FA4890-14-R-0024_CN GT_Training_QASP_20150330.docx

CN&GT Training Support Services ID/IQ Quality Assurance Surveillance Plan Attachment 1 First / Second Notice Template

30 March 2015 (Original)

Counter Narcotics & Global Threats Training Support Services

FA4890-14-R-0024

Quality Assurance Surveillance Plan

COMPLIANCE WITH THIS DOCUMENT IS MANDATORY

NOTICE: This Document is available in digital format through ACC AMIC/DRQC

Pages: 12

TABLE OF CONTENTS

TABLES

ATTACHMENTS

1.0 SCOPE. The Quality Assurance Surveillance Plan (QASP) is applicable to personnel performing contract surveillance audits in accordance with (IAW) Federal Acquisition Regulation (FAR) Part 46, Quality Assurance; Department of Defense FAR Supplement (DFARS) Subpart and PGI 201.602-2 , Contracting Officer Responsibilities; Air Force FAR Supplement (AFFARS) Mandatory Procedures (MP) 5346-103, Contracting Office Responsibilities, The Quality Assurance Program; Air Force Instruction (AFI) 63-501, Air Force Acquisition Quality Program; AFI 63-138, Acquisition of Services; and organizational policy. It is designed to provide the Contracting Officer Representative (COR) a systematic surveillance method for each service identified in the Performance Work Statement (PWS) for each contract. The CN&GT Training Support Services (Training) ID/IQ Program Manager (PM) and Quality Assurance Manager (QAM) develop the methods for administering and evaluating the Indefinite Delivery/Indefinite Quantity (ID/IQ) and is accepted or rejected by the Contracting Officer (CO).

1.1 Purpose. This document defines the surveillance policy, procedures, and associated methods used by CORs for planning, preparing, performing, documenting, analyzing, and reporting Contractor performance. This QASP provides a systematic surveillance method to evaluate the products and services received from the Contractor and DOES NOT address the details of how the Contractor accomplishes the work.

1.2 Application: This QASP is used by all parties involved with assessing Contractor performance on the CN&GT Training ID/IQ contracts with the primary user being the COR. The Contractor may receive a courtesy copy at the discretion of the CO in order to further enhance communications, but is not part of the contract.

2.0 MANAGEMENT LOCATIONS AND KEY PERSONNEL.

2.1 CN&GT Management Locations.

2.1.1 Acquisition Management and Integration Center (AMIC). The mailing address for the CN&GT Program Management Office (PMO) is:

11817 Canon Blvd, Suite 306 Newport News VA 23606-4516

2.1.2 ACC AMIC Counter Narcotics and Global Threats Division (ACC AMIC/PMT). The CN&GT Training ID/IQ PMO and HQ ACC Management Team for HQ ACC requirements are also physically located at the address above, available via email at: amic.pmt.acq@langley.af.mil.

2.2 CN&GT Management Team.

2.2.1 CN&GT Program Management Office (PMO).

2.2.1.1 Contracting Officer (CO). CO duties are detailed in FAR subpart 1.602-2. The CO is the only Government agent authorized to award or modify contracts; therefore, the CO is the only person authorized to contractually obligate the Government. The CO is also the individual who will sign any notifications to Contractors regarding performance issues and accepts Government surveillance methods utilized for each TO. The CO approves and appoints CORs.

2.2.1.2 Contract Manager (CM). The CM is the Government agent within the contracting office who performs day-to-day contract administration. The CM can also be a warranted CO in some circumstances.

2.2.1.3 Program Manager (PM). The PM assists customers with defining and developing requirements, PWS modifications, deficiency resolution – basically, everything under the contract not required to be handled by a CO. The PM also acts as the Assessing Official Representative (AOR) for the CN&GT ID/IQ level Training Contractor Performance Assessment Reports (CPAR).

2.2.1.4 Quality Assurance Manager (QAM). The QAM is responsible for the CN&GT quality assurance program, to include management and execution, procedures and policies. The QAM provides policy and overarching guidance to the CORs and Delivery Assurance (DA) personnel. The QAM performs quality surveillance at the ID/IQ level, serving as the COR for the basic CN&GT Training ID/IQ contract, as well as being responsible for developing QASPs for all subsequent Task Orders (T/O) issued under the ID/IQ contract, ensuring proper execution at the T/O level. The QAM for CN&GT is also a QAPC and is the COR Branch Chief, thus the terms may be used interchangeably.

