Attachment 3 - Amended QASP.pdf

SECTION J - LIST OF DOCUMENTS, EXHIBITS AND OTHER ATTACHMENTS

SECTION J, ATTACHMENT 3 – QASP

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

LANGUAGE & CULTURAL SERVICES

CONTRACT

H92222-11-D-0009

TABLE OF CONTENTS

CHAPTER PAGE

Introduction 2

1. Contract Synopsis 2

2. Acronyms 3

3. Objective 3

4. Goals of the Multi-Functional Team 3

5. Roles and Responsibilities 4

6. Performance Assessment 5

7. Performance Management 6

8. Multi-Functional Team membership 7

9. Quality assurance surveillance plan Surveillance Procedures 7

10. Summary of the Contractor’s Required Level of Quality 7

11. Summary of the Government Quality Assurance (QA) Mgmt System 8

12. Performance Measurement 8

13. Contract Surveillance 9

14. Quality Assurance Management System Documentation 10

15. Acceptance of Services 11

16. Quality Assurance Monthly Report 11

17. Memorandum for Record 11 Quality assurance surveillance plan Addendum 1a – Sample Monthly Progress Report (Excel portion) Quality assurance surveillance plan Addendum 1b – Sample Monthly Progress Report (Word portion) Quality assurance surveillance plan Addendum 2– Sample Student Progress Report Quality assurance surveillance plan Addendum 3 - Sample Resume Quality assurance surveillance plan Addendum 4 –Surveillance Guide Quality assurance surveillance plan Addendum 5 -Classroom Evaluation Checklist

INTRODUCTION

This Quality Assurance Surveillance Plan (QASP) is designed to assess and document Contractor performance in accordance with the requirements set forth in the Government Performance Work Statement (PWS), as well as to provide the Quality Assurance Personnel (QAP) an effective and systematic surveillance method to evaluate the services the Contractor is required to furnish and not the details of how the Contractor accomplishes the work. In addition, this Quality assurance surveillance plan implements the Multi-Functional Team (MFT) concept. The signatures attached on the charter signature page indicate membership in the MFT.

The Quality assurance surveillance plan is based on the premise that the Contractor and not the Government is responsible for management and quality control actions to meet the terms of the contract and allow the Contractor to operate within the specified performance requirements. The role of the Government is to ensure the terms of the contract are met.

1. SYNOPSIS OF THE CONTRACT

1.1. Contract Type: This contract will have firm-fixed pricing for overall language instruction and cultural awareness in accordance with the Performance Work Statement of the contract and task orders issued. A firm-fixed priced CLIN is established on the basic contract that shall include instructor-hours and tutoring hours as required per task order. A cost reimbursable contract line item (CLIN) for travel has been established in the basic contract also as required per task order.

1.2. Contract Performance Period: Basic Contract: The total base period of performance for the Language and Cultural Services will be twelve (12) months starting 1 July 2011 and ending 30 June 2012. Two ordering periods (1 July 2012 – 30 June 2013 and 1 July 2013 – 30 June 2014) will be established to continue support through 2014.

1.3. Scope of Contracted Services: This Contract describes the services required to execute the Language & Cultural Serves as defined by the Government PWS.

1.4. Government Contracting Officer (CO): The Contracting Officer for the basic contract is Janice Kimberly Jones, SORDAC-KH.

1.5. Government Contracting Lead: The Contracting Lead for this effort is the Contracting Officer, SORDAC-KH

1.6. Government Quality Assurance Manager (QAM): The QAM for this effort is the Director, SOF Language Office, Mr. Mark Roemer.

1.7. Contractor: TBD

2. ACRONYMS

AOR Assessing Official Representative ASP Acquisition Strategy Planning CEI Critical Evaluation Item CI Continuous Improvement CIO Continuous Improvement Opportunities CID Contractor Identified Discrepancy CPARS Contracting Performance Assessment Reporting System DA Data Analysis FD/FC Functional Director/Functional Commander GID Government Identified Discrepancy MAJCOMS Major Commands MFR Memo for Record MFT Multi-Functional Team MOASP Management Oversight of the Acquisition Services Process PCO Procuring Contracting Officer POC Point of Contact PWS Performance Work Statement QA Quality Assurance QAD Quality Assurance Director QAM Quality Assurance Manager QAPC Quality Assurance Program Coordinator QAP Quality Assurance Personnel QAQR Quality Assurance Quarterly Report QASP Quality Assurance Surveillance Plan QPP Quality Program Plan QSE Quality System Evaluation REI Routine Evaluation Item SS Services Summary SOW Statement of Work TET Technical Evaluation Team

3. OBJECTIVE

The objective of this quality assurance surveillance plan is to ensure quality service is provided for the contract. The objective of the contract is to teach and improve the language and cultural skills of Special Operations Forces in support of their critical career path and missions. The plan will provide oversight capability to ensure the Contractor is delivering services that conform to contract requirements. It will also identify the methods used for evaluation and surveillance of the Contractor.

