Attachment 5 - Quality Assurance Surveillance Plan.pdf

Version 01/24/2018

Quality Assurance Surveillance Plan

For

Drug Testing BEP-WCF

10/31/2024

COR

DATE BEP

CONTRACTING

OFFICER

Michael Horn

DATE

SUMMARY OF REVISIONS

Revision Dated

Revision page(s) number

Content Position Name

Original version Date

Original COR

Michael Horn

TABLE OF CONTENTS

Subject Page Number

1. Overview

2. Description of Services/Supply/Product

3. Roles and Responsibilities

4. Contract Quality Requirements

5. Government Surveillance

6. Non-Conforming Performance

7. Data Analysis

8. Acceptance of Services

9. COR Status Report

10. Contractor Performance Assessment Reporting System (CPARS)

11. COR/Quality Assurance Surveillance Files

12. QASP Changes

1. Overview.

1.1. Purpose. The purpose of this Quality Assurance Surveillance Plan (QASP) is to identify the methods and procedures the Government will use to ensure it receives the services under this contract as identified in the Performance Work Statement (PWS).

1.2. Intent. The intent of this QASP is to: 1) ensure Contractor performance meets or exceeds contract terms, conditions and specifications; 2) hold the Contractor accountable for quality control; and 3) encourage the Contractor to take appropriate steps to control and improve quality.

Accordingly, the Government will perform surveillance on the contract in accordance with this QASP, but reserves the right to monitor the contract in any manner necessary, at any times necessary, and at all places necessary to ensure that the rendered services conform to contract requirements. The Government also reserves the right to perform quality assurance at the Subcontractor level and perform quality assurance at the contractor's place of business, if applicable. Resolution of non-conforming services discovered at the Subcontractor level will be addressed with the prime Contractor.

2. Description of Services.

2.1. Scope of Work. This is a non-personnel services BPA to provide drug testing services for the Bureau of Engraving and Printing (BEP) in Fort Worth, Texas (WCF). The government shall not exercise any supervision or control over the contract service providers performing the services herein. Such contract service providers shall be accountable solely to the Contractor who, in turn is responsible to the government.

The specific objective of this BPA is to coordinate the collection of specimens required to carry out the BEP’s Drug-Free Federal Workplace Program required under E.O. 12564. Such coordination will be in compliance with the scientific and technical guidelines issued by the Department of Health and Human Services (DHHS) and the Office of Personnel Management for Drug-Free Federal Workplace Programs.

E.O. 12564 and Public Law 100-71 prohibit any unauthorized use of controlled substances. Drug testing is conducted by analyzing the applicant’s/employee’s urine/saliva specimen. The analysis is performed at laboratories certified and monitored by DHHS. A list of DHHS approved laboratories is published monthly in the Federal Register. Specimens are analyzed for the following: Marijuana, Cocaine, Amphetamines, Opioids, Phencyclidine, and other substances identified by DHHS or other legal entities in the future.

BEP-WCF has approximately 747 employees. Random drug testing requirements extend to approximately 534 employees that occupy testing designated positions. BEP-WCF has a 7 day a week, 24 hour-a-day operation. Drug testing provisions must accommodate this operational environment. In order to minimize time away from work BEP-WCF will provide a drug-testing facility for employee collections at its work site. BEP-WCF also conducts testing for approximately 120 internal and external applicants/hires annually. Pre-employment testing for these individuals and BEP Teleworkers/Remote Workers needs to be conducted at clinics near

(generally within a 25-mile radius) the applicant’s home or business address. The applicants and tele/remote workers must be given a specific date and time for their appointment and not simply the hours of operation of the clinic that their drug test is to be conducted. The applicant must also be notified by email and phone of the date, time, and location of their appointment as well as being notified that they have 48 hours to take their test or the job offer could be rescinded. This agreement will also cover fees for Litigation Packages and Non-Negative test handling. It will also cover education and training sessions annually with up to 175 participants for BEP supervisors and DERs.

BEP-WCF will also be the contingency plan for testing services for the BEP-DCF.

