Attachment J.2 - QASP Template.docx

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

TEMPLATE

Issued: November 11, 2016

TABLE OF CONTENTS

APPENDIX 2: SAMPLE QUALITY ASSURANCE MONITORING FORM ………………………………………………………..10

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

INTRODUCTION

This quality assurance surveillance plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS) entitled [insert name of services]. This plan sets forth the procedures and guidelines [insert name of government monitoring/surveillance activity] will use in ensuring the required performance standards or services levels are achieved by the contractor.

Purpose The purpose of the QASP is to describe the systematic methods used to monitor performance and to 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/quality levels identified in the PWS and the contractor’s quality control plan (QCP), and to ensure that the government pays only for the level of services received.

This 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 quality assurance documentation requirements, and describes the analysis of quality assurance monitoring results.

Performance Management Approach The PWS structures the acquisition around “what” service or quality level is required, as opposed to “how” the contractor should perform the work (i.e., results, not compliance). This QASP will define the performance management approach taken by [insert name of program office/monitoring activity] to monitor and manage the contractor’s performance to ensure the expected outcomes or performance objectives communicated in the PWS are achieved. Performance management rests on developing a capability to review and analyze information generated through performance assessment. The ability to make decisions based on the analysis of performance data is the cornerstone of performance management; this analysis yields information that indicates whether expected outcomes for the project are being achieved by the contractor.

Performance management represents a significant shift from the more traditional quality assurance (QA) concepts in several ways. Performance management focuses on assessing whether outcomes are being achieved and to what extent. This approach migrates away from scrutiny of compliance with the processes and practices used to achieve the outcome. A performance-based approach enables the contractor to play a large role in how the work is performed, as long as the proposed processes are within the stated constraints. The only exceptions to process reviews are those required by law (federal, state, and local) and compelling business situations, such as safety and health. A “results” focus provides the contractor flexibility to continuously improve and innovate over the course of the contract as long as the critical outcomes expected are being achieved and/or the desired performance levels are being met.

Performance Management Strategy The contractor is responsible for the quality of all work performed. The contractor measures that quality through the contractor’s own quality control (QC) program. QC is work output, not workers, and therefore includes all work performed under this contract regardless of whether the work is performed by contractor employees or by subcontractors. The contractor’s QCP will set forth the staffing and procedures for self-inspecting the quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the PWS. The contractor will develop and implement a performance management system with processes to assess and report its performance to the designated government representative. The contractor’s QCP will set forth the staffing and procedures for self-inspecting the quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the PWS. This QASP enables the government to take advantage of the contractor’s QC program.

1.3.2 The government representative(s) will monitor performance and review performance reports furnished by the contractor to determine how the contractor is performing against communicated performance objectives. The government will make determination regarding incentives based on performance measurement metric data and notify the contractor of those decisions. The contractor will be responsible for making required changes in processes and practices to ensure performance is managed effectively.

ROLES AND RESPONSIBILITIES

The Contracting Officer The contracting officer (CO) is responsible for monitoring contract compliance, contract administration, and cost control and for resolving any differences between the observations documented by the [insert title of government authority for performance management: "contracting officer's representative (COR)," "contracting officer's technical representative (COTR)," "administrative contracting officer (ACO)," "quality assurance representative (QAR),” or "program manager (PM)"] and the contractor. The CO will designate one full-time [insert COR, COTR] as the government authority for performance management. The number of additional representatives serving as technical inspectors depends on the complexity of the services measured, as well as the contractor’s performance, and must be identified and designated by the CO.

The Contracting Officer’s Technical Representative The contracting officer’s technical representative (COTR) is designated in writing by the CO to act as his or her authorized representative to assist in administering a contract. COTR limitations are contained in the written appointment letter. The COTR is responsible for technical administration of the project and ensures proper government surveillance of the contractor’s performance. The COTR is not empowered to make any contractual commitments or to authorize any contractual changes on the government’s behalf. Any changes that the contractor deems may affect contract price, terms, or conditions shall be referred to the CO for action. The COTR will have the responsibility for completing QA monitoring forms used to document the inspection and evaluation of the contractor’s work performance. Government surveillance may occur under the inspection of services clause for any service relating to the contract.