4. GOALS OF THE MULTI-FUNCTIONAL TEAM

The Multi-Functional Team (MFT) is striving to achieve efficiencies in the contract performance and improved customer support. The team is composed of stakeholders in the acquisition process and is responsible for the acquisition throughout the life of the requirement. The goal of the team with other government personnel is to partner with the contractor for improving communications, assuring contract compliance and managing the risk associated with this acquisition in order to ensure mission performance is within cost and schedule constraints. In addition, another goal is implementation and execution of the acquisition strategy to ensure support of the mission. The role entails planning, programming, and budgeting for adequate funds, ensuring program execution within the approved funding, developing the milestones and managing execution to ensure the contract supports mission requirements within the approved scheduled baseline and ensuring the program maintains accountability.

The planning and managing of this service contract will continue throughout the life of the requirement.

When applicable, Continuous Improvement Opportunities (CIO) will be identified.

5. ROLES AND RESPONSIBILITIES

5.1. Contracting Officer

5.1.1. Serves as the Business Advisor to the Commander, Component Commanders, and other Directors (as appropriate). The PCO is responsible for chairing the Acquisition Strategy Planning (ASP) meeting to form the milestones for the acquisition process jointly with the Functional Director/Commander, ensuring acquisition processes (i.e. performing market research, gathering past performance information, performing source selection, issuing solicitation, performing evaluations and awarding the contract) are aggressively performed, participating in all MFT meetings, and taking minutes and maintaining a written record of team meetings, action items and milestones when Contract Negotiator/ Specialist is not present.

The PCO will give a written delegation letter to the Contractor informing them who will be performing QA duties on their contract.

5.1.2. Develops and implements acquisition strategies for service acquisitions.

5.1.3. Provides oversight of the MFT in planning, assessing contractor performance, and managing the acquisition throughout the life of the requirement.

5.1.4. Updates the Commanders and Component Commanders annually on the health of the service acquisitions. Provide Management Oversight of the Acquisition of Services Process (MOASP) reports on service acquisitions to the Director of Procurement for consolidation.

5.1.5. Ensures personnel on the MFT receive the appropriate level of training to meet local needs.

5.2. Functional Director/Functional Commander (FD/FC):

5.2.1. Assigns competent and capable functional experts to the multi-functional team who will be available full time or as warranted by the procurement cycle. Functional experts assigned to the MFT shall:

5.2.1.1. Maintain functional knowledge

5.2.1.2. Have priority for continuing education

5.2.1.3. Provide functional continuity and stability

5.2.2. Ensures requirements documents developed by the multi-functional team satisfy mission requirements, are performance based, foster innovation, and define metrics. Metrics should provide meaningful measurements of the contractor progress aimed at attaining desired outcomes. Identifies mission essential services and developing the necessary documents in accordance with DoDI 3020.37, Continuation of Essential DoD Contractor Services During Crisis.

5.2.3. Assigns primary and alternate QA personnel, unless another QA organization or method is used to satisfy surveillance requirements (e.g. centralized performance management office). QA duties take precedence over all other duties. QA personnel must be appointed and trained prior to assuming QA responsibility (Phase I and II). This written appointment is by the Contracting Officer once nominated.

5.3. Quality Assurance Program Coordinator (QAPC): The QAPC shall assist in preparing the Performance Work Statement, Quality assurance surveillance plan, and participate in team meetings, as requested.

5.4. Contract Specialist: Is responsible for participating in the Acquisition Strategy Planning meetings, performing acquisition processes, (i.e. market research, gathering past performance information, source selection, solicitation issuance, evaluation and award), participating in all team meetings and taking minutes and maintaining a written record of team meetings, action items and milestones.

5.5. Quality Assurance Personnel (QAP): The QAPs are responsible for participating in the ASP meetings, performing/assisting in market research, gathering past performance information, evaluating proposals, assisting the Functional Director/Commander in preparing the PWS, QASP, and participating in all MFT meetings unless located off-site. QAPs also perform inspections to evaluate and document the Contractor’s performance, notify the PCO of any significant performance discrepancies, maintain documentation, and recommend improvements to the surveillance procedures and PWS throughout the life of the contract.

