PBM_Attachment_3__QASP.docx

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

For

United States Air Force Headquarters (HAF) Pharmacy Benefits & Durable Medical Equipment Management Services (Program)

AUGUST 2014

TABLE OF CONTENTS

Page

9.0 ATTACHMENTS

ATTCH 1: MONTHLY PERFORMANCE REPORT/CERTIFICATE OF SERVICE……11

ATTCH 2: PERFORMANCE EVALUATION REPORT…………………………………14

ATTCH 3: CORRECTIVE ACTION REPORT (CAR)…………………………………

1.0 OVERVIEW

1.1 Purpose. This performance plan prescribes how the Contracting Officer’s Representative (COR) will assess the contractor’s performance and manage the acquisition throughout its life cycle. The team’s goal is successful contract performance. This plan addresses both Performance Management and Performance Assessment.

1.2 Performance Management. Performance Management is a cradle-to-grave process beginning with the identification of the requirement and ending when the service is completed or a follow-on acquisition begins. The performance management section outlines how the Contracting Officer’s Representative is going to manage the contract.

1.3 Performance Assessment. Performance assessment is evaluating, assessing and documenting the contractor’s performance in accordance with the overall performance plan. The performance assessment section identifies the methods and procedures the Government will use to ensure it receives the services under contract and how performance information will be documented for use as past performance information.

2.0 DESCRIPTION OF SERVICES. The contractor shall be expert, experienced and specialized in federal workers compensation, to support the AF Pilot PBM Program. The pilot PBM Program will be supported in principle by the Office of Workers’ Compensation Programs (OWCP), Department of Labor (DOL). The pilot PBM Program will be an AF wide program for AF employees who are injured on the job, require prescription medications, durable medical equipment (DME) (walkers, crutches, canes, splints, muscle stimulators, etc) and ancillary services (Magnetic Resonance Imaging (MRI), Computerized Tomography Scans (CT), X-Rays, Electromyogram (EMG), Nerve Conduction Velocity (NCV), and other related tests. The function of the PBM is to provide a more efficient way for employees who are injured on the job to obtain the services they need, eliminate any out-of-pocket expenses and the need to save receipts or file reimbursement forms, and provide a convenient mail order option

3.0 DUTIES AND RESPONSIBILITIES

3.1 Contracting Officer’s Representative (COR).

3.1.1 The COR is responsible for the performance management on this acquisition. Provides continuous oversight of the contractor’s performance throughout the life of the requirement, ensures the program is within cost and schedule and reports to executive leadership. The COR is the first element of performance management. A COR is established and meets on a regular basis, with the Contracting Officer (CO) and other members of the multi-functional team. The COR will manage contract performance with the goal of achieving cost savings, performance efficiencies and improved customer service. The COR is responsible to ensure the acquisition requirements are met on schedule and within budget during the requirements lifecycle. The COR will identify and report any significant performance deficiencies to the CO. Responsibilities of the COR include:

3.1.2 Processes, maintains and updates quality assurance appointment/delegation memos.

3.1.3 Serves as the focal point for CO performance assessment activities. Ensures performance assessment is evaluated and documented in accordance with (IAW) this plan.

3.1.4 Monitors, assess, records and reports on contractor compliance with the terms and conditions of the contract.

3.1.5 Manages contractor performance assessment data and prepares the annual Contract Performance Assessment Reports (CPARS) evaluation if applicable.

3.1.6 Collects and documents all contractor deficiencies, analyzes them for recurring instances and monitors all corrective actions. Reviews and presents for discussion at COR meetings.

3.1.7 Attends COR meetings and recommends to the CO any needed improvements to the performance work statement and the quality surveillance plan.

3.1.8 Observes contractor performance and provides current, accurate information and assessment.

3.1.9 Maintains accurate documentation of contractor performance assessment in accordance with the QASP.

3.1.10 Prepares Monthly Performance Report/Certificate of Service and provides to CO.

3.1.11 Manages contract performance IAW the QASP.

3.1.12 Develops and fosters partnerships for the common goal of continuous improvement. Establish effective communication with the contractor for the overall good of the contract.

