Attachment I - Quality Assurance Surveillance Plan v2.docx

QASP | 36C79122

Department of Veteran Affair Quality Assurance Surveillance Plan For VA Dental Insurance Program

Contractor’s Name:

Contract Number:

1.0

Initial Version

Table of Contents

1. Introduction This Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate performance for the stated contract, ensure the Contractor performs the contract requirements satisfactorily, and that the Government receives the quality of services defined in the contract. The QASP is based on the premise that the Contractor, not the Government, is responsible for managing and ensuring that contract requirements are met and that quality controls are in place and meet the terms of the contract. It is not intended to provide details of how the Contractor accomplishes this work. It is the Government’s responsibility to be objective, fair, and consistent in evaluating performance. In addition, the QASP should recognize that unforeseen and uncontrollable situations may occur.

This QASP is a “living document” and the Government may review and revise it on a regular basis. The Government and Contractor will mutually agree on any revisions. Updates will ensure that the QASP remains a valid, useful, and enforceable document. Copies of the original QASP and revisions will be provided to the contractor and VA officials implementing surveillance activities.

0. Purpose The purpose of the QASP is to describe the systematic methods used to monitor the performance and the identify the required documentation and the resources to be employed. The QASP provides a means for evaluating whether the contractor is meeting the performance standards.

The QASP defines the roles and responsibilities of all members of the integrated project team (IPT), identifies the performance objectives, defines the methodologies used to monitor and evaluate the contractor’s performance, describes the quality assurance documentation requirements and describes the analysis of quality assurance monitoring.

This QASP is based on the premise the Government desires to maintain a quality standard in customer service operations and that a service contract to provide the service is the best means of achieving that objective.

Roles and Responsibilities The following personnel shall oversee and coordinate surveillance activities:

0. Contracting Officer The contracting officer (CO) is responsible for monitoring contract compliance and administration and for resolving any differences between observations documented by the program office contracting officer’s representative (COR) and the contractor. The CO will designate a COR as the government authority for performance management.

The individual(s) with a prescribed authority to enter into, administer, and/or terminate contracts and make related determinations and findings. 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 ensures that appropriate contractual remedies and solutions are applied if the Contractor fails to meet contract requirements. The CO shall also ensure that 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: Bradley Geghan Agency: Department of Veterans Affairs, National Acquisition Center, CSAS

Contracting Officer’s Representative (COR) The COR is designated in writing by the CO to perform specific technical and/or administrative functions and is responsible for technical administration of the contract and shall ensure proper Government surveillance of the contractor’s performance. The COR will 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: Tarsha Tremble Agency: Department of Veterans Affairs, Member Services, Health Eligibility Center

Other Key Government Personnel Contracting Specialist(s), Contracting Officer Representative (COR), and Program Manager (PM) will provide contractual guidance and requirements when needed or appropriate. Any unforeseen or potential conflicts or problems can be addressed with the individuals listed but for any contractual changes, the Contracting Officer is the ONLY authority to make any change to the contract. If applicable, this QASP will be revised to include relevant POC information

Assigned PM: Tarsha Tremble Agency: Department of Veterans Affairs, Member Services, Health Eligibility Center

Contractor Representatives The Contractor has the responsibility for complying fully with the terms and conditions of the contract, participating as a member of the multi-functional team in the post-award management phase, maintaining and implementing a Quality Control Plan that complements the Performance Plan insuring that non-conforming contract services are identified and corrected. The Contractor will perform for the Government services that conform to the contract requirements and recommend changes to the contract that will provide more effective operations. The Contractor will be responsible for the execution of both the contractual and technical aspects of the contract performance.

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

Primary: Tarsha Tremble

Alternate: Ernest Lyons

Contract Requirements The contract requirements applicable to this QASP are listed in Section B.4 Performance Work Statement (PWS); however, the Government is not limited to contract monitoring/surveillance for only those contract requirements included in the QASP. The Contractor is responsible for satisfactory performance of all contract requirements and the Government will modify monitoring methods and requirements as necessary.

The Contractor is responsible for developing, managing, and maintaining a Quality Assurance Plan (QAP) to meet the performance measures and requirements established in the contract. This action is specified in Section B.4. The Government is responsible to conduct adequate contract surveillance and quality assurance to ensure contract requirements are satisfactorily performed and performance measures are met or exceeded.

Performance Measures Performance measures define desired services. The Government performs surveillance to determine if the contractor exceeds, meets, or does not meet these standards.

The Services Summary Matrix incorporated below includes performance measures. The government will use these measures to determine contractor performance and will compare the Contractor’s actual performance to the performance measure.

