B02 Attachment 3 QASP.pdf

US Department of Agriculture (USDA)

Quality Assurance Surveillance Plan

Contents Project Name

Solicitation / Contract Number

Section 1: Introduction

1.1 Purpose

1.2 QASP Relation to the Contract

1.2.1 QASP Revisions

1.2.2 Surveillance of Performance Progression

1.3 QASP Relation to the Quality Control Plan (QCP)

Section 2: Performance Description

2.1 Performance Standards and Acceptable Quality Levels (AQLs)

2.1.1 Allowable Deviation

2.1.2 Substantially Complete

2.2 Non-Performance

2.2.1 Documentation

2.2.2 Remedial Actions

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

3.2.2 Contracting Officer Representative (COR)

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods

4.1.1 COR Review of Submittals and Customer Feedback

4.1.1.1 100 Percent Inspection

4.1.1.2 Performance Standards and AQLs

4.1.1.3 Evaluation Procedures

4.2 Analysis and Results

Appendix A: Performance Requirement Summaries

Appendix B: Customer Feedback Record

Appendix C: Surveillance Activity Checklist

Project Name MRL Specialty Crop Quick Reference Sheets

Solicitation / Contract Number 12314424Q0125

Section 1: Introduction This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS) entitled MRL Specialty Crop Quick Reference Sheets. This plan sets forth the procedures and guidelines that the USDA, [Foreign Agricultural Service (FAS) will use in ensuring the required performance standards or services levels are achieved by the contractor.

1.1 Purpose

The purpose of the QASP is to describe the systematic methods used to measure performance and to identify the reports required and the resources to be employed. The QASP provides a means for evaluating whether the contractor is meeting the performance standards identified in the PWS. This QASP is designed to define roles and responsibilities, identify the performance objectives, define the methodologies used to monitor and evaluate the contractor’s performance, describe quality assurance reporting, and describe the analysis of quality assurance monitoring results.

1.2 QASP Relation to the Contract

1.2.1 QASP Revisions

The Contracting Officer Representative (COR) may make revisions or changes to the QASP procedures and surveillance methods or increase or decrease the degree of surveillance methods at any time during the contract performance period. Changes to the Metric must be incorporated into the PWS, Performance Requirement Summary (PRS) and QASP by a bilateral modification to contract that is issued by the Contracting Officer (CO). A copy of the QASP is provided to the contractor to enable the contractor to enhance its Quality Control (QC) program to perform in accordance with its Quality Control Plan (QCP).

1.2.2 Surveillance of Performance Progression

As the performance period progresses, the levels of surveillance may be altered for service areas where performance is either consistently excellent or unsatisfactory. If consistently good performance, then the amount of surveillance may be reduced. If observations reveal consistent deficiencies, increased surveillance may be implemented.

1.3 QASP Relation to the Quality Control Plan (QCP)

The QCP is a required element of contract and the Contractor shall adhere to its established quality control processes and procedures in managing and performing work as described in the contract. While the QCP represents the way in which the Contractor will ensure its quality and timeliness of services, as defined in the PWS, the QASP represents the way in which the Government personnel specified in Section 3: Contractor and Government Responsibilities, Paragraph 3.2, Government Responsibilities will evaluate the contractor’s performance. The contractor’s QC program and the residual organization’s QASP should be complementary programs that ensure successful contractor performance.

Section 2: Performance Description Performance of the contractor will be monitored through the surveillance methods described in Section 4: Surveillance Methods to Perform Quality Assurance to assess the Contractor’s performance against PWS requirements.

2.1 Performance Standards and Acceptable Quality Levels (AQLs) For selected activities in the PWS, the PRS provides a performance standard and an AQL. A performance standard is the expected level of contractor performance. An AQL defines the level of performance that is satisfactory. Depending on the service evaluated and the evaluation method selected, performance standards and AQLs may be stated as a number of occurrences or as a percentage. Performance standards and AQLs for random sampling and 100 percent inspection are generally stated as percentages. For periodic inspections, performance standards may be stated as either percentages or as absolute numbers.

The contract requires the Contractor to perform all work as specified. Any inaccuracies or omissions in services or products are referred to as “defects” on the part of the Contractor. The Contractor shall be responsible for all identified defects and may be required to perform the work at no cost to the government. The AQLs take into account that in some instances an allowable level of deficiencies (deviations) is possible while overall performance continues to meet the government’s desired level of service.

