, will be forwarded to the CO. In the case of the Contractor, the COR will decide whether to elevate the problem to the CO for corrective action.

2.2.2 Remedial Actions

The Federal Acquisition Regulation allows for penalties in the event that the Contractor fails to perform the required services. Penalties are defined as those actions taken under the direction of the CO against the contractor within the general provisions of the contract for nonconformance to the PWS and PRS.

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

The Contractor is responsible for delivering products or services in accordance with the contract. Implementing its QCP, which describes the Contractor’s methods for ensuring all products and services under the contract meet established performance standards and AQLs. Maintaining, and providing for audit, quality control records and reports and all records associated with the investigation and complaint resolutions. Appointing a single quality control point-of-contact to act as a central recipient of communication from the COR or CO.

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

The CO is responsible for administering and monitoring contract compliance, contract administration, and cost control and for resolving any differences between the observations documented by COR and the contractor’s performance. The CO may delegate various day-to-day contract administration duties to an Administering ACO (ACO) and/or the COR for performance management and administrative actions such as invoice approval and issuance of Contract Discrepancy Reports may be, and normally are, delegated by the CO to the COR. The CO shall approve any revisions to the QASP processes or standards.

3.2.2 Contracting Officer Representative (COR)

The COR, is designated in writing, by the CO. The COR will ensure that the QA function is properly executed, plays a key role in contract administration and performs the contract surveillance and monitoring. Some key contract administration duties include, but are not limited to, performs surveillance as required by this QASP; make recommendations to the CO for issuance of Contract Discrepancy Reports or letters of commendation and acceptance or rejection of completed work and for administrative actions based on unsatisfactory or non-performed work, and revisions or changes to the QASP;

and assists the CO in identifying necessary contract modifications and preparing reports of Contractor performance and cost.

The COR may use the form(s) included in the Appendices to perform the inspection or other forms as approved by the CO. The Contractor overall guidance is also provided by FAR clause 12.201-1(b)(2) in Section (page 2) of the contract.

3.2.3 Customers

Customers or organizations/offices that the Contractor provided support may be requested to assist the COR in conducting QA to provide information relating to the Contractor’s performance through Customer Feedback.

Information gained from the Customer Feedback may be used in conjunction with other methods of observation to rate the performance of the Contractor.

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods

The surveillance methods used in the QA process are the Government’s tools to monitor the Contractor’s products and services. The best means of determining whether the Contractor has met all contract requirements is to inspect the Contractor’s service products and analyze the results. Further, documented inspection results are an effective tool in contract administration that can confirm the successful achievement of all performance requirements or highlight areas where defects exist and improvements are necessary.

Deliverable Performance Standard

Acceptable quality level

Method of surveillance

Submit deliverable to

The contractor shall provide all resources and equipment necessary to carry out the requirements stated in the PWS

Resources and Equipment available 98% of the time

98% Periodic Inspection

COR

The contractor shall provide required number of personnel to fill all position.

Including for missed shifts of regular shifts.

All positions filled 98% of the time

95% Periodic Inspection

COR

The contractor shall provide personnel for 40 hour of work per week. Hours may be adjusted by the COR as needed upon CO approval.

All positions filled 98% of the time

98% 100% Inspection

COR

The contractor shall provide a Quality Control Plan.

QC Plan available 10 days after award

100% Periodic Inspection

COR

The contractor shall provide a monthly status report each month. The monthly report shall include scheduled, completed and outstanding tasks. Problems/issues/concerns/successes and failures at the site, pay issues, and other information deemed important.

Reports provided on time and accurately depict current status

100% Monthly file review, and random observations, customer complaints

COR

Employees to maintain logs as required Reports to be daily and accurate.

97% Random file review, and customer complaints

Center

POC/COR

Inform center of new hires 2 days prior to first shift.

Contractor complies 97% of the time

97% Customer Complaint

Center

POC/COR

4.2 Analysis and Results

When the inspections and “customer feedback” validations have been completed, the COR will perform an analysis of the Contractor’s performance. The purpose of the analysis is to ensure Government is receiving high-quality products and services from the Contractor. The COR will review the results, rate the Contractor’s compliance with the performance standards and AQLs, and characterize the Contractor’s overall performance. Analysis of all types of contract monitoring will result in one of the following outcomes:

4.2.1 – COR will notify Contractor of result on a quarterly basis is all review is acceptable.

4.2.2 – COR will notify Contractor of result immediately is there is compliant or unacceptable performance.

4.2.3 – COR will complete the CPARS rating as required.

[THIS PAGE IS FOR INFORMATIONAL PURPOSES]

The Contacting Officer must include as attachments or exhibits the appropriate performance requirement summary, forms, checklists, etc. in the QASP that will be used during surveillance / monitoring for the applicable contract.

Appendix C: Customer Feedback Record The following document will be used by Center’s point of contact to complete and submit to the COR/CO.

CUSTOMER FEEDBACK RECORD

DATE AND TIME OF COMPLAINT CONTRACT NUMBER/ OR PROJECT:

SOURCE OF COMPLAINT

ORGANIZATION

INDIVIDUAL

NATURE OF COMPLAINT

PWS REFERENCE

VALIDATION

DATE AND TIME CONTRACTOR INFORMED OF COMPLAINT NAME OF CONTRACTOR REPRESENTATIVE INFORMED OF COMPLAINT

ACTION TAKEN BY CONTRACTOR (Responsible officer):

RECEIVED AND VALIDATED BY

Determination: Complaint Valid Complaint Invalid

Appendix E: Example Quality Assurance Monitoring The following document will be used to review and provide analysis of performance.

CONTRACT NUMBER: ______________________________________

SERVICE or STANDARD:

SURVEY PERIOD:

SURVEILLANCE METHOD (Check the applicable item):

Random Sampling 100% Inspection Periodic Inspection Customer Complaint

LEVEL OF SURVEILLANCE (Check the applicable item):

Monthly Quarterly As needed

PERCENTAGE OF ITEMS SAMPLED DURING SURVEY PERIOD: ______ %

ANALYSIS OF RESULTS:

Observed Service Provider Performance Measurement Rate: ______%

Service Provider’s Performance (Check the applicable item):

Meets Standards

Does Not Meet Standards

Narrative of Performance During Survey Period:

Prepared By: _______________________________ Date: ______________

Appendix F: Example Customer Complaint Investigation The following document will be used to report to the Contractor what information was found during the investigation.

CONTRACT NUMBER: _________________________

SERVICE or STANDARD:

SURVEY PERIOD: ___________________

DATE COMPLAINT RECEIVED: ____________

SOURCE OF COMPLAINT: _________________________________________ (Name) _______________________________________________________________ (Organization) ___________________ (Phone No.) _________________________________ (Email Address)

NATURE OF COMPLAINT:

RESULTS OF COMPLAINT INVESTIGATION:

DATE SERVICE PROVIDER INFORMED OF COMPLAINT: _____________

CORRECTIVE ACTION TAKEN BY SERVICE PROVIDER:

Received and Validated By: __________________________________________ Prepared By: _____________________________ Date: _________________