D.1 ATTACHMENT 1 QASP 36C25526Q0259.pdf

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Attached to
Intraoperative Neurophysiologic Monitoring (IONM) Services
Solicitation number
36C25526Q0259
Issued by

About this file

This is a Quality Assurance Surveillance Plan (QASP) for federal contract solicitation number 36C25526Q0259 issued by the Department of Veterans Affairs Network Contracting Office (NCO) 15. The QASP establishes systematic methods to evaluate contractor performance on an Electro Neurophysiologic services contract at Truman VAMC in Columbia, Missouri, dated March 1, 2018 (Version 0003).

The contract is administered by Contracting Officer Leah Thurman (leah.thurman@va.gov, 913-946-1122) and Contract Specialist Stephen Showers (stephen.showers@va.gov, 785-350-3111 Ext 52487), with Contracting Officer's Representative Tonya Brooks (Truman VAMC, 800 Hospital Dr., Columbia, MO 65201) responsible for technical administration. The QASP defines six performance standards monitored through direct observation, periodic inspection, and customer feedback methods: (1) Patient Access—Electro Neurophysiologic Technologists must be on time and available 100% of the time per operating hours; (2) Patient Safety—100% of patient safety incidents must be reported within 24 hours using required forms; (3) Licensing, Registration, and Certification—Neurologists must maintain current unrestricted licenses and ABPN Board Certification/Eligibility, while Technologists maintain ABRET accreditation and current BLS certification; (4) Medical Records—100% of reports/status must be available in real time to surgeons; (5) Privacy, Confidentiality, and HIPAA—100% compliance required with annual training and violation reporting per VA Directive 6500.6; and (6) Billing for Services—100% of invoices must be submitted by the 7th business day of the following month. Contractor performance is rated using five CPARS levels: Exceptional, Very Good, Satisfactory, Marginal, and Unsatisfactory, with ratings becoming part of past performance evaluations. The COR maintains a quality assurance file and provides quarterly progress reports to the CO, while the contractor must acknowledge receipt of any Contract Reports citing performance deficiencies and submit corrective action plans as required.

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Page 1 of 7 Version 0003 Dated 3/1/2018

Attachment 1 Quality Assurance Surveillance Plan Solicitation Number 36C25526Q0259

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: Leah Thurman Organization or Agency: Department of Veterans Affairs Network Contracting Office (NCO) 15 3450 South 4th Street Leavenworth, KS 66048-5055 913-946-1122 leah.thurman@va.gov

Contract Specialist:

Organization or Agency: Department of Veterans Affairs Network Contracting Office (NCO) 15 3450 South 4th Street Leavenworth, KS 66048-5055 785-350-3111 Ext 52487 Stephen.showers@va.gov

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.

mailto:leah.thurman@va.gov mailto:Stephen.showers@va.gov

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Assigned COR: Tonya Brooks Organization or Agency: Truman VAMC 800 Hospital Dr.

Columbia, MO 65201

3. CONTRACTOR REPRESENTATIVES

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.

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

Primary:

Alternate:

4. PERFORMANCE STANDARDS

A. 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.

B. 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. 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. Direct Observation: The COR shall monitor scheduled semi-annually preventive and corrective maintenance performance standards (100% Inspection) and enter results into the Surveillance Activity

Page 3 of 7 Version 0003 Dated 3/1/2018

Checklist.

B. Periodic Inspection: Inspections shall be unscheduled and/or conducted quarterly, per COR delegation, or as needed.

C. 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 forwarded to the COR. The COR shall maintain a summary log of all formally received customer complaints as well as a copy of each complaint in a documentation file. The COR shall also keep the tabulated results of all customer satisfaction surveys on file and shall enter the summary results into the Surveillance Activity Checklist. Copies of all records shall be submitted to the CO upon receipt for placement in the official contract file, and when necessary, determination of actions.

Quality Assurance Surveillance Plan (QASP)

Page 3 of 7 Version 0003 Dated 3/1/2018

36C25526Q0259

6. QASP PERFORMANCE REPORT

Measures Reference Performance Requirement

Standard Acceptable Quality Level Surveillance

Method Incentive

Patient Access PWS 7.4.1 The contractor shall provide contractor’s Electro Neurophysiologic

Technologists in accordance with the operating hours, and VA clinical schedule outlined in this PWS.

Contractor’s Electro Neurophysiologic Technologists are on time and available to perform services.

Contractor’s Electro Neurophysiologic Technologists are on time and available to perform services. are on-time and available to perform services 100 %of the time in accordance with this performance work statement.

Direct Observation

Favorable contactor performance evaluation

Patient Safety PWS 4.13, 7.4.2

Patient safety incidents shall be reported using Patient Safety Report. All incidents reported immediately (within 24 hours.)

All (100%) of patient safety incidents are reported using Patient Safety Report within 24 hours of incident.

100%of patient safety incidents are reported using Patient Safety Report within 24 hours of incident.

Direct Observation

Favorable contactor performance evaluation

Licensing, Registration, and Certif ication

PWS 7.4.3 Updated Licensing, registration and certif ication shall be provided as they are renewed. Licensing and registration information kept current.

Standard 1: Neurologists shall maintain current unrestricted licenses and Board Certif ication/Eligibility by ABPN; Technologists shall maintain ABRET accreditation;

on-site personnel shall maintain BLS certif ication.