Incentives Upon satisfactory contract performance the contractor will be eligible for favorable past performance reporting.

Identification of Required Performance Standards/Quality Levels The required performance standards and/or quality levels are included in Appendix Q1, “Performance Requirements Summary.”

0. General Areas to be Monitored during Contract Performance The following PBSC items are identified within the PWS to be applicable on a wide basis and are to be monitored under this QASP.

See the Performance Requirements Summary Appendix Q1:

Quality of Services Provided

· Compliance with Contract Requirements

· Technical Excellence Timeliness of Performance

· Responsiveness to Customer requests

· Reliability Premium Rate Control

· Effectiveness in Forecasting, Managing & Controlling Costs

· Ability to Keep Rates Affordable

· Accuracy, Completeness & Timeliness of Invoicing Business Relations

· Customer-focus

· Management Effectiveness

· Flexibility

· Timeliness of Notification and Mitigation of Problems Regulatory Compliance

· Contract security, HIPPA

· Contract reporting requirements

· Quality assurance surveillance plan

· Industry-related requirements, and safety requirements Unique contract-specific requirements

· Network Insurance Coverage

· Marketing to Veterans

Compliance with terms and conditions

Section II of this QASP provides further technical guidance and lists the specific operational plans as Contractor Associated with this Services contract.

Performance Standards Performance Standards outlined in this QASP shall be used to determine the level of contractor performance in the elements defined. The Performance Work Statement identifies Government objectives and performance standards for each task contracted. The Government will use these standards to assess Contractor performance against these objectives to ensure performance is, at a minimum, satisfactory. The VA surveillance will measure contractor performance in meeting the standards using the following ratings: unsatisfactory, marginal, satisfactory, very good, or exceptional.

The COR will use the performance standards to determine contractor performance rating and will compare contractor performance to the performance threshold of Table A: Performance Standard Measures. The standards, measures and ratings will be used in the assessment process for the Contractor Performance Assessment Report (CPARS). (CPARS Language )

Contract Monitoring It is the intention of both parties to conduct joint reviews prior to the expiration of the contract to determine and evaluate that services are being performed in accordance to contract terms, to include invoicing and payment are being handled in accordance to contract terms. The parties will jointly determine if this agreement is satisfactory to both parties in the terms of services provided and consideration received. This review may include but not limited to:

· Analyze all billings to Veterans (Complaints?)

· Analyze all payments to Veterans for Dental Service (Complaints?)

· Analyze cost administrative issues

· Veteran beneficiary satisfaction

· Quality of Service

· Other documentation related to services received.

Table A: Performance Standard Measures

1. Customer Service

2. Veteran Satisfaction

3. Security Breaches/Privacy/HIPAA

Methods of Quality Assurance (QA) Surveillance The COR and/or designated VA Contractor personnel will perform scheduled and impromptu inspections in accordance with the frequency and standards contained in this QASP to ensure Contractor compliance with the appropriate paragraphs of the PWS and will record the results of inspection, noting the date and time of inspection. If inspection indicates minor discrepancies the COR will notify the Contractor of the discrepancy. If inspection indicates unacceptable performance, the COR will notify the Contracting Officer, who in turn will notify the Contractor of the deficiencies for correction. The Contractor will be given a Contractor reasonable time after notification to correct the unacceptable performance if such correction is possible. The length of time allowed to correct the problem will depend upon the requirement and the deficiency, and the Contractor will be notified of the time allowed for correction when the deficiency is reported to the Contractor. Should the COR and contractor reach an impasse on any matter dealing with inspection and re-performance, the Contracting Officer will be consulted for Contractor resolution.

In addition to specific instructions that may be mentioned, the appropriate and standardized form that is to be used for documentation of QA surveillance is the Surveillance Activity Checklist, Appendix Q5.

0. Customer Feedback Customer feedback may be obtained either from the results of formal customer satisfaction surveys or from random customer complaints. Customer complaints, to be considered valid, must set forth clearly and in writing the detailed nature of the complaint, must be signed, and must be forwarded to the PM.

The PM shall maintain a summary log of all formally received customer complaints as well as a copy of each complaint in a documentation file. The PM shall also keep the tabulated results of all customer satisfaction surveys on file and shall enter the summary results into the Surveillance Activity Checklist.

Verification of Documentation Provided by Contractor This level of inspection shall be accomplished by monitoring and documentation. Each month, the PM, or if Contractor designated the appropriate Technical Monitor, shall review the generated documentation, and enter summary results into the Surveillance Activity Checklist.

Periodic Inspection Periodic inspections shall be conducted if and when specified in individual task orders. For the potential tasks that have been identified Contractor far and included in this QASP, the appropriate Technical Monitor typically performs the periodic inspection on a monthly basis.

