Attachment 5-QASP - DDJC Janitorial.pdf

Revised October 2014

Quality Assurance Surveillance Plan

(QASP)

(DATE)

Contracting Officer Electronic Signature

Solicitation Number: SP330022P0048

Contractor:

Table of Contents

1. OVERVIEW

1.1 CONTRACT QUALITY REQUIREMENTS

2. RESPONSIBILITIES FOR QUALITY

2.1 DLA DISTRIBUTION JANITORIAL

2.2 SERVICE PROVIDER (SP)

2.3 QUALITY TEAM (QT)

3. PRINCIPLES OF SURVEILLANCE

3.1 QASP IMPLEMENTATION AND EXECUTION

3.2 SURVEILLANCE PLANNING AND SCHEDULING

3.3 QUALITY CHECKLISTS

3.4 DOCUMENTATION

3.5 MODIFICATIONS

4. QUALITY POLICIES, PROCEDURES, AND HELPFUL AIDS

4.1 THE 7-STEP SURVEILLANCE PROCESS

4.2 SURVEILLANCE METHODS

4.3 ... NON-CONFORMANCE TREND REPORTING

5. SURVEILLANCE ACTIVITIES FOR SPECIFIC TASKS

5.1 ACCEPTABLE PERFORMANCE LEVEL (APL) SURVEILLANCE

5.1.1 APL CATEGORY DEFINITIONS

5.1.2 MONITORING APLS

5.2 NON-APL SURVEILLANCE REQUIREMENTS

1. Overview This Quality Assurance Surveillance Plan (QASP) has been developed to supplement quality control efforts and provide a framework for performing quality assurance for service contracts within the distribution enterprise. The responsibility for the administration of the contract is the DLA Distribution, Acquisition Operations (J7). This surveillance plan is intended for enterprise-wide implementation and is applicable to identified service contracts. Additionally, this QASP has been developed to address DLA Accountability Office, Office of Internal Review, findings and recommendations (Audit Report DAO-09-20).

When requirements are issued as a performance-based solicitation as defined in FAR 37.601, a performance-based contract ensures the required performance quality levels are achieved and the total payment is related to the degree services performed or outcomes achieved meet contract standards.

FAR 37.602-2 requires enabling assessment of work performance against measurable performance standards and FAR 37.604 requires agencies to develop a QASP when acquiring services through performance-based contracts. The QASP recognizes the responsibility of the service provider (SP) to carry out its quality control (QC) obligations and contains measurable inspection and acceptance criteria corresponding to the performance standards and requirements contained in the contract. The QASP focuses on the level of performance required rather than the methodology used by the SP to achieve that level of performance.

The FAR, including Part 46, Quality Assurance, “prescribes policies and procedures to ensure that supplies and services acquired under Government contract conform to the contract’s quality and quantity requirements. Included are inspection, acceptance, warranty, and other measures associated with quality requirements.”

In order to verify fulfillment of the requirements for performance-based contracting, the contract must use measurable performance standards (e.g., in terms of quality, timeliness, and quantity).

Quality Team’s1 (QT’s) use the QASP as their guide for the verification process. This QASP complies with the requirements of FAR Parts 37 and 46 and serves as the QT’s guide to monitoring SP performance in accordance with (IAW) the requirements. It is organized into three major headings: Overview and Organization, Principles of Surveillance, and Surveillance Activities for Specific Tasks. The content outline above identifies further subdivisions of these sections. This outline also serves as the Table of Contents. The various headings and page references are hyperlinked to detailed topical discussions in the QASP.

A well implemented quality program includes two essential elements. The SP implements their Quality Control/Customer Satisfaction Plan (QC/CSP) through QC inspections of the services they perform IAW with contract requirements. The QT performs Quality Assurance (QA) on the SP IAW the QASP to ensure acceptable performance is achieved.

1 Quality Team (QT) is the term used to identify those individuals that have been assigned quality related roles and responsibilities.

1.1 Contract Quality Requirements

The FAR (46.202) identifies four general categories of contract quality requirements, depending on the extent of QA needed by the Government for the acquisition involved:

• Contracts for commercial items

• Government reliance on inspection by the SP

• Standard inspection requirements

• Higher-level contract quality requirements.

