DRAFT QASP 12_9_21.docx
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UNITED STATES DEPARTMENT OF AGRICULTURE (USDA)
RURAL DEVELOPMENT (RD)
DRAFT
Quality Assurance Surveillance Plan (QASP) for Single-Family Housing Nationwide Appraisals Services (SHNAS)
9 December 2021
Contents
| Project Name | 3 | |
| Solicitation / Contract Number | 3 | |
| Section 1: Introduction | 3 | |
| 1.1 | Purpose | 3 |
| 1.2 | QASP Relation to the Contract | 3 |
| 1.2.1 | QASP Revisions | 3 |
| 1.2.2 | Surveillance of Performance Progression | 3 |
| 1.3 | QASP Relation to the Quality Control Plan (QCP) | 3 |
| Section 2: Performance Description | 3 | |
| 2.1 | Performance Standards and Acceptable Quality Levels (AQLs) | 3 |
| 2.1.1 | Allowable Deviation | 4 |
| 2.1.2 | Substantially Complete | 4 |
| 2.2 | Non-Performance | 4 |
| 2.2.1 | Documentation | 4 |
| 2.2.2 | Remedial Actions | 5 |
| Section 3: Contractor and Government Responsibilities | 5 | |
| 3.1 | Contractor Responsibility | 5 |
| 3.2 | Government Responsibility | 5 |
| 3.2.1 | Contracting Officer (CO) | 5 |
| 3.2.2 | Contracting Officer Representative (COR) | 5 |
| 3.2.3 | Customers | 5 |
| Section 4: Surveillance Methods to Perform Quality Assurance | 5 | |
| 4.1 | Surveillance Methods | 5 |
| 4.2 | Analysis and Results | 6 |
| Section 5: Quality Assurance Performance, Reporting and Documentation | 7 | |
| 5.1 Monitoring Performance | 7 | |
| 5.2 Reporting Performance | 7 | |
| 5.3 Monitoring Forms | 7 | |
| 5.4 Monthly Reviews and Resolution | 7 | |
| Appendix A: Performance Requirement Summaries | 8 | |
| Appendix B: Discrepancy Report | 10 | |
| Appendix C: Customer Feedback Record | 11 | |
| Appendix D: Inspection List | 12 | |
| Appendix E: Quality Assurance Monitoring | 13 | |
| Appendix F: Customer Complaint Investigation | 14 | |
| Appendix G: Surveillance Activity Checklist | 15 |
Project Name Single-Family Housing Nationwide Appraisal Services (SHNAS)
Solicitation / Contract Number
TBD
Section 1: Introduction This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the performance work statement (PWS) entitled Single-Family Housing Nationwide Appraisal Services (SHNOAS). This plan sets forth the procedures and guidelines that the USDA, Rural Development (RD) Procurement Management Office (PMO) 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 the 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 the 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 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 of 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 Government may consider one of the following actions: (1) the Contractor is responsible for correction of the problem at no additional expense to the Government; (2) the Government may charge the Contractor for any costs incurred by the Government that are directly related to having another Contractor perform the work, including the difference in price by the new Contractor that is hired to perform the services requested; (3) terminate the contract and/or individual task order.
All instances of non-conformance must be documented verbally or in writing, in the form of a corrective action request (CAR):
| Corrective Action Request (CAR) |
| Documentation |
| Level I- Can casually be corrected on the spot; non-recurring |
| Verbally or in writing |
| Level II- Repeat or uncorrected Level I Contractor Discrepancy Report (CDR); failure of Contractor’s Quality Control Plan |
| In writing only |
| Level III- Repeated or uncorrected Level II CDR |
| In writing only |
2.2.1 Documentation
Documentation of work not 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 to substantiate nonconformance with the contract. 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. FAR 52.211-11 Liquidated Damages-Supplies, Services or Research and Development is in Section F Deliveries or Performance of the contract.
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 Contract Specialist and/or the COR for performance management and administrative actions such as invoice approval. Issuance of Contract Discrepancy Reports (Appendix B) is delegated 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 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 (Appendix B) 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. The Contractor overall guidance is also provided by FAR clause 52.246-4 Inspection of Services -Fixed Price in Section E Inspection and Acceptance of the contract.
3.2.3 Customers
USDA customers or regional offices that the Contractor provided support may be requested to assist the COR in conducting QA to provide information relating to the Contractor’s performance through Customer Feedback (Appendix C). Information gained from the Customer Feedback may be used in conjunction with other methods of observation (i.e., Inspection (Appendix D), Customer Complaint (Appendix F)) to rate the performance of the Contractor.