2.2. Type of Contract. Blanket Purchase Agreement (BPA). Firm Fixed Price BPA Calls will be issued against the BPA.

3. Roles and Responsibilities.

3.1. Government.

3.1.1. Contracting Officer (CO). The CO is the only person with the authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the Government. Note: The only individual who can legally bind the Government.

3.1.2. Contract Specialist. The official Government representative delegated authority by the Contracting Officer to administer a contract. This individual is normally a member of the appropriate Contracting/Procurement career field and advises on all technical contractual matters.

3.1.3. Contracting Officer’s Representative (COR). The (COR) will be identified by separate letter. The COR monitors all technical aspects of the contract and assists in contract administration. The COR is authorized to perform the following functions: assure that the Contractor performs the technical requirements of the contract: perform inspections necessary in connection with contract performance: maintain written and oral communications with the Contractor concerning technical aspects of the contract: issue written interpretations of technical requirements, including Government drawings, designs, specifications: monitor Contractor's performance and notifies both the Contracting Officer and Contractor of any deficiencies;

coordinate availability of Government furnished property, and provide site entry of Contractor personnel. A letter of designation issued to the COR, states the responsibilities and limitations of the COR, especially with regard to changes in cost or price, estimates or changes in delivery dates. The COR is not authorized to change any of the terms and conditions of the resulting order.

4. Contract Quality Requirements.

4.1. Contractor’s Quality Control Program. Quality Control is the responsibility of the contractor. The contractor is responsible for the delivery of quality services/supplies to the government.

The contractor shall develop, implement, and maintain an effective Quality Control System which includes a written Quality Control Plan (QCP). This plan will be submitted to the Contracting Officer and COR within 30 days after contract award. The QCP shall implement standardized procedure/methodology for monitoring and documenting performance to ensure all BPA requirements are met. The contractor’s QCP must contain a systematic approach to monitor operations to ensure acceptable services/products are provided to the government. The QCP as a minimum shall address; procedures for scheduling, conducting and documentation of inspection;

discrepancy identification and correction; corrective action procedures to include procedures for addressing Government discovered non-conformance; procedures for root cause analysis to prevent reoccurrence of discrepancies and procedures for collecting and addressing customer feedback/complaints.

The contractor shall upon request provide to the Government their quality control documentation. The contractor agrees to submit Quality Control (QC) specimens to the contract lab in accordance with ratios specified by the DHHS Guidelines. QC specimens will be purchased and repackaged to resemble BEP samples. The contractor will report the results to the Designated Employer Representative (DER)/Contracting Officer Representative (COR) monthly.

4.2. Government Quality Assurance. The government shall evaluate the contractor’s performance under this BPA in accordance with the Quality Assurance Plan. This plan is a Government only document Primarily focused on what the Government must do to assure that the contractor has performed in accordance with the requirements of the BPA.

5. Government Surveillance.

5.1. Methods of Surveillance. The following Methods of Surveillance will be utilized in monitoring the Contractors’ performance:

5.1.1. 100% Inspection Reserved for the highest risk areas where consequence of failure is high (i.e. life or limb are threatened) or there is likelihood of mission failure.

5.1.2. Random Sampling - When a service is performed relatively frequently and a statistically valid sample can be selected for audit. The most appropriate method for frequently recurring tasks.

5.1.3. Periodic Inspection - Planned sampling of a service at specific predetermined dates and times. May be appropriate for tasks that occur infrequently.

5.1.4. Customer Feedback. The Customer Complaint Record, Attachment 2, will be used to document/record all complaints. The following procedures will be followed when a complaint is received.

• The COR will investigate and determine the validity of the complaint.

• If the complaint is determined to be invalid, the COR will inform the person who submitted the complaint of the reason(s) as soon as practical.

• For validated complaints that are true contractual non-conformances, the procedures in paragraph 6 below will be followed.

5.2. Surveillance Schedule. A Surveillance Schedule will be created each month utilizing the COR Surveillance Schedule, Attachment 3. The schedule is “FOR OFFICIAL USE ONLY” and is not releasable to anyone other than authorized Government personnel. A copy of the Surveillance Schedule will be filed and will become part of the CORs file.