“Standard inspection requirements” is the primary category of inspection required in this contract.

As specified in FAR 46.202-3, standard inspection requirements:

• Require the SP to provide and maintain an inspection system that is acceptable to the Government

• Give the Government the right to make inspections and tests while work is in process

• Require the SP to keep complete, and make available to the Government, records of its inspection work

2. Responsibilities for Quality Responsibilities for contract QA are defined in FAR Part 46 for the Contracting Office, DLA Distribution, and the SP. Highlights of responsibilities are included in the following sub-paragraphs.

2.1 DLA Distribution Janitorial Support

• Develops and applies efficient procedures for performing government QA actions under the contract IAW the written direction of the contracting officer.

• Performs all actions necessary to verify whether the supplies or services conform to contract quality requirements.

• Develops, tests, and fields automated Quality Management Tool (QMT) to facilitate enterprise-wide collection and reporting of quality related operational information.

• Monitors QT work products to ensure non-conformances are identified.

• Establishes the significance of a nonconformance when considering the acceptability of supplies or services which do not meet contract requirements

• Maintains, as part of the performance records of the contract, suitable records including:

° The nature of Government contract QA actions, including, when appropriate, the number of observations made and the number and types of non-conformances

° Decisions regarding the acceptability of the products, the processes, and the requirements, as well as actions taken to correct nonconforming items

• Implements any specific written instructions from the contracting officer.

• Recommends any changes necessary to the contract, specifications, instructions, or other requirements that will improve effective operations or eliminate unnecessary costs

• Develops and provides specifications for inspection, testing, and other contract quality requirements essential to ensure the integrity of the supplies or services

• Prescribes contract quality requirements, such as inspection and testing requirements, or, for service contracts, a QASP

2.2 Service Provider (SP)

The SP is responsible for carrying out its responsibilities under the contract by:

• Controlling the quality of supplies or services

• Tendering to the Government for acceptance only those supplies or services which conform to contract requirements

• Ensuring vendors or suppliers of raw materials, parts, components, subassemblies, and others have an acceptable QC system

• Maintaining substantiating evidence, when required by the contract, that the supplies or services conform to contract quality requirements, and furnishing such information to the Government, as required

The SP provides and maintains an inspection system or program for the control of quality that is acceptable to the Government (See QC/CSP requirements in PWS).

The control of quality by the SP may relate to, but is not limited to:

• Fabrication and delivery of products to ensure only conforming products are tendered to the Government that will provide a high degree of customer satisfaction.

• Technical documentation, including drawings, specifications, handbooks, manuals and other technical publications

• Procedures and processes for services to ensure services meet contract performance requirements

• Training all appropriate personnel in the purpose, use, and implementation of the QC/CSP The SP is responsible for performing all inspections and tests required by the contract except those specifically reserved for performance by the Government.

2.3 Quality Team (QT)

The QT’s quality responsibilities include:

• The Contracting Officer’s Representative (COR) is a member of the QT and has reporting responsibility to the Contracting Officer. The COR is responsible for assuring the QASP is implemented.

• Ensure all appropriate personnel attend training in the purpose, use, and implementation of the QASP

• Implement the QASP, to include developing surveillance schedules, performing surveillance, and documenting and reporting results

• Monitor and review the QASP for effectiveness

3. Principles of Surveillance The inspection and acceptance clauses contained within the contract allow the QT to implement QA procedures. Other contract clauses require the SP to implement a QC/CSP, resulting in the SP being responsible for quality control assessments of goods and services produced. The Government is responsible for QA, surveillance, monitoring, and evaluation of the SP’s quality performance. This concept, defined in FAR 46.101, says Government contract QA means “the various functions, including inspection, performed by the Government to determine whether a contractor has fulfilled the contract obligations pertaining to quality and quantity” (emphasis added).

The QASP focuses on corroborating the quality and timeliness of the products and services received from the SP and the fulfillment of contract requirements including both APLs and 'non- APLs' – those mandatory requirements commonly referred to as “SP Shalls”.