Standard 2: Electro Neurophysiologic

Technologists shall be accredited through the American Board of

Registration of Electroencephalographic and Evoked Potential

Technologists (ABRET) and shall maintain current Basic Life Support (BLS) certif ication.

100% licensing, registration(s) and certif ication(s) for contractor’s

Neurologists shall be provided as they are renewed. Licensing and registration information kept current.

Periodic and Random

Sampling

Favorable contactor performance evaluation

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Medical Records

PWS 6,

7.4.4

Contractor shall make all medical records concerning the veteran’s surgical care readily accessible to VA and VA surgeons.

All (100%) of reports/status will be available in real time during operation to surgeon(s).

100% compliance

Direct Observation

Favorable contactor

Privacy, Conf identiality and HIPAA

PWS 6

Medical

Records, 7.4.5

Contractor must maintain privacy, conf identiality, and security guided by VA policies/procedures.

All (100%) contractor’s Electro Neurophysiologic Technologists comply with all laws, regulations, policies and procedures relating to Privacy, Confidentiality and HIPAA

100% compliance Periodic Sampling;

contractor shall provide evidence of annual training required by

KCVAMC,

reports violations per VA Directive

6500.6.

Favorable contactor performance evaluation

Billing for Services

PWS 9.3

Billing, 7.4.6

Billing invoices must be submitted timely, in monthly arrears.

100% of invoices submitted by the 7th business day of the following month af ter services performed.

100% compliance Direct Observation.

System-generated compliance reports f rom the VA’s electronic invoicing platform (Tungsten).

Favorable contactor

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7. CPAR RATINGS ASSIGNED TO QASP ITEMS:

Metrics and methods are designed to determine rating for a given standard and acceptable quality level. The following ratings shall be used (Reference: CPARS User Manual https://www.cpars.gov/cparsweb/assets/documents/CPARS_User_Manual.pdf )

EXCEPTIONAL: Performance meets contractual requirements and exceeds many to the 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 should have been NO significant weaknesses identified.

VERY GOOD:

Performance meets contractual requirements and exceeds some to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor were effective.

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 should have been NO significant weaknesses identified.

SATISFACTORY:

Performance meets contractual requirements. The contractual performance of the element or sub- element contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory.

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 should have been NO significant weaknesses identified.

MARGINAL:

Performance does not meet some contractual requirements. The contractual performance of the element or sub-element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented.

Note: To justify Marginal performance, you should identify a significant event in each category that the contractor had trouble overcoming and state how it impacted the GOVERNMENT. A Marginal rating should be supported by referencing the management tool that notified the contractor of the contractual deficiency (e.g. Management, Quality, Safety or Environmental Deficiency Report or letter).

UNSATISFACTORY:

Performance does not meet most contractual requirements, and recovery is not likely in a timely manner. The contractual performance of the element or sub-element being assessed contains serious problem(s) for which the contractor’s corrective actions appear or were ineffective.

Note: To justify an Unsatisfactory rating, you should identify multiple significant events in each category that the contractor had trouble overcoming and state how it impacted the GOVERNMENT. However, a singular problem https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.cpars.gov%2Fcparsweb%2Fassets%2Fdocuments%2FCPARS_User_Manual.pdf&data=05%7C02%7C%7C1299a8a1556647c9c9b208dd897915ec%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C638817875334440754%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=6A9MQEEm9YUvO1cWqDUn1sC8wYUJvuCVqG%2F2AhW8s1E%3D&reserved=0

Page 6 of 7 Version 0003 Dated 3/1/2018 could be of such serious magnitude that it alone constitutes an unsatisfactory rating. An Unsatisfactory rating should be supported by referencing the management tools used to notify the contractor of the contractual deficiencies (e.g. Management, Quality, Safety or Environmental Deficiency Reports, or letters).

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8. DOCUMENTING PERFORMANCE

a. The Government shall document positive and/or negative performance. Any report may become a part of the supporting documentation for any contractual action and preparing annual past performance using CONTRACTOR PERFORMANCE ASSESSMENT REPORT (CPAR).

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 Report (CR), 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 CR in writing. The CR 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 CR 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 CRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO. See Sample CR below.

9. COR AND CONTRACTOR ACKNOWLEDGEMENT OF QASP

SIGNED:

COR NAME/TITLE DATE

SIGNED:

CONTRACTOR NAME/TITLE DATE

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CONTRACT REPORT

DISCREPANCY

1. CONTRACT NUMBER 2. REPORT NUMBER FOR THIS ISSUE

3. TO: (Contracting Officer) 4. FROM: (Name of COR)

5. DATES

a. CR PREPARED b. RETURNED BY

CONTRACTOR:

c. ACTION COMPLETE

6. Issue Identif ied (Describe in detail. Include reference to PWS Directive; attach continuation sheet if necessary.)

7. SIGNATURE OF COR Date:

8. SIGNATURE OF CONTRACTING OFFICER Date:

9a. TO (Contracting Officer) 9a. FROM (Contractor)

10. CONTRACTOR RESPONSE AS TO CAUSE AND ACTIONS TO PREVENT RECURRENCE.

(Cite applicable quality control program procedures or new procedures. Attach continuation sheet(s) if necessary.)

11. SIGNATURE OF CONTRACTOR REPRESENTATIVE Date:

12. GOVERNMENT EVALUATION.

13. GOVERNMENT ACTIONS

14. CLOSE OUT

NAME TITLE SIGNATURE DATE

CONTRACTOR

NOTIFIED

COR

CONTRACTING

OFFICER

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