Attachment 7 - Draft QASP.docx

Attachment 7 Draft QASP

TABLE OF CONTENTS

Subject Page Number

1. Overview 3

2. Description of Services 3

3. Roles and Responsibilities 3

4. Contract Quality Requirements 4

5. Government Surveillance 5

6. Nonconformance Reports (NCRs) 5

7. Deduct Plan 6

8. Data Analysis 6

9. Acceptance of Services 6

10. COR Status Report 7

11. Contractor Manpower Reporting Application (CMRA) 7

12. Contractor Performance Assessment Reporting System (CPARS) 7

Attachments

Performance Requirements Summary (PRS) 8 Nonconformance Report Worksheet 11

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 and subsequent task orders 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.

2. Description of Services.

2.1. Scope of Work. This contract is issued to provide qualified personal and non-personal medical services to supplement the medical staff in support of the Military Treatment Facilities (MTFs) within the US Army Medical Command (MEDCOM), Regional Health Command Europe (RHCE), US Army Europe and Africa (USAREURAF), Central Command (CENTCOM) and Africa Command (AFRICOM) area of responsibility (AOR) and for other Department of Defense (DoD) agencies including US Air Forces in Europe and eligible beneficiaries spanning three Combatant Command AORs in Europe, Africa, and the Middle East having similar requirements, including but not limited to Defense Health Agency (DHA). The Contractor shall provide qualified Health Care Workers (HCW) at MTFs and outlying areas in accordance with (IAW) the terms and conditions of this contract, to include any terms and conditions defined in task orders (TOs) issued under this contract. This contract shall serve as a strategic sourcing vehicle to provide all Full-Time Equivalent (FTE)-based HCWs, with Product Service Codes (PSCs) within Q200 through Q500, Q700, Q800, and Q900 series, at DoD MTF’s identified in paragraph 1.1. The latest PSC Manual can be found at https://www.acquisition.gov/psc-manual.The HCWs shall supplement the MTF’s clinical staff (e.g., military personnel, DoD civilian employees or other contracted staff) in accomplishing its mission of providing direct health care services to eligible beneficiaries. Direct health care services may take the form of but not limited to treatment, movement of patients, advice, clinical evaluations, recommendations, area and equipment preparation, and other medical services.

2.2. Type of Contract. This is a follow-on contract to the Regional Health Contracting Office- Europe (RHCO-E) ADCMS GEN III, Single Award Task Order Contract (SATOC), Indefinite Delivery, Indefinite Quantity, (IDIQ) contract W9114F18D0006 with Sterling Medical Associates, Inc. which expires 14 May 2023. The resultant contract type will be a commercial SATOC IDIQ contract. The planned ordering Period of Performance is 01 October 2022 – 30 September 2027, plus FAR Clause, 52.217-8 Option to Extend Services.

3. Roles and Responsibilities.

3.1. Government.

3.1.1. Contracting Officer (KO). The KO 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. Contracting Officer’s Representative (COR). The (COR) will be identified by separate letter. The COR monitors all technical aspects of the contract and task orders 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 and task order 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 at both the contract and task order level, a copy of which is sent to the Contractor, 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.

3.1.3. Contract Administrator. N/A

3.1.4. Property Administrator. N/A

3.1.5. Ordering Authority. Appointed by the Contracting Officer.

3.2. Contractor.

3.2.1. Contract Manager. TBD at time of award. Contract manager having direct oversight and legal binding authority between the contractor and the Government.

3.2.2. Project Manager. TBD at time of award. Serves as the key point of contact on behalf of the contractor with the Government overseeing the daily operations of the contractor.

3.2.3. Quality Manager. The contractor, and not the Government, is responsible for management and quality control actions to meet the terms of the contract. The role of the Government is quality assurance to ensure contract standards are achieved.

POC TBD at time of award.

4. Contract Quality Requirements.

4.1. Contractor’s Quality Control Program. The Contractor’s quality control program (IAW FAR Part 46 and applicable 52.246 Clause(s)) is the means by which the Contractor assures that work complies with the requirement of the contract. The Contractor shall ensure services are performed in accordance with this PWS. The Contractor shall identify, prevent, and ensure non-recurrence of defective services. The Contractor shall submit a complete Quality Control Plan (QCP) to the Procuring Contracting Officer (PKO) within 15 calendar days of contract award

4.2. Government Quality Assurance. The Government shall evaluate the Contractor’s performance under this contract in accordance with this QASP. This plan is primarily focused on what the Government must do to ensure that the Contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance and minimum acceptable defect rate(s).