5.6. Legal, Finance, and Engineering POCs: Other POCs shall coordinate, review and provide input as needed by the MFT.

5.7. Multi-Functional Team (MFT): This customer-focused team is composed of stakeholders in the acquisition process. The team provides support to the Executive Leadership (EL) as required, promotes good business decisions to meet customer requirements, fosters partnerships with industry to ensure exchanges of information with the Contractor and other business experts, develops a performance-based acquisition strategy to include performance metrics, develops PBSA requirements, develops technical requirements and the independent government cost estimate. The team is also responsible for assessing and documenting Contractor performance in accordance with the Quality assurance surveillance plan, managing contract performance in accordance with the Quality assurance surveillance plan, identifying opportunities to improve performance throughout the life of the contract completing and reporting annual performance reviews (i.e. Contract Performance Assessment Reporting System (CPARs)) and managing the acquisition in accordance with the MOASP.

5.7.1. The team will participate in management reviews, working group meetings, and general meetings.

After contract award, the Contractor becomes a member of the MFT.

6. PERFORMANCE ASSESSMENT

6.1. This Quality assurance surveillance plan is based on the premise that the Contractor, not the Government, is responsible for the management and quality control actions needed to meet the requirements of the contract. A contractor Quality Program Plan (QPP) will be required with the submission of the proposal. The Quality Assurance Manager (QAM), Technical Evaluation Team and Contract Specialist /Contracting Officer will review the QPP. The Contractor will be expected to perform quality assurance inspections in accordance with their plan, and keep records of those inspections. This documentation, along with the government-documented inspections, will be reviewed periodically FD/FC to ensure the Contractor is performing up to the standards set forth in the contract. Reporting metrics will be developed IAW the MOASP requirements.

6.2. Periodic meetings will be held with the Contractor to discuss surveillance results and the relevance to performance.

6.3. The required services are outlined in the Government Performance Work Statement. This PWS explains the performance objectives and performance threshold required by the Government in the Contractor’s performance. These performance objectives will directly relate to mission essential items.

The performance thresholds briefly describe the minimum acceptable levels of service required for each objective, and are critical to mission success.

6.3.1. Where appropriate methods for administering and evaluating services are not included in the Services Summary (SS), methods for evaluating non-SS items are to be developed by the Quality Assurance Personnel (QAP).

7. PERFORMANCE MANAGEMENT

7.1. Market research will be used as a tool throughout the life of the contract to ensure the most current, efficient, and effective assessment methods and techniques being used by the commercial marketplace.

7.2. Multi-Functional Team (MFT) meetings will be scheduled throughout the life of the contract. The participants will include personnel from the Government and the Contractor after contract award. The goal of the MFT is to give all members/stakeholders the ability to maintain the highest quality representative service to our customers and propose/initiate improvements throughout the life of the contract. The success of the contract is a combined effort of all members of the MFT.

7.3. All performance assessment data will be reviewed. If performance improvement is necessary the corrective action will be requested from the Contractor. The MFT will continue to review data and procedures to improve efficiency. Any additional efficiency shall be noted through “benchmarking”.

7.4. The Quality Management system should include:

7.4.1. Providing adequate contract planning to meet quality assurance manning and training requirements.

7.4.2. Tailoring the system to manage risks and costs associated with the requirement.

7.4.3. Recommending source selection criteria that promise potential to reduce government oversight and ensure the Government is only receiving and paying for the services required.

7.4.4 Relying on customer complaints (if used) where contract non-conformance can be validated.

7.4.5. Allowing the Contractor to perform surveillance of services as part of the quality assurance system.

7.4.6. Developing a government inspection procedure that specifies how inspection and acceptance of the service is to occur and using past performance history as part of the process.

7.5. Contract Performance Assessment Reporting System (CPARS) (applicable if contract is for over $1 million)

7.5.1. CPARS will be updated documenting Contractor performance. The Assessing Official Representative (AOR) will be the QAP; and the reviewing official will be Functional Director/Commander.

The Contractor also has input prior to finalization. The website for CPARs is:

http://www.cpars.csd.disa.mil/.

