D.7 QASP.docx

ATTACHMENT D.6

Quality Assurance Surveillance Plan

Contract Name: VHA Office of Finance (OF) Recovery Audit Contract

Contract Number/Solicitation: 36C10X25R0021

Contract Description: This contract will meet the requirements of 38 U.S.C. 1703(d) which requires a recovery audit contract be awarded to audit Veterans Health Administration (VHA) programs for overpayments erroneously made to providers.

The contractor will also be required to set-up and maintain:

· A Customer Service Center.

· A public website.

· A secure portal for transferring data between VA and the contractor.

The authorities of the VHA programs being audited are 38 U.S.C. 1703, 38 U.S.C. 1781, 38 U.S.C. 1725, 38 U.S.C.1728, 38 U.S.C.8153, 38 C.F.R. § 17.900 – 17.905 and 38 C.F.R. §17.1500 – 17.1540.

Contractor’s Name: _____________________________

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. 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: Jacky Jean-Jacque Assigned CS: LaShawn Knight Organization or Agency: SAC

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: Akeel Omari Organization or Agency: VHA/OF

Other Key Government Personnel: Robert Terral, PM Organization or Agency: VHA/OF

3. CONTRACTOR REPRESENTATIVES:

The following employees of the contractor serve as the contractor’s points of contact for this contract:

a. Assigned Program Director: _______________________

b. Assigned IT Security Analyst (ITSA): ______________________

4. PERFORMANCE STANDARDS:

Performance standards define desired services. The Government performs surveillance to determine if the contractor meets or does not meet these standards.

PERFORMANCE STANDARDS MATRIX TABLE:

Prepare Batch Transmission Report containing data required for collections to VA or designee on a weekly basis.

Reports are submitted no later than the due dates. Reports contain the required data elements.

The Batch Transmission Report is provided by the due date each week.

5. INCENTIVES

The Government shall use positive past performance and the possible exercising of option periods and as incentives. Incentives shall be based on meeting or not meeting performance standards.

6. METHODS OF QA SURVEILLANCE

Various methods exist to monitor performance. The COR may use any surveillance methods listed below in the administration of this QASP:

a. Virtual Observation: Can be performed periodically or through 100% surveillance.

· May be used on Tasks: 1 – 7(a-g)

b. Management Information Systems (MIS): Evaluates outputs through the use of management information reports. Best used for general surveillance and may need to be supplemented by periodic inspections.

· May be used on Tasks: 7(a-g)

c. Periodic Inspection: Evaluates outcomes on a periodic basis. Inspections may be scheduled [Daily, Weekly, Monthly, Quarterly, or annually] or unscheduled, as required.

· May be used on Tasks: 7(a-g)

d. User Survey: Combines elements of validated user complaints and random sampling. Random survey is conducted to solicit user satisfaction. May also generate inspections and sampling.

· May be used on Task: 6

e. Validated User/Customer Complaints: Relies on the patient to identify deficiencies. Complaints are then investigated and validated.

· May be used on Tasks: 3 & 6

f. 100% Inspection: Evaluates all outcomes.

· May be used on Tasks: 1 – 5

g. Periodic Sampling: Variation of random sampling. However, sample is only taken when a problem/deficiency is suspected. Sample results are applicable only for the specific work inspected. Since sample is not entirely random, it cannot be applied to total activity performance.

· May be used on Tasks: 3, 4, and 7(a-g)

h. Random Sampling: Designed to evaluate performance by randomly selecting and inspecting a sample of cases.

· May be used on Tasks: 7(a-g)

i. Progress Meetings: Designed to evaluate performance through information obtained through discussions and reporting from progress or status meetings.

· May be used on Tasks: 1 - 7(a-g)

j. Analysis of Contractor's Progress Reports: Evaluate cost, schedule, etc.

· May be used on Tasks: 2, 4 – 7(a-g)

7. RATINGS

Metrics and methods are designed to determine if performance meets or does not meet a given standard and acceptable quality level. A rating scale shall be used to determine a positive, neutral, or negative outcome. The following ratings shall be used:

· ACCEPTABLE PERFORMANCE

· UNACCEPTABLE PERFORMANCE

8. DOCUMENTING PERFORMANCE

a. ACCEPTABLE PERFORMANCE: The Government shall document positive performance. Any report may become a part of the supporting documentation for any contractual action.

b. UNACCEPTABLE PERFORMANCE: When unacceptable performance occurs, the COR shall inform the contractor. This will normally be in writing unless circumstances necessitate verbal communication. In any case the COR shall document the discussion and place it in the COR file.

The COR will complete a Contract Inspection Performance Report (CIPR) when conducting inspections in accordance with the QASP identifying any weaknesses or deficiencies as well as any noteworthy positive comments. The COR will forward the CIPR to the contractor’s Point of Contact (POC) and the contractor shall acknowledge receipt of the CIPR in writing.

Audit accuracy for tasks 7(a-g) shall be measured through a quarterly validation audit. That audit may be conducted by VA staff or a support contractor. The quarterly validation report will be shared with the contracting officer and the contractor point of contact. Incentives and disincentives will be applied based on the audit results; in cases where the contractor is below a 95% accuracy level the CO may request a corrective action plan.

If the COR believes there may be performance issues other than audit accuracy, the COR will forward the CIPR to the CO to discuss any next steps and again, if required the CO may require a corrective action plan documenting how the contractor will correct the unacceptable performance and avoid a recurrence. The CO will identify when the contractor must present their corrective action plan to the COR. The Government shall review the contractor's corrective action plan to determine acceptability.

Any CIPRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO.

9. FREQUENCY OF MEASUREMENT

a. Frequency of Measurement – During contract performance, the COR will periodically analyze whether the negotiated frequency of surveillance is appropriate for the work being performed. The frequency will be as needed and at the discretion of the COR.

b. Frequency of Performance Assessment Meetings – The COR shall provide the contractor with a copy of the CIPR for any inspection. If the contractor would like to discuss the CIPR, the COR and the contractor will set up a meeting for that discussion.