2.1.1 Allowable Deviation

The AQLs define the level or number of performance deficiencies the Contractor is permitted to reach under this contract. AQLs take into account the difference between an occasional defect and a gross number of defects. AQLs can be expressed as a percentage of or as an absolute number (e.g., three per month). There may be instances where 100 percent compliance is required, and no deviation is acceptable (e.g., where safety is involved).

2.1.2 Substantially Complete

In some cases, service outputs are evaluated using subjective values (e.g., excellent, satisfactory, unsatisfactory). The criteria for acceptable performance and for defects must be defined for these service outputs. The concept of “substantially complete” should be the basis for inspections based on subjective scales. Work is considered “substantially complete” where there has been no significant departure from the terms of the contract and no omission of essential work. In addition, the Contractor has performed the work required to the best of its ability and the only variance consists of minor omissions or deficiencies.

2.2 Non-Performance

Non-performance occurs when the contractor’s performance does not meet the AQL for a given requirement.

Requirements may contain multiple performance elements, and therefore, deficiencies may occur in one or more aspects of performance (e.g., timeliness, accuracy, completeness, etc.) or subject areas of effort.

When surveillance indicates that the contractor's service output is not in compliance with the contract requirements, the Contracting Officer’s Representative (COR) must determine whether the Contractor or the Government caused the deficiency. If the cause of the defect rests with the Government, corrective action must be taken through Government channels. If the cause of the defect is due to action or inaction by the contractor, the contractor is responsible for correction of the problem at no additional expense to the Government.

2.2.1 Documentation

Documentation of work non-performed or unacceptable work is essential for tracking Contractor performance. The COR will document deficient work by compiling facts describing the inspection methods and results and to substantiate nonconformance with the contract. A sample documentation reporting form is provided in Appendix C: Surveillance Activity Checklist. The documentation, with any recommendations, will be forwarded to the CO. In the case of the Contractor, the COR will decide whether to elevate the problem to the CO for corrective action.

2.2.2 Remedial Actions

The Federal Acquisition Regulation allows for penalties in the event that the Contractor fails to perform the required services. Penalties are defined as those actions taken under the direction of the CO against the contractor within the general provisions of the contract for nonconformance to the PWS and PRS.

Section 3: Contractor and Government Responsibilities

3.1 Contractor Responsibility

The Contractor is responsible for delivering products or services in accordance with the contract. Implementing its QCP, which describes the Contractor’s methods for ensuring all products and services under the contract meet established performance standards and AQLs. Maintaining, and providing for audit, quality control records and reports and all records associated with the investigation and complaint resolutions. Appointing a single quality control point-of-contact to act as a central recipient of communication from the COR or CO.

3.2 Government Responsibility

3.2.1 Contracting Officer (CO)

The CO is responsible for administering and monitoring contract compliance, contract administration, and cost control and for resolving any differences between the observations documented by COR and the contractor’s performance. The CO may delegate various day-to-day contract administration duties to a Administering ACO (ACO) and/or the COR for performance management and administrative actions such as invoice approval and issuance of Contract Discrepancy Reports may be, and normally are, delegated by the CO to the COR. The CO shall approve any revisions to the QASP processes or standards.

3.2.2 Contracting Officer Representative (COR)

The COR, is designated in writing, by the CO. The COR will ensure that the QA function is properly executed, plays a key role in contract administration and performs the contract surveillance and monitoring. Some key contract administration duties include, but are not limited to, performs surveillance as required by this QASP; make recommendations to the CO for issuance of Contract Discrepancy Reports or letters of commendation and acceptance or rejection of completed work and for administrative actions based on unsatisfactory or non-performed work, and revisions or changes to the QASP;

and assists the CO in identifying necessary contract modifications and preparing reports of Contractor performance and cost.

The COR may use the form(s) included in the Appendices to perform the inspection or other forms as approved by the

CO.

Section 4: Surveillance Methods to Perform Quality Assurance

4.1 Surveillance Methods

The surveillance methods used in the QA process are the Government’s tools to monitor the Contractor’s products and services. The best means of determining whether the Contractor has met all contract requirements is to inspect the Contractor’s service products and analyze the results. Further, documented inspection results are an effective tool in contract administration that can confirm the successful achievement of all performance requirements or highlight areas where defects exist, and improvements are necessary.