IDENTIFICATION OF REQUIRED PERFORMANCE STANDARDS/QUALITY LEVELS

The required performance standards and/or quality levels are included in the PWS and in Attachment 1, “Performance Requirements Summary.” [Adjust the following sentences to reflect the instant acquisition.] If the contractor meets the required service or performance level, it will be paid the monthly amount agreed on in the contract. If the contractor exceeds the service or performance level, it is eligible to receive an incentive or award fee as stated in the contract. Failure to meet the required service or performance level will result in a deduction from the monthly amount.

METHODOLOGIES TO MONITOR PERFORMANCE

Surveillance Techniques In an effort to minimize the performance management burden, simplified surveillance methods shall be used by the government to evaluate contractor performance when appropriate. The primary methods of surveillance are (include those that apply)

· Random monitoring, which shall be performed by the COTR/COR designated inspector.

· 100% Inspection – Each month or quarter, the COTR/COR, shall review the generated documentation and enter summary results into the Surveillance Activity Checklist.

· Periodic Inspection – COTR/COR typically performs the periodic inspection on a monthly or quarterly basis.

Customer Feedback The contractor is expected to establish and maintain professional communication between its employees and customers. The primary objective of this communication is customer satisfaction. Customer satisfaction is the most significant external indicator of the success and effectiveness of all services provided and can be measured through customer complaints.

Performance management drives the contractor to be customer focused through initially and internally addressing customer complaints and investigating the issues and/or problems but the customer always has the option to communicate complaints to the [insert CO, COR, COTR], as opposed to the contractor.

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 COTR/COR. The COTR/COR will accept those customer complaints and investigate using the Quality Assurance Monitoring Form – Customer Complaint Investigation, identified in Attachment 3.

Customer feedback may also be obtained either from the results of formal customer satisfaction surveys or from random customer complaints.

Acceptable Quality Levels The acceptable quality levels (AQLs) included in Attachment 1, 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 [insert names of any critical services], the desired performance level is established at 100 percent. Other levels of performance are keyed to the relative importance of the task to the overall mission performance at [insert name of government activity receiving services].

QUALITY ASSURANCE DOCUMENTATION

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 Attachment 1.

Monitoring Forms The government’s QA surveillance, accomplished by the [insert COR, COTR, ACO, QA, or PM], will be reported using the monitoring forms in Attachments 2 and 3. 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 [insert COR, COTR, ACO, QAR, or PM] will retain a copy of all completed QA surveillance forms.

ANALYSIS OF QUALITY ASSURANCE ASSESSMENT

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 Attachment 1. Likewise, if the contractor exceeds the performance standards, an incentive or award fee will be paid, in accordance with the incentive fee or award fee plan included in the contract.]

Reporting At the end of each month, the [insert title of person who will prepare the report – COR, COTR, ACO, QAR, or PM] will prepare a written report for the [insert title of government representative responsible for overall monitoring of performance – COR, COTR, ACO, QAR, or PM] 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 (Attachment 2), 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 cost/technical/scheduling objectives.

Reviews and Resolution

The [insert title of government representative responsible for overall monitoring of performance – COR, COTR, ACO, QAR, or PM] may require the contractor’s project manager, or a designated alternate, to meet with the [insert CO, ACO, COR, COTR, QAS, or PM] and other government IPT personnel as deemed necessary to discuss performance evaluation. The [insert CO, ACO, COR, COTR, QAR, or PM] 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 [insert COR, COTR, ACO, QAR, or PM] as often as required or per the contractor’s request. The agenda of the reviews may include:

· Monthly/Quarterly performance assessment data and trend analysis

· Issues and concerns of both parties

· Projected outlook for upcoming months/quarters 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 must coordinate and communicate with the contractor to resolve issues and concerns regarding marginal or unacceptable performance.

The [insert COR, COTR, ACO, QAR, or PM] 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.

APPENDIX 1. EXAMPLE PERFORMANCE REQUIREMENTS SUMMARY

Timely submission and quality of deliverables: submit high-quality products within the provided timeframe

Timely reporting of budget spent and projection that is consistent with invoices submitted for cost reimbursement.

Routine review correspondence and deliverables records.

Thorough review of budget reports and invoice, with supporting documents (including staffing list, quarterly and monthly).

Two (2) late responses or rejection of invoices during a six (6)-month period will lower the contractor performance rating. Three (3) late submissions per six (6) months will require a corrective action plan.