2.2.2 Contracting Officer Representative (COR). The COR is ultimately responsible for implementing all Quality Assurance (QA) matters and procedures. COR(s) should be at a level where other duties do not interfere with proper oversight of Contractor performance. The COR must maintain both technical competency and evaluation proficiency in Contractor surveillance procedures. The COR must also have enough knowledge of Contractor activities to properly review and disposition monthly invoices. The COR cannot assume duties until assigned by the requiring agency, completed COR required training (QAM and CO-led training), and appointed by the CO. For the CN&GT ID/IQ level contracts, the QAM serves as the COR.

2.3 Contractor Key Personnel. Reference applicable contract for a list of key personnel.

3.0 CONTRACT SURVEILLANCE. The COR function is responsible for a wide range of surveillance requirements that effectively measure and evaluate Contractor performance. The Contractor, not the Government, is responsible for contract management and Quality Control (QC) actions to meet the terms of the contract. However, because of the non-commercial nature of the work performed by CN&GT Contractors, the Government cannot rely solely on the Contractor’s quality program but must have a method to oversee the entire contracting process. The Government does this through the QASP and can inspect or test all services and deliverables called for by the contract, to the extent practicable, at all times, during the term of the contract. The COR contribution is comprised of professional, non-adversarial relationships, which include positive and open communications with the CO, PM, QAM, and the Contractor. The foundation of this relationship is built upon regular, objective, fair, and consistent COR evaluations of Contractor performance against contract requirements, and the ability to discuss inspection results, trends, and items of mutual interest with the Contractor. The COR uses the methods in this QASP and the PWS to achieve this goal.

3.1 Surveillance Methods. Three primary methods of surveillance will be used under the CN&GT Training ID/IQ contract: one hundred percent inspection, periodic audits, and customer complaints. Other methods of surveillance must be fully documented and approved by the CO and QAM before implementation. Information obtained from these activities may be used by the PM to ascertain whether or not Contractor performance is compatible with contract and mission objectives and by the CO for actions relating to the Contractor.

3.1.1 One Hundred Percent Inspection. This method will be used for Contractor submissions, products, and deliverables (tangible items). CORs will use the One Hundred Percent Inspection method to evaluate all reports delivered under QASP paragraph 3.2. The COR, with assistance from the PM and CO if necessary, accepts or rejects these products based on the criteria and performance standards as outlined in the Services Summary (both at the ID/IQ and T/O levels). The COR also documents all results of inspections actions, and subsequent Contractor re-performance taskings, if applicable.

3.1.2 Periodic Audit. This type of surveillance consists of evaluating products/services not surveilled via One Hundred Percent Inspection or by customer complaint, and is implemented at a pre-defined frequency. An example of periodic audit is performing monthly inspections of classroom training conducted by the Contractor or weekly inspection of a Contractor’s process / progress in developing training manuals. Desktop audits conducted remotely fall into this category.

3.1.3 Customer Complaint. Although usually not a primary method, this is a valuable supplement to other, more systematic methods of surveillance. Typically customer complaints can be used as substantiating evidence. All customer complaints will be forwarded to the CN&GT PM. Information obtained from customer complaint activities may be used by the CO for actions relating to the Contractor.

3.1.4 Random Sampling. Though typically not considered a type of surveillance, it is often part of the plan as to how the items (documents, equipment, records, etc.) will be audited to validate the Contractor is meeting requirements. Random sampling is especially useful when there are a large number of items to be audited.

3.2 Surveillance Documents.

3.2.1 Deliverables (ID/IQ PWS paragraph 3.5.4, Table 2). All deliverables will be reviewed for timeliness, accuracy and format. If a deliverable due date falls on a weekend or holiday, the Contractor shall submit the deliverable on the last work day prior to the due date.

3.2.2 Services Summary (ID/IQ PWS paragraph 3.6.3, Table 3). The Services Summary is a list of critical tasks that must be performed by the Contractor, the performance threshold, and the method of surveillance the COR will use to validate/inspect these tasks. Inspection of each task will be documented in the COR folder.

3.2.3 Surveillance Checklist. The COR is responsible for developing standard procedures for Surveillance Checklists; the Surveillance Checklist serves as the guideline for all inspections. As a minimum, the Surveillance Checklist will include the items in the Services Summary and Deliverables tables. The COR may also add other inspection activities/surveillance items to the Surveillance Checklist, with applicable PWS references, and obtain permission from the QAPC. These items may fluctuate throughout the course of the contract based on customer needs, identified risks, or issues related to Contractor performance. The COR will document all inspections conducted using the Surveillance Checklist and maintain them in the COR folder.