4.1.1 COR Review of Submittals and Customer Feedback

Deliverables will be submitted and reviewed following guidelines in the PWS.

4.1.1.1 100 Percent Inspection The 100 percent inspection method requires complete inspection of each deliverable and will be used for critical contract requirements.

4.1.1.2 Performance Standards and AQLs

The performance standards and AQLs may be stated as either percentages or absolute numbers.

4.1.1.3 Evaluation Procedures

Observed defects for a service monitored by 100 percent inspection is compared to the performance standard and AQL.

4.2 Analysis and Results

When the inspections and customer feedback validations have been completed, the COR will perform an analysis of the Contractor’s performance. The purpose of the analysis is to ensure Government is receiving high-quality products and services from the Contractor. The COR will review the results, rate the Contractor’s compliance with the performance standards and AQLs, and characterize the Contractor’s overall performance. Analysis of all types of contract monitoring will result in one of the following outcomes:

Appendix A: Performance Requirement Summaries

PERFORMANCE REQUIREMENT SUMMARY

Performan ce Objective

Required Task or Deliverable

Performance Standard Method of Surveillance Positive/Negative Incentive

% for NOT meeting the Task

3.1 Productio n of MRL Quick Reference Sheets

(QRS)

Production of each QRS for each commodity

At least 50 chemicals included on each sheet (unless fewer than 50 are registered for U.S. use), with correct spelling, trade name, and class of product.

98% of MRLs shown i.e.

(588/600) are correct as of the date shown on each sheet.

FAS will spot-check each sheet as submitted; FAS may reference any of several data sources to do so.

Sheets not meeting specification will be returned for correction; and future submissions may be scrutinized more closely, resulting in longer review times before acceptance.

3.2 The

Maintenan ce of MRL Quick Reference Sheets

Semi-annual review and update of the QRS for each commodity, with revised sheets submitted to

FAS

95% (i.e. 57/60) of accepted sheets have an “as-of” date that is less than seven months from the current date

98% of MRLs shown (i.e.

588/600) are correct as of the date shown on each sheet.

FAS will maintain a roster of when each sheet was last updated

FAS will spot-check each sheet as submitted; FAS may reference any of several data sources to do so.

If the standard is not met for more than 15 cumulative days in any 12-month period, payment for the maintenance portion may be withheld until all sheets are current

3.3 Productio n of MRL Quick Reference Sheets User Guide

A “user guide” to explain how to read and understand the QRS documents, will be made available

FAS receives fewer than 5 usability or interpretation inquiries each month from stakeholders, which could not have been addressed by a reasonably prudent review of the user guide.

FAS will log inquiries received, noting whether or not the inquiry could have been addressed had the inquirer consulted the user guide.

The vendor may be required to revise or reissue the user guide, at no additional cost, if inquiry volume is consistently in excess of the established threshold.

3.4 Meetings and Discussion s

The vendor participates in meetings and discussions with the agency to discuss contract activities

Vendor personnel who are needed to discuss the production, update, and usability of the QRS documents are present at a meeting/discussion

To clarify, it is not necessary that the vendor’s entire team attend each meeting; rather, the vendor must ensure that attendees, taken en banc, are qualified and empowered to speak to all aspects of the contract.

FAS will note when the vendor must defer a response due to appropriate personnel not being present; or if the vendor does not have any representatives present

Payments will be withheld until pending matters are addressed

Appendix B: Customer Feedback Record

CUSTOMER FEEDBACK RECORD

DATE AND TIME OF COMPLAINT CONTRACT NUMBER/ OR PROJECT:

SOURCE OF COMPLAINT

ORGANIZATION

INDIVIDUAL

NATURE OF COMPLAINT

PWS REFERENCE

VALIDATION

DATE AND TIME CONTRACTOR INFORMED OF COMPLAINT NAME OF CONTRACTOR REPRESENTATIVE INFORMED OF COMPLAINT

ACTION TAKEN BY CONTRACTOR (Responsible officer):

RECEIVED AND VALIDATED BY

Determination: Complaint Valid Complaint Invalid

Appendix C: Surveillance Activity Checklist

Performance Requirement

Performance Standard

Method of Measurement

Performance Metrics

Method of Surveillance

Date Accomplished

Compliance (Exceed, Met, Partial Met)