3.1.13 Identifies opportunities to improve performance throughout the life of the contract. Implement changes to make these goals a reality.

3.1.14 Develop Performance Objectives and any other assessment items for periodic performance assessment.

3.2 Contracting Officer (CO).

3.2.1 The CO has overall responsibility for overseeing the contractor’s performance in the areas of contract compliance, contract administration, review the OCR assessment of the contractors’ performance, and serves as the liaison between the COR and the contractor. The CO is responsible for ensuring performance of all necessary actions for effective contracting; ensuring compliance with the terms and conditions of the contract, safeguarding the interests of the United States, ensuring that contractors receive fair, impartial, and equitable treatment and requests and considers the advice of government functional experts as appropriate. The CO has the authority to resolve disputes or conflicts.

3.2.2 Ensures the contractor is performing their duties under the contract terms, makes interpretations of and changes to the contract.

3.2.3 Delegates authority for inspection and/or acceptance IAW terms of the contract. Informs the contractor of the names, duties, and limitations of authority for all COR(s) assigned to the contract.

3.2.4 Conducts COR training for all CORs before they perform quality evaluation duties .

3.2.5 Inputs contract registration data into the Contractor Performance Assessment Reporting System (CPARS) database within 30 days of contract award. Ensures CPARs are completed as required (primary POC is contract specialist).

4.0 PERFORMANCE MANAGEMENT

4.1 Performance Management. Performance is managed by a multi-tiered approach including the day-to-day management performed by the COR, periodic Performance Management Reviews for executive leadership, and compilation and submission of the Contractor Performance Assessment Report.

4.2 Contractor Performance Assessment Report. The CPAR assesses a contractor’s performance and provides a record, both positive and negative, on a given contract for a specific period of time. Each assessment is based on objective facts and is supported by contract management data, performance management data, and performance assessment data. Data is entered into the web-based CPARS.

5.0 PERFORMANCE ASSESSMENT

5.1 Purpose. Performance Assessment detailed in this plan focuses on the performance outcomes required by the Performance Work Statement (PWS) not the methodology or process implemented by the contractor. The objective of this plan is to rely on the Contractor’s Quality Contract Personnel (QCP) for quality control, effectively changing the Government’s role from “oversight” to “insight”. This plan identifies the methods and procedures the Government will use to ensure it receives the services under contract as identified in the PWS.

5.2 Approach. The approach is to gain confidence in the Contractor’s ability to provide satisfactory services through on-site assessment by the COR and analysis of performance reports and metrics. The level of assessment and approach may be adjusted as needed to maintain confidence based upon the Contractor’s performance.

5.2.1 The key elements of this process are the Contractor’s QCP complimented by the Government’s assessment of Performance Requirements.

5.2.2 Performance Requirements listed in this plan are based upon the Services Summary in the PWS. The performance objectives establish performance thresholds as the minimum acceptable quality level of performance that must be assessed, documented and reported by the COR.

5.2.3 Use of Metrics Metrics will be used wherever possible to track contractor progress in meeting Performance Requirements. Metrics may be contractor or government generated. Required contractor metrics are identified at paragraph 2.0 of the PWS and must be submitted with the monthly status report.

6.0 SERVICES SUMMARY (SS)

6.1 The purpose of the SS is to set Contractor performance objectives and acceptable thresholds of performance and to provide objective measurement of the Contractor’s performance.

6.2 The SS must cite the performance objective (or service required) and the threshold (specific standard) required. The SS should align the contractor’s performance with the contract performance objectives and focus on critical factors in meeting those objectives. The goal of the SS is to promote continuous improvement in performance.

6.3 The functional area is responsible to develop an individualized Performance Monitoring Plan supplement for each contract generated. The supplement shall contain a SS that captures performance objectives and standards/thresholds specific to contract requirements.

6.4 Services Summary.

Periodic Inspection

Negotiate own contract with pharmacies and providers that generate a discount for generic and brand named drugs, DME and ancillary services at a rate below FECA fee schedule

7.0 PERFORMANCE ASSESSMENT AND REPORTING REQUIREMENTS.

7.1 Monthly Assessment. The COR will monitor the Contractor’s performance monthly as it relates to the performance thresholds set forth in the SS. The results will be documented on the Monthly Performance Report/Certificate of Service (MPR/COS) (Attachment 1) and forwarded to the Contracting Specialist and CO by the tenth working day of the month.

7.2 Assessment Method. The Contractor’s performance will be monitored using the following method:

Periodic Inspection. There are some contractual requirements that the COR will evaluate the contractor’s performance using the periodic review method of surveillance. The COR will evaluate all of the scheduled inspections. Defects will be recorded. The Contractor Representative will be given time to correct the unacceptable performance. The COR will ensure the contractor has taken appropriate action(s) to prevent the recurrence of defects. Recurring defects are not permitted for any of the service items. It a repeat defect is received indicating the same deficiency during the service period (monthly), the COR should contract the Contracting Officer for appropriate actions.

The report shall indicate what methods of assessment were used that month and shall detail the strengths, weaknesses and any areas where the Contractor does not meet contract requirements.

7.3 Performance Ratings. The COR shall assign an overall rating for the month. Definitions of ratings are as follows:

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 was highly effective.

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 was effective.

SATISFACTORY: Performance meets contractual requirements. The Contractor’s performance has been satisfactory and any corrective actions taken by the Contractor are acceptable.

MARGINAL: Performance does not meet some contractual requirements, or re-performance was necessary due to contractor negligence. The Contractor’s proposed corrective actions appear only marginally effective or was not fully implemented.

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 contains serious problem(s) for which the Contractor’s corrective actions were ineffective.

7.4 Certificate of Service. The Certificate of Service section of the monthly report provides the CO with verification that all services and products were provided to the Government IAW all contract and contract requirements, as well as confirming the Contractor’s invoice has been reviewed and accepted for payment.

7.5 Contractor Performance Assessment Reporting System. The COR shall assist in preparing the annual CPARS report. The COR shall complete the Performance Evaluation Report at Attachment 2 at least annually during the contract period of performance and again at the completion of the contract. Copies of all Performance Evaluation Reports shall be forwarded to the PCOR and will serve as supporting documentation for the contractor’s annual assessment.

7.6 Performance Deficiency Resolution. If discrepancies are found during contract performance, the COR shall notify the contractor’s Team Lead immediately upon discovery. Whenever possible, performance deficiencies should be resolved at the lowest practical level. The COR shall determine the type of deficiency notification to issue based on the severity of the deficiency. The Performance Assessment folder shall be documented to reflect the type of notification issued, the name of the individual contacted and date of notification.

7.6.1 Performance Deficiency Notification. There are three types of notification: verbal notification, written notification and Corrective Action Report (CAR).

7.6.1.2 Verbal notification is primarily used for minor discrepancies or tasks that can be re-performed.

7.6.2.2 Written notification is used when verbal notification does not result in correction or whenever the COR feels that written documentation is necessary. The notification will contain the statement, “Notice to Contractor: Failure to correct may result in a CAR.”

7.6.2.3 A CAR will be issued by the COR when previous notifications failed to result in corrective actions or when severe deficiencies exist. The CAR will be forwarded to the CO through the COR for action.

7.7 Timely Feedback to the Contractor. The COR will provide timely feedback regarding any deficiencies or substandard work for contractor corrective action. Performance Evaluation Reports to support the annual CPARS assessment shall be provided to the contractor when completed. A performance evaluation meeting shall be held at least quarterly to review performance and contract issues. Required attendees at the monthly meeting shall be the AFPC/DPITA Branch Chief, the Government Program Manager/CQAE, the Contracting Officer and the Contractor’s Team Lead.

8.0 DOCUMENTATION REQUIREMENTS

8.1 Federal Acquisition Regulation (FAR) 46.401 states the Government has the responsibility to ensure services conform to contract quality requirements. Records are to be maintained of actions taken to verify services conform to contact quality requirements, to include the method used to assess the contractor’s performance, type and number of deficiencies found as well as actions taken to correct deficiencies.

8.2 COR File. The purpose of the COR Folder is to have a central point to file and maintain documentation relating to performance assessment.

8.2.1 Contents. A COR Folder must be developed and maintained by each COR. The folder may be maintained in hard copy, electronic format or any combination thereof provided there is adequate backup of the data to preclude accidental loss. The folder must contain the following sections and may contain other sections or information the folder owner finds necessary.

8.2.1.1 Section 1. Appointment Letters. This section must include:

a. The primary and alternate COR’s nomination letters.

b. The primary and alternate COR designation/appointment letters.

c. The primary and alternate COR’s training certificates.

8.2.1.2 Section 2. Contract and Performance Work Statement

8.2.1.3 Section 3. A copy of the contract Performance Plan and applicable contract Performance Monitoring Plan supplement(s), as appropriate/applicable.

8.2.1.4 Section 4. Activity/Correspondence. Documentation of meetings or communications (written or email) with the Contractor regarding contract performance.

8.2.1.5 Section 5. Records. Documentation of all contractor performance assessment. This section shall contain completed Monthly Performance Report/Certificate of Service forms, completed Performance Evaluation Reports and any Corrective Action Reports issued to the Contractor.

8.3 Disposition of Performance Monitor Folder. Upon completion of contract performance or in the event of COR departure, the Quality Assurance folder shall be submitted to the CO.

Attachment 1

MONTHLY PERFORMANCE REPORT/CERTIFICATE OF SERVICE

Contract Title:

Contractor Team Lead:

Method of Performance Evaluation

· At least every month, performance will be evaluated by using one or more of the methods checked below. Check all that apply or may be used if deeper levels of scrutiny is required.

RATING: |_| Exceptional |_| Very Good |_| Satisfactory |_| Marginal |_| Unsatisfactory

TRAVEL: Date______ Destination________________

INVOICE APPROVAL:

________ Hours and travel billed under Invoice # __________ are accepted.

________ Invoice not yet received for this service period.

________ ODC’s billed were approved IAW contract requirements and accepted.

(COR signature)

NARRATIVE

1. SPECIAL CONDITIONS: (Describe any special conditions, which may have influenced contractor monthly performance. Special conditions may include aspects of the technical, economic, and schedule environment under which the contractor was required or unable to perform and the effect they had on contractor performance).

2. CRITERIA:

Technical Performance:

Program Management:

Personnel Attraction/Retention:

Security:

Cost Management:

Special Interest (if applicable):

3. DEFICIENCIES:

4. AREAS FOR IMPROVEMENT:

5. ADDITIONAL COMMENTS:

INSTRUCTIONS

1. Special Conditions. Describe any special conditions that may have influenced contractor monthly performance. Special conditions may include aspects of the technical, economic, and schedule environment under which the Contractor was required to perform and the effect they had on contractor performance. If any action initiated by the Government or outside source results in the Contractor’s inability to perform requirements of the contract SOW it shall be considered a special condition. The Contractor shall not be held accountable for conditions that are outside of their control.

2. Criteria. Describe the Contractor’s performance relative to each of the Service Delivery Summary areas (as applicable). Include strengths, weaknesses, and performance trends (i.e. worsening, steady, and improving). Describe any corrective actions that are being planned or taken, as appropriate.

3. Deficiencies. Identify contractor performance deficiencies. Discuss any areas where repeated government intervention was required, particularly if such intervention still failed to resolve the problem.

4. Areas Needing Improvement. Describe any areas where the Contractor needs improvement, follow-up, etc. Be specific; cite areas that could result in potential negative impact to the contract execution if not appropriately addressed. Indicate the Contractor’s progress in showing demonstrated performance improvement, as applicable, from previous monthly reports.

5. Additional Comments. Identify any areas of notable achievement or areas where the Contractor exceeds contract requirements, particularly if resulting in cost, time, energy, or process-related savings to the government.

Rate the task output and not the individual contractor employee to avoid any appearance of personal services or individual preference on the part of the government. Document the Contractor’s performance against the contract/contract requirements only, not status, employee names, individual employee accomplishments or your “opinion” as a government COR. Use the “insight” approach to performance assessment unless a deeper level of scrutiny is warranted.

Attachment 2

PERFORMANCE EVALUATION REPORT

Contract Number ______________________ Customer’s Organization ___________ Contract Title__________________________________________________________

Review Type (circle one) QUARTERLY END OF TASK

This report is used to evaluate the contractor quarterly during and at the end of each task. In addition to providing verification that performance thresholds are being met, the ratings and comments provided on this checklist help to determine the contractor’s annual CPARS ratings.

The ratings used will be as follows: Exceptional (E), Very Good (VG), Satisfactory (SAT), Marginal (MAR) and Unsatisfactory (UNSAT). Ratings will be in accordance with the definitions described in the Performance Plan section 4.4.3.1. N/A (not applicable) should be used if the ratings are not going to be applied to a particular area for evaluation.

AREA OF EVALUATION: QUALITY OF PRODUCT OR SERVICE. Assess the contractor’s conformance to contract requirements, specifications and standards of good workmanship Did the work performed satisfy technical requirements/stated objectives? Was the work professional and did it meet standards?

E VG SAT MAR UNSAT N/A

Comments:

Were written deliverables clear, concise, correctly formatted and did they meet grammatical, spelling and punctuation standards? Were reports/data accurate?

E VG SAT MAR UNSAT N/A

AREA OF EVALUATION: SCHEDULE. Assess the timeliness of the contractor against the completion of the contract, milestones, delivery schedules and administrative requirements.

1. Was the work timely? Did the contractor meet deadlines and scheduled milestones?

E VG SAT MAR UNSAT N/A

2. How does the contractor rate in terms of quick response to tight deadlines and/or contingencies?

E VG SAT MAR UNSAT N/A

3. Are deliverables completed in a timely manner?

E VG SAT MAR UNSAT N/A

Comments:

AREA OF EVALUATION: COST CONTROL. Assess the contractor’s effectiveness in forecasting, managing and controlling contract cost.

Does the contractor keep within the total estimated cost?

E VG SAT MAR UNSAT N/A

Did the contractor do anything innovative that resulted in cost savings?

E VG SAT MAR UNSAT N/A

Were billings current, accurate and complete?

E VG SAT MAR UNSAT N/A

AREA OF EVALUATION: BUSINESS RELATIONS. Assess the integration and coordination of all activity needed to execute the contract, specifically the timeliness, completeness and quality of problem identification, corrective action plans and the contractor’s history of reasonable and cooperative behavior.

1. Is the contractor oriented towards the customer? Was the contractor responsive to customer/COR requirements?

E VG SAT MAR UNSAT N/A

2. Is the contractor proactive in problem identification and resolution?

E VG SAT MAR UNSAT N/A

AREA OF EVALUATION: MANAGEMENT OF KEY PERSONNEL. Assess the contractor’s performance in selecting, retaining, supporting and replacing, when necessary, key personnel.

Did the contractor provide key personnel that demonstrate leadership, initiative and technical expertise for successful contract completion?

E VG SAT MAR UNSAT N/A

2. Did the contractor provide guidance and support key personnel so they were able to work effectively?

E VG SAT MAR UNSAT N/A

3. If a replacement for a key person was necessary did the replacement meet or exceed the qualifications needed for the position?