3.2.4 Contractor’s Quality Manual (QM). A Contractor's internal actions, in the form of a QM, are usually written to satisfy T/O requirements for written procedures or to provide direction on how Contractor employees are to perform. The QAM will review the Contractor’s QM upon delivery per ID/IQ PWS Table 2 to ensure compliance with proposed approach. Any deviations will be reviewed and may result in deficiencies/nonconformances, which will be handled IAW paragraph 3.3.3.

3.3 Assessing Performance. CORs must document Contractor performance on each contract, as well as the scope and purpose of any inspections. CORs will also assess and rate Contractor performance as it relates to contract requirements. Performance Assessment may take the form of notes, assessment results from the Surveillance Checklist, nonconformance notifications, and annual CPARs. Each builds on the other and provides a thorough documented history of Contractor performance.

3.3.1 Initial Contract Performance Review (ICPR). IAW AFI 63-138, Chapter 6, Para 6.4, the initial evaluation of Contractor performance is a joint determination by the multi-functional team (MFT) that the Contractor has successfully started performance, completed transition, is fully operational, and is within the estimated cost, schedule, and performance parameters of the contract. The ICPR shall take place within 30 days after the Contractor assumes full performance responsibility (for your purposes - after contract start). The results of the ICPR shall be documented on the ICPR template Quality Management System Template (QMST) 4.2.4-8 located on the AMIC Quality Assurance SharePoint site. For all contracts, which are >$100M, the ICPR report shall include an assessment of schedule, management, technical, and cost performance. Negative variations in cost, schedule, staffing, and performance shall be reported with an assessment of the root causes and corrective action plan. What does this mean to you? Your responsibility is to ensure that whatever the Contractor put in its respective proposal that we the Government included as part of the contract (most O&M contracts include the Contractor’s entire proposal as an Appendix to the PWS) is reviewed. For instance:

· Has the Contractor started performance? (There are usually deliverables due to the Government within the first 30-days, e.g., CDRL.)

· How is the Contractor meeting the Transition Plan?

· Is the Contractor on track with schedule and milestones?

· Where does the Contractor stand in regards to its QMS?

· Have all personnel been hired? If not, are operations impeded?

These questions must be asked and reported. Use reports that have already been accomplished as examples, located on the DRQ SharePoint, embedded in the Monthly Activity Reports (MAR). Report contract performance assessment values in the following method:

· Red - Issue(s) with inadequate or no Contractor mitigation or corrective action plan; any "red" assessment shall include the Contractor's proposed mitigation plan and corrective actions for noncompliance (changed based on our AFI 63-138 review)

· Yellow - Issue(s) but Contractor has adequate mitigation or corrective action plan in place

· Green - No issues Additionally, any significant modifications to the contract made since contract award shall be included in the initial performance report as special interest items (SII).

3.3.2 Inspections. The COR may perform inspection/surveillance at any time during contract performance IAW FAR 252.246-2 through -5, as applicable. The COR will retain all audit and inspection documentation until contract closeout, unless otherwise approved by the CO.

3.3.3 Nonconformances and Deficiencies. Audit or Inspection results that fall below contractual standards shall be identified as nonconformances or deficiencies. The COR will notify the contactor IAW para 3.3.3.2 and document all nonconformances, referencing the specific ID/IQ or T/O requirement that the Contractor did not meet.

3.3.3.1 Types of Nonconformance. See ID/IQ PWS paragraph 3.4.2 and subparagraphs.

3.3.3.2 Nonconformance Notification. If a deficiency is found during inspection of the Contractor’s performance, the COR will determine the type of notification based on the category of the nonconformance (see Table 1 below) and pursue nonconformance resolution per paragraph 3.4.

TABLE 1 – NONCONFORMANCE NOTIFICATIONS

Minor

Step 1: First Notice Step 2: Second Notice

3.3.3.2.1 First or Second Notices (see Attachment 1). As shown in Table 1, First and Second Notices provide written notification from the Government to the Contractor of minor nonconformances. Initial minor nonconformances should be addressed with a First Notice to the applicable Contractor representative. If the Contractor fails to respond by the specified due date, the COR will review the circumstances and may issue a second notice and ultimately a CAR if the Contractor fails to resolve the issue. Corrective/preventive actions initiated and/or completed by the Contractor will be verified by CORs on the scheduled inspection and documented accordingly.

3.3.3.2.2 Corrective Action Requests (CAR) (see Attachment 2). As shown in Table 1 above, a CAR provides written notification from the Government to the Contractor of significant performance discrepancies. The COR will complete a CAR and provide to the CO for consideration for issuance to the Contractor. The draft CAR will be routed to the CO for review and signature, as the CO is the only person who has authority to issue a CAR to the Contractor unless the CO determines the COR may issue.

3.3.3.2.2.1 To satisfactorily close-out a CAR, the following criteria must be met:

· The Contractor must meet the suspense;

· The corrective action must have already begun; and

· The Contractor's actions must correct the deficiency and if applicable, be within specified standards

3.3.3.2.2.2 If the corrective action does not provide effective planned or complete actions to meet PWS requirements, the COR (to include coordination with the PM, CO, SME(s), as required) will annotate the CAR accordingly and forward it to the CO with a brief explanation, including an estimate of the Government's loss due to the deficient performance. The estimate may account for loss or destruction of property, supplies, or equipment, and hours lost to re-perform the task. If the task cannot be re-performed, indicate the number of hours it ordinarily would have taken to do the task.

3.3.3.2.3 The COR will maintain a nonconformance log documenting all First and Second Notices and CARs. A template for this log is available on the Quality SharePoint site.

3.3.4 Monthly Services Summary Reporting. CORs will perform Services Summary inspections (see paragraph 3.2.2).

3.3.5 Annual Contract Performance Assessment Reporting System (CPARS) – The CPARS http://www.cpars.csd.disa.mil/cparsmain.htm ) is the Department of Defense (DoD) Enterprise Solution for collection of Contractor Past Performance Information (PPI) as required by the Federal Acquisition Regulation (FAR). CPARS is a web-enabled application that collects and manages a library of automated Contractor report cards. An annual CPAR will be written on all CN&GT ID/IQ contracts and all CN&GT T/Os that exceed $1M total contract value (or threshold established by the DoD CPARS Guide). The PM on the ID/IQ contracts will be designated as the AOR in CPARS; the written assessment in CPARS will begin annually from the start date of the contract and forwarded to the CM within 60 days of the contract start date anniversary. The COR will provide the CN&GT PM objective evidence from the Services Summary, inspection logs, 1st/2nd notices, CARS, and correspondence letters for CPARs assessment. A CPARS quality checklist is available at: http://www.cpars.csd.disa.mil/cparsfiles/pdfs/CPARSQualityChecklist.pdf.

4.0 WIDE AREA WORK FLOW (WAWF). The COR or PM (or designated representative) will accept or reject all Receiving Reports submitted by the Contactor in WAWF within 7 days of submittal by the Contractor. To access the receiving report, log into WAWF, select the Government, Acceptor, Acceptance Folder tab; then type in the contract and delivery order (T/O) number. The Shipment Number column in WAWF is the Receiving Report number.

4.1 Validating Receiving Reports. The COR or PM will review and validate all WAWF receiving reports (Shipment Number in WAWF) using the CN&GT Checklist available on the PMT shared drive.

4.2 Certifying and Accepting Receiving Reports.

4.2.1 Certification. Certification of services is performed by the appointed COR or PM. After validation of services is performed by the COR per paragraph 4.1 above, the COR or PM will select the “Accepted and conforms to the contract except as noted” box, enter the dates, and then select “Certificate Signature” to complete the acceptance.

4.2.2 Expenditure Log. After certification of an invoice in WAWF, the COR, PM or designated representative will update the expenditure log documenting/tracking certified invoice expenditures against funds allocated on the contract against each Contract Line Item Number (CLIN). In lieu of a log, CMS may be used to track CLIN expenditures and remaining values.

4.3 Rejecting Receiving Reports. If a receiving report is rejected in WAWF, the COR will go to the Miscellaneous Info tab to complete the comments block as follows:

· List details regarding all unsatisfactory services or incorrect invoice information

AND

· Instruct the Contractor to contact applicable Defense Finance and Accounting Service (DFAS) office to have the invoice rejected back to the Contractor; this will allow the Contractor to make the same correction on both the receiving report and invoice, if required

The rejecter will then return to the Header tab and click the “Reject to Initiator” block.

5.0 COR FOLDER. The COR will establish and maintain a COR folder for each contract. The COR folder should contain contents outlined below in Table 2; however, the files or a portion of the files can be combined with the PM’s and/or contract files to avoid duplicated efforts. Note that designation and training documents are typically maintained in the Contract Management System (CMS). ALL surveillance records are considered For Official Use Only documents, and must be safeguarded as such. Documentation is kept for the life of the contract and provides necessary continuity should COR duties transition during the course of the contract. The COR will receive instructions from the CO on disposition or archival procedures upon contract completion.

