D.1 QASP TELRADIOLOGY CONTRACTORS.docx

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Attached to
Q522--Other - VISN 9 Tele-Radiology Contract - VISN Replacement base+4 requirement
Solicitation number
36C24926R0007
Issued by

About this file

This is a Quality Assurance Surveillance Plan (QASP) for a Veterans Affairs teleradiology contract (36C24926R0007) under VISN 9 (Veterans Integrated Services Network 9). The QASP establishes a systematic framework for monitoring and evaluating contractor performance in delivering Board Certified teleradiology physician services to VA beneficiaries. The plan designates the Contracting Officer (Carol Franklin, NCO 9) and Contracting Officer's Representative (Debbie Thompson, with alternates assigned to specific stations: Tiffany Cannon at Tennessee Valley, Rodney McKinney at Lexington, Virgil Snashall at Louisville, and Reginald Penny at Memphis) as responsible for oversight and surveillance activities. The contractor's program manager information is to be completed by the contractor.

The QASP defines eight key performance standards with specific acceptable quality levels (AQLs) measured through direct observation, periodic inspection, customer complaints, random sampling, and contractor-provided documentation. Critical performance areas include: timeliness of radiology report delivery (98% compliance), provider quality performance based on Ongoing Professional Performance Evaluation (97% compliance), physician board certification and current licensing (100%), scope of practice adherence (100%), patient access and availability (99%), maintenance of credentials (100%), completion of mandatory training (100%), and compliance with privacy, confidentiality, and HIPAA requirements (zero breaches). Performance ratings—Exceptional, Very Good, Satisfactory, Marginal, or Unsatisfactory—are assigned to each measure and documented in the Contractor Performance Assessment Reporting System (CPARS). Non-compliance with acceptable quality levels triggers a formal Contract Report (CR) process requiring written notification, contractor response, and corrective action plans reviewed by the Contracting Officer. The QASP serves as a living document subject to government revision and contractor notification through contract modification.

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ATTACHMENT D.1 – QUALTIY ASSURANCE SURVEILLANCE PLAN

CONTRACT NUMBER: CONTRACTOR:

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 will monitoring take place.

· Who will conduct the monitoring?

· How will monitoring efforts and results 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 CS: Ramona Bonness Assigned CO: Carol Franklin Organization or Agency: Network Contracting Office 9 (NCO 9)

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.

Primary COR:

Debbie Thompson Alternate CORs (by station):

Debbie Thompson – Mountain Home Tiffany Cannon – Tennessee Valley (TVH) Rodney McKinney – Lexington Virgil Snashall – Louisville Reginald Penny – Memphis

3. CONTRACTOR REPRESENTATIVES

The following employee(s) of the contractor serve as the contractor’s program manager(s) for this contract. (List, include POC Names, Phone and Emails.)

CONTRACTOR’s Primary Program Manager:

Alternate Program Manager(s):

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. 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. 100% surveillance: CORs and PACS Administrators will actively monitor Radiology PACS for completion of radiology exam reports and timeliness thereof.

b. PERIODIC INSPECTION. Inspections scheduled and reported quarterly per COR delegation or as needed. CORs and/or PACS Adminsitrators will run monthly reports to validate invoicing prior to payment. Reports from VistA to monitor accurate documentation of critical findings within the report, timeliness reports, and random sampling will be performed monthly, quarterly, annually, or on demand. Peer reviews will randomly be performed daily with escalation of any 2b findings or greater to peer subcommittee review.

c. VALIDATED USER/CUSTOMER COMPLAINTS. Complaints will be reported to Primary COR in real time, communicated to CO, and validation process completed. Contractor to be notified in writing.

d. RANDOM SAMPLING. Various reports and dashboards are configured to monitor Radiology processes throughout the VISN. All reviews and reports will be conducted in compliance with VA Privacy and Information security standards.

e. VERIFICATION AND/OR DOCUMENTATION PROVIDED BY CONTRACTOR. Contractor will provide information, updated documents, and reports on demand. Contractor is required to update VISN of any changes that will impact contract performance.