Billed pharmacy products align with allowable and member-specific benefits Prior authorizations for pharmacy products are appropriately justified and recorded for audit.

Staffing plan is cost-effective in terms of staffing mix and assigned tasks

Review of the Operations Manual for the pharmacy management section.

Random records review to verify administrative record of member eligibility for specific pharmacy benefits

Thorough review of contract deliverables and reports supporting invoicing:

· PBM section of the Operations Manual (initial and annual updates)

· Monthly and semi-annual reports supporting the infrastructure cost for PBM.

Absence of an appropriate pharmacy management section in the Operation Manual requires an immediate corrective action plan.

Absence of records indicating appropriate member-specific pharmacy utilization review and approval requires immediate correction and ongoing process quality auditing.

Trend of invoicing for PBM services that are not sufficiently supported will result in a corrective action plan

Internal quality assurance audit approaches align with an approved and current Quality Assurance Plan (QAP) are aligned with Program’s guidance and Administrative Manual.

The findings from Technical Guidance for Quality Assurance and Internal Audits and Summary of Services and Requirements Selected for Inspection shall be reported semi-annually within 45 days from the end of the reporting period.

Random monitoring/ periodic inspection as agreed upon between the contractor and WTC Health Program.

Thorough review of contract deliverables and semi-annual report Absence of the QAP requires an immediate corrective action plan.

One (1) late submission per six (6)- month reporting period will require an immediate corrective action plan.

Review of training records; training requirement stated in Operations Manual.

One (1) late submission of HIPAA breach notification or one (1) missing record of annual required staff training during the performance period will require a corrective action plan.

Member’s Valid Complaints about Care, Services or Staff

*“Valid” means that WTC Health Program has sought input from the contractor and confirmed that the complaint is real and has merit.

100% inspection based on information maintained by WTC Health Program

Three (3) valid complaints per six (6) months will lower the contractor performance rating. Six (6) valid complaints per six (6) months will require a corrective action plan.

· Current (within 4 months) Plan of Care is on file for each member receiving ICM services

· Staffing plan is cost-effective in terms of staffing mix and assigned tasks

Random records review for member-specific Plan of Care for members receiving ICM services

Thorough review of contract deliverables and reports supporting invoicing:

· ICM Operations Plan (initial and annual updates)

· Monthly and semi-annual reports supporting the infrastructure cost for ICM

Absence of the ICM Operations Plan requires an immediate corrective action plan.

Absence of a Plan of Care for a member receiving ICM services requires correction and assurance of appropriate internal process QA.

Trend of invoicing for ICM services that are not sufficiently supported will result in a corrective action plan

The CCE shall maintain a current list of providers and no more than one (1) provider shall not be on the list; the CCE shall notify the HPS Contractor of any changes to the list within one (1) month.

Random monitoring/ periodic inspection as agreed upon between contractor and WTC Health Program

Credentialing and training records

Denied claims records due to providers not enrolled.

Any failure to meet the QA check is immediately rectified by the CCE. Two (2) consecutive months of failing to meet the QA measure will result in a corrective action plan (for care coordination) and/or lower performance rating.

(2) of the performance thresholds are not met in a month, a corrective action plan is required.

between the contractor and WTC Health Program If any of the three (3) performance thresholds are not met for two (2) consecutive months, it will result in a lower performance rating. If two (2) of the performance thresholds are not met in a month, a corrective action plan is required.

Random monitoring/ periodic inspection as agreed upon between the contractor and WTC Health Program Any claims not reviewed each month will result in re-performance of the review. If at least three (3) claims do not meet the performance threshold for two (2) consecutive months, it will result in a lower performance rating. If at least six (6) claims do not meet the performance threshold for two (2) consecutive months, a corrective action plan is required.

APPENDIX 2: SAMPLE QUALITY ASSURANCE MONITORING FORM

SERVICE and STANDARD:

SURVEY PERIOD:

SURVEILLANCE METHOD (Check):

Random Sampling 100% Inspection Periodic Inspection Contract Discrepancy Report (CDR).

LEVEL OF SURVEILLANCE (Check):

Monthly Quarterly As needed

PERCENTAGE OF ITEMS SAMPLED DURING SURVEY PERIOD: %

ANALYSIS OF RESULTS:

Narrative of Performance During Survey Period:

PREPARED BY: DATE: