D.3 Quality Assurance Surveillance Plan.docx

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Attached to
Intraoperative Neurophysiologic Monitoring Services (IONM)
Solicitation number
36C24623Q0900_2
Issued by

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This document outlines a Quality Assurance Surveillance Plan (QASP) for intraoperative neurophysiological monitoring services under solicitation number 36C24623Q0900_2 issued by the Department of Veterans Affairs Veterans Health Administration Veterans Integrated Service Network 6. The QASP defines performance standards and acceptable quality levels for key personnel, patient safety, licensing and certification, mandatory training, privacy and confidentiality, invoicing timeliness, and other factors. Performance will be monitored through methods such as direct observation, periodic inspection of patient files, validated customer complaints, random sampling, and documentation from the contractor. Performance ratings may impact past performance assessments and potential incentives or disincentives include favorable or unfavorable contractor evaluations or removal from the contract.

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Other files

File Type Posted
S06_36C24623Q0900 0001 Q and A Amendment.pdf PDF
S02_36C24623Q0900 (IONM).pdf PDF
D.1 Past Performance Questionnaire.docx DOCX document
D.5 VA Contractor Conflict of interest Certification Statement.docx DOCX document
D.2 Contractor Certification.docx DOCX document
CONTRACT DISCREPANCY REPORT.docx DOCX document
D.4 VA National Rules of Behavior.docx DOCX document

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D.3 Quality Assurance Surveillance Plan (QASP)

Intra-operative Neurophysiological Monitoring

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: David E. Smith Organization or Agency: Network Contracting Office (NCO) 6 Email: David.Smith78@va.gov Phone: 757-728-7156

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.

Assigned COR: Herbert L. Clark Organization or Agency: Durham VA Medical Center.

Email: Herbert.Clark28@va.gov Phone: 919-286-04111 ex 4576

3. CONTRACTOR REPRESENTATIVES

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

Primary: _________________________________

Alternate: ________________________________

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. INCENTIVES/DEDUCTS

The Government shall use past performance as incentives. Incentives shall be based on ratings received on the performance standards (Inclusion of any monetary incentives requires approval through the Department’s Senior Procurement Executive (SPE).

6. 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.

The table below is a sample that can be tailored – note that the table must identify where in the PWS the standards are found for monitoring performance.

7. PERFORMANCE MEASURES

Measures
PWS

Reference Performance Requirement

Standard
AcceptableQuality Level
Surveillance

Method

Incentive
Disincentive

(Deduct)

1 - Key Personnel
2.3
Provide required medical service as specified in the requirements.
Qualified personnel are available and in location as needed to properly perform tasks as specified.
100%
Random Inspection, Time and Attendance Sheets, Quality Assurance Reports
Favorable contactor performance evaluation.
Unfavorable contractor performance evaluation
2 - Patient Safety
10.0
Patient safety incidents must be reported using Patient Safety Report.
All incidents reported immediately (within 24 hours.)
100%
Direct Observation
Favorable contactor performance evaluation.
Unfavorable contractor performance evaluation

3 - Maintains licensing, registration, and certification

2.3.2
Updated Licensing, registration and certification will be provided as they are renewed.
Licensing and registration information kept current.
Contract Provider records will be kept 100% up-to- date
Periodic Sampling and Random Sampling
Favorable contactor performance evaluation.
Unfavorable contractor performance evaluation

4 - Mandatory Training

2.3.5
Contractor completes all mandatory required training
Contractor will complete all required training per VAMC policy
100%
Contractor to provide documented evidence
Favorable contactor performance evaluation.
Suspension or termination of all physical and/or electronic access privileges and removal from contract until such time as the training is complete
5 - Privacy, Confidentiali ty and HIPPA
9.0 and Special Requirements
Contractor is aware of all laws, regulations, policies and procedures relating to Privacy, Confidentiality and HIPPA and complies with all standards
Zero breaches of privacy or confidentiality
100%
Contractor to provide evidence of annual training required by VAMC, reports violations per policy
Favorable contactor performance evaluation.
Immediate removal from contract
6 - Timely Invoicing
8.0
Within 30 days of the end of each month services were provided, as described above, the

vendor shall

All itemized invoices provided within 30 days of end of each month services delivered
100%
Inspection
Favorable contactor performance evaluation.
Unfavorable contractor performance evaluation

Other performance evaluation factors will be monitored that are not quantified by numerical measurements which include: no inappropriate prescriptions; patient customer service comments; provider and Contractor relationship with hospital staff/government contracting personnel; compliance with hospital policy and procedures.

The contractor is responsible for performance of ALL terms and conditions of the contract, the elements above represent those that will be subject to ongoing reporting by the COR in accordance with this plan.

a. DIRECT OBSERVATION. 100% surveillance

b. PERIODIC INSPECTION. Inspections scheduled annually or as needed. 10 randomly selected patient files per inspection period.

c. VALIDATED USER/CUSTOMER COMPLAINTS. Customer complaint data is compiled quarterly and reviewed by Service Chief – any validated complaints against a Contractor that are not resolved within the required seven-day period will be further investigated.

d. RANDOM SAMPLING. Patient treatment files to be reviewed will be randomly selected and cover the period of service.

e. Verification and/or documentation provided by Contractor.

8. 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/pdfs/CPARS-Guidance.pdf p. A2-1):

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).

9. 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.

10. COR AND CONTRACTOR ACKNOWLEDGEMENT OF QASP

SIGNED:

COR NAME/TITLE DATE

SIGNED:

CONTRACTOR NAME/TITLE DATE

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