5. Government Surveillance.

5.1. Methods of Surveillance. The following Methods of Surveillance will be utilized in monitoring the Contractors’ performance: They can occur quarterly, monthly, or as needed:

5.1.1. 100% Inspection The COR may conduct 100% inspections of the work defined in the performance work statement (PWS). The COR will also review information submitted in the required reports defined in the PWS (if applicable).

5.1.2. Random Sampling

5.1.3. Periodic Inspection The government may conduct periodic inspections monthly, quarterly, or on an as-needed basis. The periodic inspection shall be conducted by the COR

5.1.4. Customer Feedback. The following procedures will be followed when a complaint is received regarding the Contractor/Contractor Employees.

· 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 for each month of Contractor performance and filed in the Procurement Integrated Enterprise Environment (PIEE), Surveillance and Performance Monitoring (SPM), Surveillance Documents Section of the Contract File using the Add Smart Form function. The schedule is “FOR OFFICIAL USE ONLY” and is not releasable to anyone other than authorized Government personnel.

5.3. Surveillance Instructions/Checklists. Surveillance Checklists will be completed when surveillances are conducted and filed in the PIEE, SPM, Surveillance Documents Section of the Contract File using the Add Smart Form function

5.4. Surveillance Documentation. No later than the 15th of each month surveillance documentation for the preceding month will be filed in the PIEE, SPM, Surveillance Documents Section. Surveillance documentation includes a COR Status Report, the Surveillance Schedule, all completed Surveillance Checklist(s) for the period the COR Status Report covers, Nonconformance Reports, if any, and Contractor Deliverables, if any.

6. Nonconformance Reports (NCRs). Nonconformance occurs when a Contractor fails to meet Contract or Task Order terms, conditions and/or specifications or the services are defective in some manner. All instances of nonconformance will be documented via a Nonconfomance Report Worksheet, Attachment 2 and the Contracting Officer will notify the Contractor of the nonconforming performance via Letter. Nonconformance is classified as either: Level 1 (Minor); Level 2 (Major); or Level 3 (Critical). NCRs may contain multiple nonconformances, each characterized by a level and type. The level of the NCR should normally correspond to the highest level of nonconformance listed in the NCR. For example, if a NCR had one Level 3, one Level 2, and three Level 1 nonconformance’s, the NCR level would be Level 3. The exception might be when the aggregate of multiple nonconformance’s considered in whole associate to a more serious type of nonconformance defined in FAR 46.101 (e.g. if a NCR had three Level 2 nonconformance’s but the definition of critical nonconformance better describes the impact/effect when considered in whole, the NCR level would be 3).

6.1. Level 1 (Minor). Level 1 nonconformance’s are those that are ‘minor’ in nature such that they can be promptly corrected by the contractor, present no need for root cause analysis or determination if other contract requirements are affected, present no need for further preventive action, and do not materially reduce the usability of the supplies, services, construction, or deliverables. While the contractor must correct the nonconformance, further actions and Government follow-up are not required, and no written response from the contractor is needed.

6.2. Level 2 (Major). Level 2 nonconformance(s) are those that are ‘major’ in nature such that they are not promptly correctable, and/or warrant root cause analysis and preventive action, and/or need action by the contractor to determine if other contract requirements are affected. These nonconformance’s are serious enough to warrant not only correction of the nonconformance, but also a written response from the contractor in the form of a Corrective Action Plan (CAP), and Government follow-up. The qualifying distinction between a Level 1 and Level 2 nonconformance is the need for a CAP and Government follow-up. A NCR identifying a Level 2 nonconformance may also be issued after repetitive Level 1 instances of the same or similar nonconformance demonstrate the contractor is failing to institute effective corrective action and/or failing to implement effective quality and/or internal control(s). Repetitive Level 1/minor nonconformance of the same or similar requirement(s) increases the risk to the Government that continued, repetitious, or cumulative failures may materially reduce the usability of the, services or deliverables for their intended purpose or is an indicator that root cause analysis and a CAP is required to fix the underlying conditions creating the nonconformance. Further, serious individual contractor employee misconduct discovered by the Government and traceable to contract requirements should normally result in a Level 2 nonconformance because the serious nature of misconduct necessitates contractor management conduct root cause analysis, take preventive actions, and requires Government follow-up (characteristics of a Level 2 NCR). Further, issue a NCR with a Level 3 nonconformance for serious contractor employee misconduct only when there is a trend demonstrating a breakdown in contractor management or processes allowing serious misconduct to repetitively occur, or the misconduct poses a hazardous or unsafe condition for the personnel receiving the contracted service, and misconduct can be traced to nonconformance of contract requirements.