6. ASP PERFORMANCE REPORT DATE: ___________________

Measures

Pws Reference
Performance Requirement
Standard
Acceptable Quality Level
Method of

Surveillance Met AQL/DID NOT MEET AQL-

CPARS RATING/ADD COMMENTS

1. Timeliness of Reports - Prompt delivery (timeliness) of interpretations and return for routine/stat/immediate
PWS para. 4.5.1

4.5.1.2.5 4.5.1.2.7

Prompt delivery (timeliness) of interpretations and return for routine/ stat/immediate

Delivery 100% of the time.

98% Compliance
MANAGEMENT INFORMATION SYSTEMS (MIS) with PERIODIC INSPECTION

2. Provider Quality Performance

Special Contract Requirements

And Para 4.6, 4.8.1, 4.8.1.2 All contract physician(s) shall perform in accordance with clinical standards provided by the VA for Ongoing Professional Performance Evaluation

Timeliness of peer review and exam summary quarterly and annual reports

All (100%) contract physician(s) shall perform in accordance with clinical standards

Required reports are received timely and complete for every credentialed provider for VISN 9.

97%
OPPE data pertinent to care performed for each provider working under this contract
3. Qualifications of Key Personnel
Special Contract Requirements. PWS Para.

2.1.5 2.1.3 1.5.12

All Contractor’s physician(s) shall be Board Certified in accordance with ACR Standards.
All (100%) licensing, registration(s) and certification(s) for contract physician(s) shall be provided as they are renewed. Licensing and registration information kept current.
100%

PERIODIC INSPECTION OR RANDOM SAMPLING of qualification documents

4. Scope of Practice/Privileging

2.1.3 2.1.3.3 2.1.3.8 2.1.5 4.2.2

Contract physician(s) performs within their individual scopes of practice/privileging.
All (100%) contract physician(s) perform within their scope of practice/privileges 100% of the time.
100%
PERIODIC INSPECTION OR RANDOM SAMPLING of records
5. Patient Access
PWS para. 3.1

3.2 3.4.4 4.1

All (100%) contract physician(s) are on time and available to perform services.
OPPE documentation for all (100%) staff providing services under the contract. All staff (100%) meet Standards
99%
PERIODIC INSPECTION OR RANDOM SAMPLING VA will monitor using Electronic report using data from VISTA/CPRS monthly.
6. Maintains licensing, registration, and certification
PWS

Para. 4.3 4.6

Updated Licensing, registration and certification shall be provided as they are renewed. Licensing and registration information kept current.
All (100%) contract physician (s) perform within their scope of practice/privileges 100% of the time.
100% Acceptable Quality Level
PERIODIC INSPECTION AND RANDOM SAMPLING
7. Mandatory training
PWS

2.1.6

Contractor shall complete all required training per VAMC policies
All (100%) of required training is complete on time by Contractor’s physician(s).
100% Acceptable Quality Level
PERIODIC INSPECTION OR RANDOM SAMPLING

8. Privacy, Confidentiality and HIPAA

PWS para. 1.5.14 1.5.26 4.4.1 4.4.2 4.4.3.

4.7.3.

and Special Contract Requirements

Contractor is aware of all laws, regulations, policies and procedures relating to Privacy, Confidentiality and HIPAA and complies with all standards. Zero breaches of privacy or confidentiality.

All (100%) Contractor’s physician(s) comply with all laws, regulations, policies and procedures relating to Privacy, Confidentiality and HIPAA
100%
PERIODIC INSPECTION Contractor shall provide evidence of annual training required by the facility, reports violations per VA Handbook 6500.6.

TELERADIOLOGY SERVICES 36C24926R0007

7. CPARS 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/documents/CPARS-Guidance.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 thecontractual 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 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).

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 REPORTING SYSTEM (CPARS).

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 on the following page.

9. COR AND CONTRACTOR ACKNOWLEDGEMENT OF QASP

SIGNED:

COR NAME/TITLE DATE

SIGNED:

CONTRACTOR NAME/TITLE DATE

CONTRACT REPORT

1. CONTRACT NUMBER
2. REPORT NUMBER
3. TO: (Contracting Officer)
4. FROM: (Name of COR)

5. DATES

a. CR PREPARED

b. RETURNED BY CONTRACTOR:
c. ACTION COMPLETE

6. Issue Identified (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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