TABLE 2 – COR FOLDER CONTENTS

General Correspondence

COR Designation Letter(s) Typically maintained in CMS Assignment/nomination letter(s), appointment letter(s) and Government/Contractor relationships guidance

COR Training Typically maintained in CMS Training certificates for Defense Acquisition University (DAU), QAPC-led and CO-led training

Attachment 2 Corrective Action Request (CAR) Template

(Date) MEMORANDUM FOR (Contractor, ATTN: Contractor POC)

FROM: ACC AMIC/DRQC Contracting Officer’s Representative

SUBJECT: First/Second Notice for (brief name for nonconformance)

1. Contracting Officer Representative: (First Last)

1. Office: ACC AMIC/DRQC

1. Control Number: (Digits 1-4 = ID/IQ Contract Number (last 4 identifying each prime); Digits 5-8 = T/O number; digits 9-12 = YYMM; digits 13-15 = three digit sequential number starting over at "001" each month; digit 16 = nonconformance levels (-1, -2, -CAR). For example: 000100051510003-1 indicates prime, T/O 0005, 2015, October, third nonconformance, first notice). Please note; if a notice is issued against the ID/IQ contract digits 5-8 are dropped.

1. Date of First or Second Notice: (dd-mm-yyyy) (If issuing a second notice include the date of the first notice

1. Reference and Text: (PWS section and paragraph; Deliverable, Services Summary (SS), or email and associated text)

1. Description of Nonconformance: (provide objective evidence of the Contractor’s performance discrepancy(ies))

1. Date response due from Contractor: (dd-mm-yyyy)

1. Contractor POC: (Mr./Ms. First Last)

1. Contractor’s Corrective Action: (Please explain what your company will do to correct the nonconformance and prevent reoccurrence)

1. COR Review (COR comments to reply):

1. Date Closed: (dd-mm-yyyy)

(COR signature block)

CORRECTIVE ACTION REQUEST (CAR)

TORP0XXX-XX-XXXX-XXX-CAR

3. Date:

Click here to enter a date.

4. Contract & TO/DO Number i.e. FA4890-15-0000

5. Issued To:

Insert Contractor

6. Date Action Plan is Required: Refer to CO Letter

Describe the nonconformity. Use continuation sheet if necessary. Attach or embed any relevant records, documents, or evidence.

7. What is the nonconformity (Provide a brief statement summarizing the finding):

(1-2 Sentences)

8. Requirements (Include Contract, (proposal if applicable), TO, Commercial Publications, and similar references. Additionally, include all Contractor Operating Instructions, Work Instructions, and similar references. Include excerpts from the references to substantiate the nonconformity):

9. Objective Evidence (Record objective evidence of the non-conformity. Include pictures, records, documents to substantiate):

Detailed Description

10. Risk Rating: (This Risk Rating is for the initial finding. State the probability (likelihood) of reoccurrence and the resultant impact (consequence) to the mission/program. Select appropriate drop down item for the likelihood and consequence of the nonconformity.)

Please click “Unlock Ratings to enable drop downs. Once you have selected the “Likelihood” and “Consequence” ratings, click “Lock Ratings” to lock selections (ratings should turn a light gray color).

LIKELIHOOD

CONSEQUENCE

RISK LEVEL

11. Action Plan (As a minimum, this plan shall include elements a – f as listed below. Use this space for all responses to include follow up responses.

a. Action taken to fix the problem (correction)

b. Root cause(s) analysis of the problem.

- Determination of whether other processes are affected by the identified root cause(s)

- Determination of whether other products/services are affected by the root causes(s), including product already delivered

c. Corrective action on the root cause of the problem

d. Action(s) taken to prevent recurrence to include the follow-up plan (how and when)

e. Action(s) required by the Contractor’s Quality Manual

- Action taken to correct the weakness which allowed deficient products/services to be provided to the government

f. All supporting evidence to support actions taken such as updated manuals, instructions, procedures, etc. (embed in this section to maintain a single point document unless size is restrictive or security policies prevent embedding. In these cases, provide location of these documents)

This is an auto-expanding field, use as much space as necessary.

12. Evaluation of Action Plan (If multiple responses are required due to partial or non-acceptance, include date of each evaluation/verification):

Fully evaluate the action plan to include all attachments.

CAR CLOSE-OUT (Initials and Date)

image2.png image3.jpeg image4.png image5.wmf image6.wmf image7.wmf image8.wmf image1.jpeg