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.
The required performance standards and/or quality levels are included in the PWS and in Appendix A, “Performance Requirements Summary.” Failure to meet the required service or performance level may result in Liquidated Damages or Nonperformance action.
To minimize the performance management burden, simplified surveillance methods shall be used by the Government to evaluate Contractor performance when appropriate. The primary methods of surveillance are:
1. 100% Inspection – with this method, performance is inspected/evaluated at each month. The COR or designated technical monitor (DTM) shall review the generated documentation and enter summary results into the Surveillance Activity Checklist available in Appendix G.
2. Periodic Inspection- this method evaluates tasks selected during a period of time. In this case, the COR will plan the dates which periodic inspections will take place. The COR or DTM ensure performance standards are implemented properly for each performance objective.
3. Customer Feedback from regional/state offices. The COR or technical representative will require feedback from state and/or regional offices during the ordering period. Customer feedback will be documented using the form available in Appendix C.
4.1.1. CUSTOMER FEEDBACK
The Contractor is expected to establish and maintain professional communication between its employees and customers. The primary objective of this communication is customer satisfaction. Customer satisfaction is the most significant external indicator of the success and effectiveness of all services provided and can be measured through customer complaints. Performance management drives the Contractor to be customer focused through initially and internally addressing customer complaints and investigating the issues and/or problems but the customer always has the option to communicate complaints to the COR or CO as opposed to the Contractor.
Customer complaints, to be considered valid, must set forth clearly and in writing the detailed nature of the complaint and must be signed and forwarded to the COR or Contracting Officer using the form in Appendix F. Customer feedback may also be obtained either from the results of formal customer satisfaction surveys or from random customer complaints.
4.1.2 ACCEPTABLE QUALITY LEVELS (AQL)
The Acceptable Quality Levels (AQLs) included in Appendix A titled Performance Requirements Summary Table, for Contractor performance are structured to allow the Contractor to manage how the work is performed while providing negative incentives for performance shortfalls. For certain critical activities, the desired performance level is established at 90 percent or higher. Other levels of performance are keyed to the relative importance of the task to the overall mission performance.
4.2 Analysis and Results
When the inspections (Appendix D) and “customer feedback,” (Appendix C) 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.
Government shall use the monitoring methods cited herein to determine whether the performance standards/service levels/AQLs have been met. If the Contractor has not met the minimum requirements, it may be asked to develop a corrective action plan to show how and by what date it intends to bring performance up to the required levels. At the end of each month, the COR will prepare a written report for summarizing the overall results of the quality assurance surveillance of the Contractor’s performance. This written report, which includes the Contractor’s submitted monthly report and the completed Quality Assurance Monitoring Form (Attachment B), will become part of the QA documentation. It will enable the Government to demonstrate whether the Contractor is meeting the stated objectives and/or performance standards.
Section 5: Quality Assurance Performance, Reporting and Documentation The performance management feedback begins with the communication of expected outcomes. Performance standards are expressed in the PWS and are assessed using the performance monitoring techniques shown in Appendix A of the QASP.
5.1 Monitoring Performance
Government shall use the monitoring methods cited to determine whether the performance standard level have been met. If the Contractor has not met the minimum requirements, it may be asked to develop a corrective action plan to show how and by what date it intends to bring performance up to the required levels.
5.2 Reporting Performance
At the end of each month, the COR will prepare a written report for summarizing the overall results of the quality assurance surveillance of the Contractor’s performance. This written report, which includes the Contractor’s submitted monthly report and the completed Quality Assurance Monitoring form (Appendix E), will become part of the QA documentation. It will enable the Government to demonstrate whether the Contractor is meeting the stated objectives and/or performance standards.
5.3 Monitoring Forms
The Government QA surveillance, accomplished by the COR will be reported using the monitoring forms in Appendices B-G. The forms when completed, will document the Government’s assessment of the Contractor’s performance under the contract to ensure results are being achieved. The COR will retain a copy of all completed QA surveillance forms for review.
5.4 Monthly Reviews and Resolution
The COR may require the Contractor’s Program Manager, to meet with the CO and other Government personnel monthly to discuss performance evaluation. The agenda of the reviews may include:
· Monthly performance assessment.
· Issues and concerns from both parties.
· Projected outlook for upcoming months and progress expected against trends, including corrective action plan analysis.
· Recommendations for improved efficiency and/or effectiveness.
The COR must coordinate and communicate with the Contractor and the CO to resolve issues and concerns regarding the marginal or unacceptable performance. The COR and Contractor should jointly formulate courses of action. Decisions regarding changes to metrics, or service levels should be clearly documented.
Appendix A: Performance Requirement Summaries
| Performance Objective |
| Performance Standard |
| Performance Threshold (AQL) |
| Method of Surveillance |
| PRS #1 The Contractor shall provide appraisal reports within timeframes stated in task orders and will vary from 10 to 30 calendar days after order receipt. |
| The Contractor shall provide appraisal reports on-time and in accordance with the USPAP and USDA specifications outlined in this PWS. |
| 90% of the appraisal reports must meet the timeframes in the executed task order. |
| 100% Inspection and customer feedback from regional offices. |
| PSR#2 The Contractor shall provide 1004D reports within 10 calendar days after order receipt. |
| The Contractor shall provide appraisal reports on-time and in accordance with the USPAP and USDA specifications outlined in this PWS. |
| 90% of the 1004D reports must be provided within 10 calendar days from the receipt order. |
| Periodic Inspection. |
| PSR#3 The Contractor shall respond and offer potential solutions to known risks and/or problems within one (1) business day. |
| The Contractor shall communicate known risks and/or problems with Agency staff and promptly offer solutions that meet the requirements stated herein. |
| The contractor will respond 95% of the time within 1 business day for known risks and/or problems. |
| Periodic Inspection and customers feedback from regional offices. |
| PSR #4 Weekly Progress Meetings |
| The Contractor shall participate in weekly teleconferences and/or telephone calls to monitor progress. |
| Weekly teleconference and/or telephone calls are done 100% of the time with zero instance of material failure. |
| 100% Inspection and customers feedback from regional offices. |
| PSR #5 Post Award Kick Off Meeting |
| The Contractor shall schedule a Post Award kickoff |
meeting with the Agency staff within 2 business days of Contract Award.
| Post Award Kick-Off meeting is scheduled on time and has zero instance of material failure. |
| 100% Inspection |
| PSR #6 Minimize disruption of services on Web-based platform (not to exceed 4 hours during normal business day of 7:00 AM Eastern to 4:00 PM Eastern) |
| The Contractor shall minimize downtime on the web-based platform during normal business days/hours. The Agency must be notified three (3) business days in advanced of any scheduled maintenance that will impact the appraisal progress activities. |
| The vendor will notify the Agency 100% of the time in advanced of any scheduled maintenance. |
The vendor’s disruption of services on Web-based platform exceeding the 4 hours during a normal business day will not exceed no more than 3 business days in a calendar year.
100% Inspection and customers feedback from regional offices.
| PSR#7 Unscheduled Outages of Web-based platform |
| The Contractor shall notify the Agency staff as soon as possible after discovery. |
| The vendor will notify the Agency 100% of the time in advanced of any scheduled maintenance. |
The vendor’s disruption of services on Web-based platform exceeding the 4 hours during a normal business day will not exceed no more than 3 business days in a calendar year.
100% Inspection and customer feedback from regional offices.