6.3. Level 3 (Critical). Level 3 nonconformance(s) are those that are ‘critical’ in nature such that they represent a serious weakness in internal controls and/or have actual or potential significant impact(s) on contract performance and/or the supported unit/Government operations. For these nonconformance(s), the qualifying distinction between a Level 2 and Level 3 nonconformance is the seriousness of the issue prompting the need for higher level management to address the nonconformance and resulting corrective action. Due to the nature of a Level 3 nonconformance, these types of nonconformance are candidates for contract remedies. Therefore, before issuance of a NCR with a Level 3 nonconformance, consideration should be made whether an NCR or contract remedy is more appropriate. Issuing a Level 3 NCR in lieu of a contract remedy would normally be considered the Government’s final attempt to work with the contractor to resolve a contractual nonconformance before contractual remedies are used. However, issuance of a Level 3 NCR is not a requirement before using contractual remedies. A NCR identifying a Level 3 nonconformance (or a contract remedy) may be issued after repetitive Level 2 instances of the same or similar nonconformance demonstrate the contractor is failing to institute effective corrective action or failing to implement effective quality/internal controls. Repetitive major nonconformance’s with the same or similar requirement(s) increase the risk to the Government that continued, repetitious, or cumulative failures may significantly impact the mission, or may result in hazardous/unsafe conditions.

6.4. Documenting NCRs. Use/fill out the Nonconformance Report Worksheet, Attachment 2, when nonconforming performance is identified. 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; and the Contractor representative who was notified. Also, include a suspense date for Contractor response/corrective action for Level 2 and Level 3 NCRs. The Contracting Officer must ensure appropriate level review and approval of the NCR Worksheet and then addresses the NCR in Letter Format to the applicable level of Contractor management based on the seriousness of the nonconformance.

6.5. Tracking and Resolving NCRs. All NCRs will be included in the COR’s Status Report. The Government considers Level 1 nonconformance closed as of the issuance of the Letter to the Contractor. However, your attention to address Level 1 Minor nonconformance is still required. Repetitive nonconformance of the same or similar requirement would be an indication the contractor failed to institute effective corrective action and/or failed to implement effective quality control and may result in a Level 2 NCR requiring submission of a CAP to the Government. The COR and KO shall track Level 2 and Level 3 NCRs to ensure the Contractor identifies and takes appropriate corrective action to the root cause and the specific nonconformance is corrected within the required timeline. The KO 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. Deduct Plan. This acquisition does not include a Deduct Plan.

8. 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 Nonconformance Report. Trends noted using Contractor data will not result in a Nonconformance Report unless the Contractor is not addressing the negative trend.

9. 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 in PIEE, WAWF.

10. COR Status Report. COR Status Reports will be submitted on a monthly basis, no later than the 15th of each month for the preceding frequency, to the Contracting Officer via PIEE, SPM, Surveillance Documents Section using the Add Smart Form function. Negative findings will be submitted to the Contracting Officer within two hours of noted findings. 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; Nonconformance Reports, if any; an analysis of the Contractors performance; recommended adjustments to surveillance schedules; and any other pertinent contract information.

11. Contractor Manpower Reporting Initiative. As this is a medical service requirement, filing of the CMRA by the contractor is no longer required.

12. Contractor Performance Assessment Reporting System (CPARS). Documented surveillance data (COR Status Reports, Completed Surveillance Checklists, Customer Feedback, Deliverables, if any, and Nonconformance Reports, if any) will be used to support CPARS ratings. CPARS will be completed in accordance with AFARS, Subpart 5142.15 – Contractor Performance Information. The COR shall document that CPARS, if required, was completed in the COR Status Report for the month in which the CPARS was completed.

13. Combating Trafficking In Persons (CTIP). In accordance with PGI 222.17 and FAR 52.222-50, the KO will be notified immediately of any information from any source that alleges a Contractor employee has engaged in conduct that violates the United States Government “zero” tolerance policy regarding trafficking in persons.

14. COR/Quality Assurance Surveillance Files. The official COR/Quality Assurance Surveillance File will be maintained in PIEE, SPM IAW DoDI 5000.72, DoD Standard for COR Certification.

15. 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 KO for approval and the KO must approve all changes.

Other metrics that may be used include, but are not limited to:

Meet Contract Requirements/Expectations Number of Patient Workload processed in a given time Positive Rapport w/Colleagues and Patients Substantiated patient complaints Professional Behavior (Ethics) Quality of Work and Technical Skills/Competency Contractor performs in a timely manner and is responsive; on-boarding Fill-Rate is in compliance

Refer to Performance Requirements Summary – Exhibit 5 PWS – PRS and Attachment 8 Nonconformance Report Worksheet.