5.3. Surveillance Instructions/Checklists. Surveillance Checklists, Attachment 4, will be utilized and completed when surveillances are conducted.

5.4. Surveillance Documentation. The applicable Surveillance Checklist(s) will be completed when/as Surveillances are conducted. Completed Surveillance Checklist(s) will be filed in CORs file. The file will have ready access to the BEP Office of Acquisition.

6. Non-Conforming Performance. Non-conformance occurs when a Contractor fails to meet Contract or Task Order terms, conditions and/or specifications. All instances of non-conformance will be documented and the Contractor will be notified. Resolution of non-conformance discovered at the Subcontractor level will be addressed with the prime Contractor.

Non-conformance is classified as either: Level I (Minor); Level II (Major); or Level III (Critical).

6.1. Level I (Minor). Level I non-conformance is not likely to materially reduce the usability of services for their intended purpose or is a departure from established standards having little bearing on completing the contract requirement. Minor non-conformances can usually be corrected on the spot and can be issued to the Contractor through either a verbal or written Contract Discrepancy Report (CDR). However, the Government is still required to document verbal Level I CDRs. The COR may issue verbal Level I CDRs directly to the appropriate level of Contractor management. The COR will notify the CO as soon as practical when a verbal Level I CDR is issued and document them in their Monthly Reports. If the non-conformance cannot be corrected on the spot, the Contractor shall be given a suspense date to correct the deficiency. The CO will issue and sign written Level I CDRs, Attachment 5.

6.2. Level II (Major). Level II non-conformance is likely to result in failure of the services to meet contract requirements. Also, repeated discrepancies, a large number of documented Level I CDRs and trends indicating failure of the Contractor’s quality control program can be classified as Level II CDRs. The CO issues all Level II CDRs in writing, Attachment 5. The COR will notify the CO as soon as practical when a major non-conformance is identified.

6.3. Level III (Critical). Level III non-conformances result in hazardous or unsafe conditions due to the manner in which the services are performed; prevent or impact a vital agency mission as a result of performance; or are for repeated or uncorrected Level II CDRs. The Contracting Office Director or Deputy Director issues written Level III CDRs. The COR is responsible for notifying the CO immediately upon discovery of a critical non-conformance.

6.4. Documenting CDRs. Documentation, as a minimum, will include: the Contract or Task Order number; reference to the specific contract requirement; the specific discrepancy to the requirement; where it was discovered; the date and time it was discovered; Contractor representative who was notified; and the suspense date for Contractor response/corrective action.

6.5. Tracking and Resolving CDRs. All CDRs, verbal and written, regardless of issuer will be included in the COR’s Monthly Report. The COR and CO shall track CDRs to ensure the Contractor identifies and takes appropriate corrective action to the root cause and the specific non-conformance is corrected within the required timeline. The CO will make a final written determination of the Government’s remedies if the non-conformance is not corrected by the Contractor after receiving notice and a reasonable opportunity to correct the work.

7. Data Analysis. Data Analysis will be performed to identify trends in cost, schedule and/or performance risks. The results of Data Analysis will be documented in COR Status Reports and may be used to make adjustments to surveillance schedules, increase or decrease surveillance, if deemed appropriate. Negative trends noted using Government data/observations could result in issuing the Contractor a Contract Discrepancy Report. Trends noted using Contractor data will not result in a CDR unless the Contractor is not addressing the negative trend.

8. Acceptance of Services. When all services have been deemed acceptable and there is documented objective quality evidence to support acceptable performance the COR will accept the services provided and authorize payment of the Contractor. This is accomplished by approving the Contractor’s Receiving Reports via IPP.