Random Monitoring Random monitoring shall be conducted if and when specified in individual task orders. For the potential tasks that have been identified Contractor far and included in this QASP, the random monitoring shall be performed by the PM or by the appropriate designated Technical Monitor.

The Inspection and Acceptance become the basis for any actions that the Contracting Officer may deem appropriate when performance requirements are not being met or the quality is of an unsatisfactory level.

Acceptable Quality Levels The acceptable quality levels (AQLs) included in Appendix Q1, Performance Requirements Summary Table, for contractor performance are structured to allow the contractor to manage how the work is performed while providing negative incentives for performance shortfalls. For certain critical activities such as those involving dental insurance claims processing, the desired performance level is established at 98 percent. Other levels of performance are keyed to the relative importance of the task to the overall mission performance for eligible Veterans and CHAMPA beneficiaries.

Process for Missed Targets Process for justification/explanation of missed targets:

· Contracting Officer will notify the Contractor of failure to meet target/metric/performance standard

· Contractor must submit a written appeal to the CO within 10 days of receipt of notification of failure to meet the standard. The appeal must contain the following:

· An explanation for the failure to meet the standard

· A performance improvement plan (PIP)

· A date for completion of the performance improvement plan, and for regaining satisfactory target goals

· If standards are not met, the Contracting Officer may take appropriate steps to remedy the Contractor’s failure to meet the terms and conditions of the contract.

Quality Assurance Documentation

0. The Performance Management Feedback Loop The performance management feedback loop begins with the communication of expected outcomes. Performance standards are expressed in the PWS and are assessed using the performance monitoring techniques shown in Appendix Q1.

Monitoring Forms The government’s QA surveillance, accomplished by the COR, will be reported using the monitoring forms in Appendixes Q2 and Q3. The forms, when completed, will document the government’s assessment of the contractor’s performance under the contract to ensure that the required results [insert service or quality levels] are being achieved.

The COR will retain a copy of all completed QA surveillance forms in COR File as well as upload to eCORS.

Analysis of Quality Assurance

0. Determining Performance Government shall use the monitoring methods cited to determine whether the performance standards/service levels/AQLs have been met. If the contractor has not met the minimum requirements, it may be asked to develop a corrective action plan to show how and by what date it intends to bring performance up to the required levels. [insert when appropriate: Failure to meet the AQL may result in a deduction from the monthly payment, using the deduction percentages shown in Appendix Q1. Likewise, if the contractor exceeds the performance standards, an incentive will be implemented, in accordance with the incentive marketing plan included in the contract.]

Performance Documentation The COR will, in addition to providing documentation to the Contracting Officer, maintain a complete Quality Assurance file. The file will contain copies of all reports, evaluations, recommendations, and any actions related to the Government’s performance of the quality assurance function, including the originals of all Surveillance Activity Checklists. All such records will be retained for the life of this contract. The COR shall forward these records to the Contracting Officer at termination or completion of the contract.

· Contractor performance on this contract will be documented in the manner described below:

· Acceptable performance. The Government will document performance that meets or exceeds minimum expectations. A Performance Report will be used for this documentation effort and is to be used whenever the COR performs monitoring/surveillance (i.e. inspections, complaints, etc.) on the contract. A template for this Report can be found at Appendix Q2. All Performance Report documentation will be placed in the COR file. It is important to note that these Performance Reports can become part of supporting documentation for appropriate actions taken under this contract.

· Unacceptable performance. When unacceptable performance is observed, in addition to completing a Performance Report, the COR will complete a Contract Discrepancy Report (CDR). An example of this form can be found at Appendix Q3. This form serves as the official written notification to the CONTRACTOR of an observed contract discrepancy. (Note: Only under unique circumstances will verbal communication be used to initially inform the CONTRACTOR of a potential contract discrepancy. However, in those cases, the COR will follow-up with written notification of the finding as Contractor on as possible, coordinate it through the CO, and provide to the CONTRACTOR.) As part of the CDR process:

· The CONTRACTOR shall acknowledge receipt of the CDR in writing.

· The CONTRACTOR will prepare a corrective action plan to document how the CONTRACTOR shall correct the unacceptable performance and avoid recurrence.

· The CDR will clearly indicate a due date by which the CONTRACTOR has to present this corrective action plan to the COR.

