Attachment E - QASP.docx

Attachment E – QASP Virtual Pharmacist Service The contractor will be evaluated in accordance with the following:

1. PURPOSE

This Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate performance for 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 with 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 on a regular basis. However, the Government shall coordinate changes with the contractor through contract modification. 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 shall safeguard the interests of the United States in the contractual relationship. The CO shall also assure 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:

Organization or Agency: Department of Veterans Affairs

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

Assigned COR: Nicole Fleeger, Butler VAMC Assigned COR: Mary Brigham, Erie VAMC Assigned COR: Michelle Stokrp, Lebanon VAMC Assigned COR: Kevin Ellis, Coatesville VAMC Assigned COR: Alicia Fitzgerald, Wilmington VAMC Assigned COR: Robert Warnagiris, Wilkes-Barre VAMC

3. CONTRACTOR REPRESENTATIVES

The following employee(s) of the contractor serve as the contractor’s program manager(s) for this contract.

Primary:

Alternate:

4. PERFORMANCE STANDARDS

The contractor is responsible for performance of ALL terms and conditions of the contract. CORs will provide contract progress reports quarterly to the CO reflecting performance on this plan and all other aspects of the resultant contract. The performance standards outlined in this QASP shall be used to determine the level of contractor performance in the elements defined.

Performance standards define desired services. The Government performs surveillance to determine the level of Contractor performance to these standards.

The Performance Requirements are listed below in Section 6. The Government shall use these standards to determine contractor performance and shall compare contractor performance to the standard and assign a rating. At the end of the performance period, these ratings will be used, in part, to establish the past performance of the contractor on the contract.

5. ACCEPTABLILITY OR UNACCEPTABLILITY

The Government shall use past performance as acceptable/unacceptable. Acceptable/unacceptable shall be based on exceeding, meeting, or not meeting performance standards. Contractor will not be unacceptable during the initial three (3) months of this contract.

6. METHODS OF QA SURVEILLANCE

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

a. VALIDATED USER/CUSTOMER COMPLAINTS. Any orders processed by the contractor’s virtual pharmacists not meeting appropriate quality standards, given the information available to the virtual pharmacist at the time of order processing, will be noted as a discrepancy per the table below. The contractor will be given the opportunity to provide a rebuttal to any COR complaints to provide a defense of virtual pharmacist actions. The CO will adjudicate the result based on COR/contractor input do decide of the COR complaint is indeed valid.

Task

Method of Surveillance

(Deducts)

Errors in order processing (i.e., medication errors)

Orders are to meet appropriate quality standards including evaluation of drug-drug interactions, contraindications for recorded drug allergies, appropriate doses, accurate directions, and, as applicable, appropriate order start time to ensure the final order will be active at the appropriate time and understandable to the nurse administering or patient taking the medication.

Individually, at each VAMC, 98% of orders processed for that VAMC will meet appropriate quality standards including evaluation of drug-drug interactions, contraindications for recorded drug allergies, appropriate doses, accurate directions, and, as applicable, appropriate order start time to ensure the final order will be active at the appropriate time and understandable to the nurse administering or patient taking the medication.

VA will monitor via error reports from VA nursing, pharmacy, and/or provider staff that raise concerns regarding the quality of orders processed by the contractor.

Contractor will be provided monthly reports in order to check its own performance Satisfactory or better past performance when evaluating contractor for future contracts and when providing references to other VAMCs

Failure to meet VA performance measures shall result in the following penalties:

VA will notify Contractor using a Contract Discrepancy Report (CDR) when this AQL is not met.

93% - 98%: A disincentive equaling 5% of that month’s invoice when the AQL was not met.

85% - 93%: A disincentive equaling 15% of that month’s invoice when the AQL was not met.

85%and below: A disincentive equaling 33% of that month’s invoice when the AQL was not met, in addition, will be considered as noncompliance

Timely Order Processing

Section: 5.0 Contractor Performance Evidence of contractor pharmacists routinely logging in to each VAMC system during coverage periods

The contractor pharmacists will log into each VAMC’s system at least every 30 minutes to check for new pending orders.

Contractor will be provided monthly reports in order to check its own performance Incentive: satisfactory or better past performance when evaluating Contractor for future contracts and when providing references to other VAMCs

Failure to meet VA performance measures shall result in the following penalties:

VA will notify Contractor using a Contract Discrepancy Report (CDR) when this AQL is not met.

93% - 98%: A disincentive equaling 5% of that month’s invoice when the AQL was not met.

85% - 93%: A disincentive equaling 15% of that month’s invoice when the AQL was not met.

85%and below: A disincentive equaling 33% of that month’s invoice when the AQL was not met, in addition, will be considered as noncompliance

7. 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:

Metrics and methods are designed to determine rating for a given standard and acceptable quality level. The following ratings shall be used:

Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with few minor problems for which corrective actions taken by the contractor were highly effective.

Note: To justify an Exceptional rating, you should identify multiple significant events in each category and state how it was a benefit to the GOVERNMENT. However a singular event could be of such magnitude that it alone constitutes an Exceptional rating. Also there shall have been NO significant weaknesses identified.

Note: To justify a Very Good rating, you should identify a significant event in each category and state how it was a benefit to the GOVERNMENT. Also there shall have been NO significant weaknesses identified.

Note: To justify a Satisfactory rating, there should have been only minor problems, or major problems the contractor recovered from without impact to the contract. Also there shall have been NO significant weaknesses identified.

b. If contractor performance does not meet the Acceptable Quality level, the CO shall inform the contractor. This will normally be in writing unless circumstances necessitate verbal communication. In any case the CO shall document the discussion and place it in the contract file. When the COR and the CO determines formal written communication is required, the COR shall prepare a Contract Discrepancy Report (CDR), and present it to CO. The CO will in turn review and will present to the contractor's program manager for corrective action.

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 CO. The Government shall review the contractor's corrective action plan to determine acceptability. The CO shall also assure that the contractor receives impartial, fair, and equitable treatment. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance and the acceptability of the Contractor’s corrective action plan.

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

9. FREQUENCY OF MEASUREMENT

a. Frequency of Measurement.

The frequency of measurement is defined in the contract or otherwise in this document. The government (COR or CO) will periodically analyze whether the negotiated frequency of surveillance is appropriate for the work being performed.

b. Frequency of Performance Reporting.

The COR shall communicate with the Contractor and will provide written reports to the Contracting Officer quarterly (or as outlined in the contract or COR delegation) to review Contractor performance.

10. COR AND CONTRACTOR ACKNOWLEDGEMENT OF QASP

SIGNED:

COR NAME/TITLE DATE

COR NAME/TITLE DATE

COR NAME/TITLE DATE

COR NAME/TITLE DATE

COR NAME/TITLE DATE

COR NAME/TITLE DATE

CONTRACTOR NAME/TITLE DATE