3.1 QASP Implementation and Execution

Successful implementation of the QASP is based upon careful planning and targeted use of the following:

• Surveillance planning and scheduling

° Surveillance planning and scheduling is a function of the Quality Management Tool

(QMT)

• Performing surveillances, including complete documentation

• Data analysis of the surveillance results

• Reporting the results of the surveillances The following four objectives are the cornerstones for the QT’s daily surveillance activities and remain critical to QASP implementation:

• Monitor the SP compliance status to established APL and non-APL requirements

• Verify the SP’s compliance with their QC/CSP

• Document surveillance observations and findings

• Analyze and report surveillance results to the SP and DLA Distribution Points of Contact (POCs)

3.2 Surveillance Planning and Scheduling

An annual Surveillance Plan, which identifies the surveillance activities, frequencies, priorities, and POCs for monitoring the SP’s performance requirements, documents the QT’s inspection objectives for the year. This plan is created in the QMT and is made available to the COR, the Installation Support Commander/Director, the Distribution Center Commander/Director, and the Contracting Officer (KO), upon request. Based on the annual surveillance plan requirements, the Contract Quality Assurance Program Office (CQAPO) updates the monthly surveillance schedule in the QMT to identify required monthly surveillance events and frequencies. QT personnel update surveillance records to identify the surveillance activities and results for each surveillance activity performed during the month. The Site SL incorporates time to validate user complaint items into the surveillance schedule to the extent possible. The SL’s key responsibilities are tracking, analyzing, and reporting surveillance results.

During all periods of the SP performance, the Site SL retains a copy of all Surveillance Reports (SRs), User Complaint Records (UCRs), and other performance documentation. The Site SL either retains these records or forwards them to the KO at the end of the contract for inclusion in the contract file. SRs are electronically maintained within the QMT.

3.3 Quality Checklists

The quality assurance program and surveillance reporting relies on the use of standardized template checklists within QMT to conduct most surveillance activities. These template checklists are designed to document QA activities so that the QT and the SP can better focus on issues, respond in a timely manner, develop best business practices to improve customer service, and consistently document performance.

The DLA Distribution’s policies and procedures for using checklists and for helping a QT implement its QA surveillance responsibilities are in the DLA Distribution Contract Quality Assurance (CQA) Handbook (hereinafter referred to as “the Handbook”).

QA surveillance checklists within the QMT are modified and/or updated as approved modifications or changes are made to performance requirements. Every effort is made to standardize surveillance requirements across the distribution enterprise.

3.4 Documentation

Documentation of the SP performance provides, if needed, a legal basis for the Government to make decisions and take action. Informal or anecdotal evidence does not provide sufficient justification to reward (i.e., award/incentive fee) the SP or to initiate corrective actions. Properly completed surveillance documentation is objective: it is equally important to document both conforming and nonconforming performance. Documentation of conforming performance assists in validating proper implementation and execution of contract requirements and assists in identifying the SP approaches that work, which, when shared with other Depots, provide ideas for improvement. The vast majority of surveillance generally results in documenting conforming performance. Documentation of nonconforming performance identifies areas where the SP’s performance does not meet contract requirements and where re-performance of nonconforming services or corrective action may be needed.

It is critically important the QT regularly documents and reports on the SP performance as required by the surveillance schedules. If there is a pattern of forbearance2 or letting substandard performance go without the Government taking action, then the Government may lose its legal right to enforce contract performance provisions.

3.5 Modifications

The Contracting Office, or DLA Distribution may unilaterally modify surveillance requirements (i.e., input from the contractor is neither needed nor required). Such modifications are not subject to the modification clauses in the contract and are not grounds for the SP to increase the cost of performance. Conversely, bi-lateral modifications involve a negotiated approach and may or may not increase the cost of performance. In either case, modifications or changes to service requirements will be evaluated and changes to the surveillance requirements and/or QA template checklists in the QMT made accordingly by DLA Distribution through the change request process.

While modifications refer to changes in the surveillance requirements, typically driven by contracts operational performance requirements, modifications do not typically refer to monthly adjustments in surveillance schedules by QT personnel or other representatives. The Handbook provides more detailed information on specific roles and responsibilities.