E VG SAT MAR UNSAT N/A

Did the contractor comply with applicable portions of the DD Form 254? Y/N

COR Signature

Attachment 3

CORRECTIVE ACTION REPORT (CAR)

CORRECTIVE ACTION REPORT (CAR)

(If More Space is Needed Use Reverse and Identify By Number)

1. CONTRACTOR

2. CONTRACT NUMBER

3. TYPE OF SERVICES

4. FUNCTIONAL AREA

5. SUSPENSE DATE

6. CONTROL NUMBER

7. MAJOR |_|MINOR |_|

FINDING:

FINDING IMPACT:

Please respond with a written corrective action plan that details the corrective action of the cited deficiency, the cause of the deficiency, and actions taken to prevent recurrence by Suspense Date in Block 5.

8. CONTRACTING OFFICERS REPRESENTATIVE (COR)

TYPED NAME AND GRADE

SIGNATURE AND DATE

9. ISSUING AUTHORITY

TYPED NAME AND GRADE

SIGNATURE AND DATE

10. COR RESPONSE TO CONTRACTOR CORRECTIVE ACTION AND ACTION TAKEN TO PREVENT RECURRENCE

11. CONTRACTOR RESPONSE

|_| ACCEPTED |_| REJECTED

12. CLOSE DATE

CAR Instructions

Block 1. Enter Contractor Name Block 2. Enter Contract Number

Block 3. Enter Contract Name or Type of Service Block 4. Enter Functional Area of the Contract

Block 5. Enter the assigned suspense date given the contractor to provide a response to the CAR.

Block 6.

a. All CARs will be tracked with a Control Number.

b. The PCOR or designee is the Issuing Authority for all CARs.

c. The control number will be made up of the contract number; the last two digits of the calendar year and a three digit number starting with 001 and progressing upward throughout the calendar year.

d. The COR will attach all CARs to their performance evaluation report.

Block 7. Check the block that indicates whether the identified deficiency is a Major or Minor finding. Definitions of Major and Minor findings are as follows:

Major Finding. A condition having a significant adverse effect on the quality of the activity under review such as:

a. Failure to meet a Performance Threshold

b. Significant mission degradation in any contractor operated function.

c. A situation that is likely to result in hazardous or unsafe conditions for individuals or any other Government resources coming into contact with the work.

d. Failure to provide adequate corrective action to preclude reoccurrence of Government identified findings.

e. Failure to provide corrective action to deficiencies identified within a prescribed suspense period.

f. Any failure to adhere to security regulations that results in a security incident.

Minor Finding. A departure from established standards having little bearing on service provided. However, if the same minor finding is repeatedly identified, it may be an indication that a major finding is occurring (failure to provide adequate corrective action to prevent reoccurrence of findings). In this case, the minor finding should be elevated to the level of a major finding and a new CAR initiated.

Clearly state the details of the finding followed by a reference to the stated contractual requirement. The reference must state the portion of the contract, part, section, paragraph and subparagraph and must make a brief but complete quotation of the contract reference.

State the impact that the finding has or could have on mission accomplishment.

Normal suspense time for contractor response is ten working days.

Block 8. The COR initiating a CAR signs and dates the report.

Block 9. The COR or designee signs and dates the report.

Block 10. Upon review of the contractor’s reply, the initiator of the CAR will enter comments regarding acceptance or rejection of the contractor’s response. This block may also contain any comments regarding follow-on inspections conducted or needed at a later date to validate that the finding has not reoccurred.

Block 11. The COR accepts or rejects the contractor’s response.

Block 12.

a. The COR enters a close out date after acceptance of the contractor’s response.

b. The COR will forward the CAR to the contractor. The COR will attach copies and record results of any reports in the Monthly Performance Report/COS. Copies of completed CARs will be maintained in the Performance Assessment folder.

If a CAR is not deemed closeable due to incomplete or unacceptable contractor response, the CAR will be returned to the contractor for additional information.

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