The Government will review the CONTRACTOR’s corrective action plan to determine acceptability:

· Summary of Methodology & Purpose for Performance Documentation. The reports & forms referenced in this QASP are designed to collectively serve as a traceable documented history of CONTRACTOR performance. These will align Contractor support recordkeeping requirements mandated by the VA Contracting Officer’s Representative Training (CORT) tool, as well as annual performance assessments mandated by CPARS. Specifically:

· Performance Report (Appendix Q2) -- Used by the COR whenever performing contract monitoring/surveillance on the UP contract. Both negative and positive aspects of the CONTRACTOR’s performance are documented. The information recorded in Performance Reports can serve as a significant Contractor source of documented CONTRACTOR performance. This information can subsequently be used in developing the COR Monthly Report to the Contracting Officer.

Reporting At the end of each month, the COR will prepare a written report for the CO summarizing the overall results of the quality assurance surveillance of the contractor’s performance. This written report, which includes the contractor’s submitted monthly report and the completed quality assurance monitoring forms (Appendix Q2), will become part of the QA documentation. It will enable the government to demonstrate whether the contractor is meeting the stated objectives and/or performance standards, including technical/scheduling objectives.

Reviews and Resolution The CO may require the contractor’s project manager, or a designated alternate, to meet with the COR, CO and other government IPT personnel as deemed necessary to discuss performance evaluation. The CO will define a frequency of in-depth reviews with the contractor, including appropriate self-assessments by the contractor; however, if the need arises, the contractor will meet with the COR and CO as often as required or per the contractor’s request.

· The agenda of the reviews may include:

· Monthly performance assessment data and trend analysis

· Issues and concerns of both parties

· Projected outlook for upcoming months and progress against expected trends, including a corrective action plan analysis

· Recommendations for improved efficiency and/or effectiveness

· [insert if appropriate: Issues arising from the performance monitoring processes]

The QAR shall coordinate and communicate with the contractor to resolve issues and concerns regarding marginal or unacceptable performance.

The COR and contractor should jointly formulate tactical and long-term courses of action. Decisions regarding changes to metrics, thresholds, or service levels should be clearly documented. Changes to service levels, procedures, and metrics will be incorporated as a contract modification at the convenience of the PCO/ACO.

CPARS Annual Assessment The Contractor will be annually assessed and rated for their performance and operation of the utility system listed per the contract. Metrics and methods are designed to determine rating for a given standard and acceptable quality level. The Contractor Performance Assessment Reporting System (CPARS) will be utilized to perform this assessment:

i. CPARS training can be accessed at: https://www.cpars.gov/ (Use “Assessing Official Representative” role) (Approx. 2 hrs. to complete)

ii. The COR will establish an account in CPARS in order to officially contribute to the Government’s annual assessment of the Contractor’s performance. The COR’s input will carry significant weight in the development of the Government’s overall annual rating of the Contractor’s performance under this contract.

iii. The COR will assign a rating to the Contractor’s performance under the contract using the following table:

· Few minor problems resulted from the performance; any corrective actions taken were highly effective.

· Contractor me minor problems resulted from the performance; any corrective actions taken were effective.

· Contractor some minor problems resulted from the performance; corrective actions taken were satisfactory.

· Serious problems resulted from the performance, but recovery was still possible; corrective actions taken were either marginally effective or not fully implemented.

· Serious problems resulted from the performance, and recovery was not considered likely; corrective actions taken were ineffective.

iv. The COR’s assessment and recommended rating will be reviewed by the Contract Specialist /Contracting Officer to ensure sufficient justification. Upon completion of the Government’s annual assessment and rating of the Contractor’s performance, the assessment and rating will be officially recorded in the Contractor Performance Assessment Reporting System (CPARS). Information in CPARS will serve as a valuable Government Contractor source of CONTRACTOR past performance information for future Contractor solicitations upon which the Contractor may offer.

a. CPARS training can be accessed at: CPARS Learning Center

b. Contractor shall assign point of contact for CPARs reviews

QASP ANNUAL ASSESSMENT

To provide for changing quality assurance and quality performance conditions, due to changes in regulatory requirements and/or VA and contractor capabilities, the components of QASP measurement and reporting will be reviewed at least annually or more frequently if required by changes in regulatory requirements.

SUMMARY

The QASP serves as an important guiding document, providing the framework for government monitoring, surveillance, and coordination of the Contractor’s activities and responsibilities under this VADIP Services contract. The typical long-life of this contract, its many moving parts, and the fact that the Contractor insurance, requires a close, long-term partnership between the government and the Contractor. The deliberate and methodical approach to the development and maintenance of this QASP will help ensure this partnership continues to be nurtured, resulting in long-term quality utility service to Department of Veteran Affairs.