| PSR#8 Inadvertent disclosure (data breach) of Personally Identifiable Information (PII) |
| The Contractor shall notify the COR or alternate and CO of any inadvertent disclosure of PII within 1 hour of discovery |
| All disclosure of PII will be reported within 1 hour of discovery. |
| 100% Inspection |
| PSR#9 Maintain Small Business Subcontracting Plan goals |
| The Contractor shall maintain the Small Business Subcontracting Plan and goals of 10% across all task order |
| Small business subcontracting plan/goals of at least 10% should be maintained 100% of the time. |
| Periodic Inspection. |
| PSR#10 Obtain and maintain all appropriate state licenses/certifications |
| Contractor shall obtain and maintain all appropriate state licensures/certifications for the entire ordering period. |
| Zero instance of material failure |
| Periodic Inspection. |
| PSR#11 Maintain reports required by Quality Control (QC) Plan |
| Contractor QC Plan shall be up to date and consistently reflect effective procedures to ensure quality performance |
| The vendor shall maintain up to date QC plan 100% of the time. |
| 100% Inspection. |
| PSR#12 Training Web-Based Portal |
| The Contractor shall host a virtual training session of their web-based portal. |
| The vendor shall maintain the virtual training session of their web-based portal on schedule and 100% of the time. |
| 100% Inspection and customer feedback from regional offices. |
Appendix B: Discrepancy Report
| DISCREPANCY REPORT |
| 1. DISCREPENCY REPORT NO. |
| 2. TO: (Contractor / Project Manager Name) |
| 3. FROM: (Name of COR) |
CONTRACT NUMBER: DATE:
| PREPARED |
| ORAL NOTIFICATION |
| RETURNED BY CONTRACTOR |
| ACTION COMPLETE |
4. DISCREPENCY OR PROBLEM (Describe in Detail. Include PWS references. Attach Continuation Sheet if Necessary)
5. SIGNATURE OF COR
| 6. TO: (Name of COR) |
| 7. FROM: (Contractor / Project Manager) |
8. CONTRACTOR RESPONSE AS TO CAUSE, EFFECT, CORRECTIVE ACTION AND ACTIONS TO PREVENT RECURRENCE (Attach Continuation Sheet if necessary. Cite applicable Contractor QC program procedures or new QC procedures)
| 9. SIGNATURE OF CONTRACTOR REPRESENTIVE |
| 10. DATE |
11. GOVERNMENT EVALUATION (Acceptance, partial acceptance, or rejection. Attach Coordination Sheet if necessary)
12. GOVERNMENT ACTIONS (Cure notice, show cause, other)
CLOSE OUT
KTR NOTIFIED
| NAME AND TITLE |
| SIGNATURE |
| DATE |
COR
Appendix C: 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 D: Inspection List
CONTRACT NUMBER: ___________________________________
SERVICE FUNCTION:
PWS SECTION:
| 1 |
| Method of Surveillance: |
| 2 |
| Lot Size: |
| 3 |
| Sample Size: |
| 4 | ||
| Performance Requirement: Performance is Excellent (E) when ___________or fewer defects are discovered per month. Performance is Satisfactory (S) when ________ | or fewer defects are discovered per month. Performance is Unsatisfactory (U) when _______ | or more defects are discovered per month. |
| 5 |
| Sampling Procedure: Instructions on how to select the sample must be clear and complete |
| 6 |
| Inspection Procedure: The procedure must be detailed enough to allow a yes/no objective decision as to the acceptability of performance by anyone making the inspection. Explain when evaluation is to occur and what is acceptable/unacceptable |
Performance: Excellent (E), Satisfactory (S), Unsatisfactory (U), Not Applicable (N/A)
| PRS Requirements |
| Timeliness |
| Quality of Work |
| Notes |
Overall Rating Of Inspection (E, S, U or N/A)
COR/Inspector Comments:
Contractor Signature: ___ Date: __
COR Signature: ____________________Date: _________________
Appendix E: Quality Assurance Monitoring
CONTRACT NUMBER: ______________________________________
SERVICE or STANDARD:
SURVEY PERIOD:
SURVEILLANCE METHOD (Check the applicable item):
r Random Sampling r 100% Inspection r Periodic Inspection r Customer Complaint LEVEL OF SURVEILLANCE (Check the applicable item):
| r | Monthly | r | Quarterly | r | As needed |
| PERCENTAGE OF ITEMS SAMPLED DURING SURVEY PERIOD: | ______ % |
ANALYSIS OF RESULTS:
Observed Service Provider Performance Measurement Rate: ______% Service Provider’s Performance (Check the applicable item):
r Meets Standards r Does Not Meet Standards Narrative of Performance During Survey Period:
Prepared By: _______________________________ Date: ______________
Appendix F: Customer Complaint Investigation
CONTRACT NUMBER: _________________________
SERVICE or STANDARD:
SURVEY PERIOD: ___________________
DATE COMPLAINT RECEIVED: ____________
SOURCE OF COMPLAINT: _________________________________________ (Name) _______________________________________________________________ (Organization) ___________________ (Phone No.) _________________________________ (Email Address)
NATURE OF COMPLAINT: ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
RESULTS OF COMPLAINT INVESTIGATION: ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
DATE SERVICE PROVIDER INFORMED OF COMPLAINT: _____________
CORRECTIVE ACTION TAKEN BY SERVICE PROVIDER: _________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Received and Validated By: __________________________________________ Prepared By: _____________________________ Date: _________________
Appendix G: Surveillance Activity Checklist
Performance Requirement Performance Standard Method of Measurement
Performance Metrics Method of Surveillance Date Accomplished Compliance (Exceed, Met, Partial Met)
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