2 According to DLA Distribution GC, various Boards of Contract Appeals cases have held that when the Government fails to promptly terminate a delinquent contractor or repeatedly permits a contractor to deviate from contract requirements without taking action, the Government may be found to have waived its rights under the contract. This is particularly true when the Contractor can show the Government was aware the Contractor was not in compliance, and that the Contractor then relied on the Government's lack of enforcement action. This waiver doctrine is closely related to the concept of estoppel whereby in certain cases the Government might have to suffer the consequences of its inactions; that is, the Government might be estopped from taking action against a Contractor if it does nothing to enforce parts of the contract, all the time knowing the Contractor was not complying. Note: estoppel means a legal bar to alleging or denying a fact because of one's own previous actions or words to the contrary.

(See generally Administration of Government Contracts, Third Edition, John Cibinic and Ralph Nash, George Washington University National Law Center, Government Contracts Programs Pages 69-77)

4. Quality Policies, Procedures, and Helpful Aids The Handbook provides the QT with specific policies, procedures, tools, and aids to help implement their QA responsibilities. This paragraph, the Handbook, and the QMT are the key tools and references the QT uses to conduct and document its QA surveillance activities.

4.1 The 7-Step Surveillance Process

The 7-Step surveillance process described in the Handbook is the mandated framework outlining the process by which the QT will implement all surveillance activities. The 7-Step Surveillance Process is as follows:

1. Identify the APL/non-APL criteria for surveillance activity

2. Review all relevant documentation

3. Conduct surveillance

4. Document observations in the post surveillance sections of the SR

5. Analyze the results

6. Report findings and make recommendations

7. File the SR with all supporting documentation in the QMT

4.2 Surveillance Methods

The surveillance methods described in the Handbook, apply to surveillance/monitoring of all contract requirements. DLA Distribution has recommended an appropriate method(s) to employ for each requirement. The following is a list of the recognized methods of surveillance:

• Direct Observation

• One Hundred Percent (100%) Inspection

• Validated Customer Complaints

• Random Sampling

4.3 Non-Conformance Trend Reporting

Non-Conforming Trend Reporting is used by the QT to determine the appropriate course of action following the documentation of the SP’s non-compliance and convey the significance of the surveillance, the individual checklist requirement, a count of the consecutive nature of the non-conformance and identifiable trends. Non-Conformance Trend Reporting relies upon surveillance frequency, number of nonconforming surveillance checklist requirements, and requirement significance to recommend the appropriate Government course of action. The course of action will range from filling out a nonconforming surveillance report to notifying the KO and suggesting a Contractor Discrepancy Report (CDR).

Depending upon the significance level of the individual checklist questions that were found nonconforming, a Corrective Action Plan (CAP) may or may not be required. Detailed guidance for the COR and Contract Specialist regarding CAP preparation and submission is included in DLA Distribution J3 Compliance SOP 4155.01.

5. Surveillance Activities for Specific Tasks The following are approaches that the QT uses to conduct surveillance activities for specific tasks IAW contract requirements:

5.1 Acceptable Performance Level (APL) Surveillance

5.1.1 APL Category Definitions

APLs are segregated into two categories; timeliness and quality. Service Contract functions may have one or both types of APLs associated with them. The following provides definitions for the APL categories:

• Timeliness – The APL standard is measured by whether the requirement or function is met in a pre-determined period of time.

• Quality – The APL standard is measured by whether the requirement or function meets a pre-determined quality standard

5.1.2 Monitoring APLs

APLs are reported monthly by the COR on the COR Report. The COR is responsible for providing rationale for significant instances of non-conformance as they track each APL throughout the month.

5.2 Non-APL Surveillance Requirements

The COR will conduct surveillance processes utilizing the QMT application. Each functional area has associated surveillance templates and checklists to be used during surveillance events. The COR utilizes a Surveillance Report (SR) to record and document individual surveillance events IAW DLA Distribution CQA Policy and CQA training guidance.

5.2 Non-APL Surveillance Requirements