LIST OF APPENDIX

Appendix Q1 – Performance Requirements Summary Appendix Q2 – Quality Assurance Monitoring Form Appendix Q3 – Customer Complaint Investigation Appendix Q4 - Submittals Table Checklist Appendix Q5- Surveillance Activity Checklist Appendix Q6 – COR/PM Quarterly Report Instructions Appendix Q7 - QASP PERIODIC MAINTENANCE, REVIEW AND ACCEPTANCE

Appendix Q1: PERFORMANCE REUIREMENT SUMMARY

APPENDIX Q2: Quality Assurance Monitoring Form

Contractor:

Contract Number:

Period of Time:

SURVEILLANCE METHOD (Check):

LEVEL OF SURVEILLANCE (Check):

ANALYSIS OF RESULTS:

Contractor’s Performance (Check):

Narrative of Performance During Survey Period: ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Prepared By: ______________________________________________________________________ (Name, Title, Date)

APPENDIX Q3: QUALITY ASSURANCE MONITORING FORM – CUSTOMER COMPLAINT INVESTIGATION

CONTRACTOR: _______________________________________________________

BPA/TASK ORDER NUMBER: __________________________________________

DATE/TIME COMPLAINT RECEIVED: _____________ ________ AM / PM

SOURCE OF COMPLAINT: _______________________________ (NAME) _______________________________ (ORGANIZATION)

_______________________________ (PHONE NUMBER)

_______________________________ (EMAIL ADDRESS)

NATURE OF COMPLAINT: __________________________________________________________________________________________________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________________________________________________________________________________________________

RESULTS OF COMPLAINT INVESTIGATION: ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ ______________________________________________________________________

DATE/TIME SERVICE PROVIDER INFORMED OF COMPLAINT: ___________________ AM / PM

CORRECTIVE ACTION TAKEN BY SERVICE PROVIDER: ____________________________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________________________________________________________________________________________________ ______________________________________________________________________

RECEIVED AND VALIDATED BY: __________________________________________________

PREPARED BY: ___________________________________ DATE: ________

APPENDIX Q4: Submittals Table Checklist Contract Number: ___________________________________________________ POC/Phone/Email: __________________________________________________

Example references below are Contractorme of the “common” submittals that are seen (but not all inclusive).

NOTE: A CORs “actual service/submittal” are very specific per their contract Contractor adding or deleting Contractorme of the listed below “EXAMPLE” submittals may be required to match contract requirements.

Quality Control Plan

Safety & Accident Prevention Plan

Infection Control Plan

Customer Relationship Management Plan

APPENDIX Q5: Surveillance Activity Checklist

Contract Number: ___________________________________________________ POC/Phone/Email: __________________________________________________

Standard Method of Measurement Performance Metrics Method of Surveillance Date Accomplished Compliance (Exceeded, Met or Partially Met)

APPENDIX Q6: PM/COR Monthly Report to Contracting Officer

The PM or COR shall complete a Monthly Report depending on the phase of the contract to the Contracting Officer (shown below) to document both negative and positive aspects of the Contractor’s performance for the contract. The report shall be submitted to the Contracting Officer in accordance with a mutually established submittal schedule.

The report shall minimally include the following information:

1. Contract Number

2. Contract Period of Performance

3. Contractor Name:

4. Method of Surveillance (ex: Assessment of Contractor, Review of Invoice/Payments by Veterans, and Customer Surveys):

5. Compliance: This document is in accordance with the Inspection of Services and the Quality Assurance Surveillance Plan Requirements.

6. Overall Assessment: Complete items 6a to 6f below by providing a detailed explanation in Item 7. Attach additional documentation for support evidence.

a. Quality of Work (Exceptional, Very Good, Satisfactory, Marginal, Unsatisfactory)

b. Inspection Reports provided by the contractor this month (list here):

c. Was contract performance timely?

d. Are there any significant issues identified and should be brought to Contracting Officer’s attention?

e. Are actions being taken by the Contractor to correct discrepancies?

f. Customer Complaints?

i. # of Complaints

ii. # of Valid Customer Complaints

7. Additional Comments

8. Sign and Date the report.

APPENDIX Q7: QASP PERIODIC MAINTENANCE, REVIEW AND ACCEPTANCE

(NOTE: This Appendix serves as a recommended form to use in formally documenting the review, and acceptance, of the contents of the latest QASP version for the UP contract…Do not include this note as part of the QASP document.)

The functional team members’ signatures below indicate their review and acceptance of the Quality Assurance & Surveillance Plan, dated _________, for (insert type utility system) services provided at (insert installation name) under contract (insert contract number). These signatures indicate coordination on this Government QASP at the time of (insert “development” or “revision”) and will remain in effect until the Plan is modified.

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