9. COR Status Report. COR Status Reports will be submitted on a Monthly basis to the Contracting Officer. COR Status Reports will provide a synopsis of the Contractors performance for the inclusive dates of the report. The synopsis will contain a summary of: surveillances performed; Customer Feedback, if any; CDRs, if any; an analysis of the Contractors performance; recommended adjustments to surveillance schedules; and any other pertinent contract information. Completed Surveillance Checklists and CDRs, if any, will be included as attachments to COR Status Reports or uploaded separately in the Miscellaneous Documents Section of the CORs’ Online file.

10. Contractor Performance Assessment Reporting System (CPARS). Documented surveillance data (COR Status Reports, Completed Surveillance Checklists, Customer Feedback and CDRs, if any) will be used to support CPARS ratings for BPA Calls that exceed CPARS reporting requirements.

11. COR/Quality Assurance Surveillance Files. The official COR/Quality Assurance Surveillance File will be maintained by the COR.

12. QASP Changes. This QASP is a living document and, as such, may be changed as needed based on Data Analysis (trends), contract modifications, etc. The COR will send any recommended changes to the Contracting Officer for approval and the Contracting Officer must approve all changes.

Attachments:

1. Performance Requirements Summary (PRS)

2. Customer Complaint Record

3. Surveillance Schedule

4. Surveillance Checklist(s)

5. Contract Discrepancy Report

Attachment 1

Performance Requirements Summary (PRS)

The contractor services requirements are summarized into performance objectives that relate directly to mission essential items. The performance threshold describes the minimum acceptable levels of service required for each requirement. These thresholds are critical to mission success. Government surveillance of contractor performance is not limited to the Performance Objectives as outlined in this

PRS. The Government reserves the right to conduct compliance surveillance of any contractual requirement of this acquisition.

Performance Objective

Standard Performance Threshold

Incentive (Positive or Negative)

The contractor shall notify BEP of the test results in accordance with

5.2.2.4 of the

PWS.

The contractor shall perform all testing timely in accordance with

5.2.3.2 of PWS.

Within two (2) working days the contractor shall notify the DER/COR of the collections analyzed.

The contractor will ensure pre-employment testing, random testing, voluntary testing, follow up testing, and re-scheduling is scheduled within twenty-four (24) hours after government notification is received.

The contractor will ensure

100%

Positive or negative assessment in

CPARS.

reasonable suspicion testing and accident, or unsafe practice testing is scheduled within two (2) hours after government notification is received.

Performance Objective

Standard Performance Threshold

Incentive (positive or negative)

The contractor shall use specimen collection sites in accordance with

PWS 5.2.4.

will notify the government of individuals with improper identification or individuals that fail to appear in

The contractor shall only utilize collection sites that are following guidelines in the Department of Health and Human Services Urine/Saliva Specimen Handbook for Drug Free Workplace Programs.

The contractor shall notify the DER within two

(2) hours if a BEP employee or potential employee reports for collection

PWS 5.2.4.3.

will provide a complete Education and Training program for approximately 175 participants annually in

PWS 5.2.1.1.7.1

without proper identification or fails to appear at the scheduled time.

The contractor will notify the DER regarding Training and Education updates affecting the drug testing program.

The DER will determine if these updates or any other information should be included in the training program provided by the contractor.

Deliverable Frequency Number of copies

Medium/Format Submit to

Quality Control Plan as discussed in PWS 1.6.1.1

30 days after BPA award.

PDF/MS

Word/Email Microsoft Word 2003 (or higher) format.

CO/COR

COR/DER

Reports as discussed in

PWS 5.2.8

CCF/eCCF

Monthly Summary reports, if a positive test occurs then the report must be submitted within fourteen (14) days.

Received within 48 hours.

Electronically

PDF/MS

Word/Email Microsoft Word (or higher) format.

Scan (Password protected)

COR/DER

Attachment 2

Customer Complaint Record

Customer Complaint Record _.

Attachment 3

Surveillance Schedule

Surveillance Schedule _.pdf

Attachment 4

Surveillance Checklist(s)

COR Inspection Checklist.pdf

SURVEILLANCE

ACTIVITY CHECKLIST.p

TALLY

CHECKLIST.pdf

Attachment 5

Contract Discrepancy Report

BEP_OA_CDR.pdf