7.6. Revisions to the Quality assurance surveillance plan are the responsibility of the QAM, FD/FC, PCO and QAP. The PWS and QASP will be reviewed annually and any proposed changes will be submitted to the MFT/PCO for review. This is a living document and can be changed at anytime, but the MFT/ PCO must accept changes.

http://www.cpars.csd.disa.mil/�

8.0 MULTI-FUNCTIONAL TEAM MEMBERSHIP

Functional Director/Commander: COL Stephen Goto Date: 3/28/2011

Quality Assurance Manager: Mark L. Roemer Date: 3/28/2011

Quality Assurance Personnel: Mickey D. Taylor (ARSOF) Date: 3/28/2011

Quality Assurance Personnel: Dr. Marla Federe (NSW) Date: 3/28/2011

Quality Assurance Personnel: Alicia Spurling (AFSOC) Date: 3/28/2011

Quality Assurance Personnel: Tanya G. Woodcook (MARSOC) Date: 3/28/2011

Contracting Officer: Janice Kimberly Jones Date: 3/28/2011

Contract Administrator: TBD Date: TBD

Contract Specialist: Ashley M. North Date: 3/28/2011

QAPC: Mark L. Roemer Date: 3/28/2011

Financial Analyst: TBD Date: TBD

Legal: Craig McCaa Date: 3/28/2011

Small Business: Chris Harrington Date: 3/28/2011

Contractor*: _______________________________ Date: __________________

Accepted By: _______________________________ Date: __________________ Contracting Officer

* Contractor (signs after award) will have limited authority in the MFT, so as to not be involved in any inherently governmental responsibilities.

9. QUALITY ASSURANCE SURVEILLANCE PLAN SURVEILLANCE PROCEDURES

This QASP has been developed to provide quality assurance personnel an effective and systematic surveillance of the Language & Cultural Services Contract. The QASP provides a systematic method to evaluate the services the Contractor is required to furnish and not the details of how the Contractor accomplishes the work.

10. SUMMARY OF THE CONTRACTOR'S REQUIRED LEVEL OF QUALITY

The Contractor shall establish, document and maintain a quality system in accordance with the best commercial practices and is required to provide and maintain an inspection system according to Federal Acquisition Regulation (FAR) clause 52.246-4-Inspection of Services Fixed Price, (AUG 96) and Federal Acquisition Regulation 52.246-5 (Inspection of Services - Cost Reimbursement, Apr 1984). The contractor is required to have a Quality Program Plan (QPP), which has been accepted by the PCO.

11. SUMMARY OF THE GOVERNMENT'S QUALITY ASSURANCE (QA) MANAGEMENT SYSTEM

11.1. General: The Government's Quality Management approach prescribes systematic surveillance and evaluation techniques that will be utilized by Quality Assurance Personnel (QAP) to identify the Government’s performance objectives; the Government’s expectations of Contractor performance and the methods whereby the Government will confirm receipt of Contractor Services. The Government’s system provides for surveillance and evaluation of the Contractor in accordance with the QASP. Additionally, the surveillance techniques outlined herein may be revised upon receipt of the QPP or on the basis of Contractor performance.

11.2. Surveillance Techniques. The Government's QA System seeks to match the level of contract surveillance required to the associated contract risks and costs. Additionally, the Government intends to adjust, as warranted throughout the life of the contract, the level of Government surveillance required commensurate with the Contractor's level of satisfactory performance. As such, the surveillance techniques as outlined in this QASP are not static, and allow for variation to the extent of government oversight relative to Contractor performance outcomes. The Government's primary method for providing surveillance relies on the systematic inspection of the contract objectives, outlined in the PWS in relation to the standards. Additional methods of surveillance the Government may employ include, but are not limited to utilization of Contractor metrics and third-party audits. Based on mutual agreement between the Government and Contractor, the Government QA Management System may also allow the Contractor to perform surveillance of services as part of their quality assurance program, however, such action will not relieve the Contractor of its duty to provide written documentation of inspections. Finally, in accordance with the Inspection of Services Clause, DFAR parts 246.2 and 246.5, re-performance of unacceptable services is the preferred course of action as dictated by the Government's assessment regarding the criticality of the service and outlined in the Surveillance Guide, Addendum 4.

12. PERFORMANCE MEASUREMENT

12.1. Performance Measurement Techniques. The Government will employ the following tools to evaluate Contractor performance.

12.2. Critical Evaluation Item (CEI). A CEI is defined as one that if not performed satisfactorily, will either pose immediate serious danger to the mission, personnel, security or government property/equipment, or have a significant adverse impact on the mission. Members of the MFT will identify mission critical requirements for CEIs and each CEI as set forth in the QASP will have a specified maximum inspection interval to be evaluated by the QAP.

12.2.1. Intervals or frequencies of inspection prescribed for CEIs represent the minimum inspection requirements; CEI requirements are verified through either random sampling or 100% inspection surveillance techniques and should cover all hours of contractor performance.

12.3. Routine Evaluation Item (REI). A REI includes any Contractor performance requirement selected by QAP and is evaluated on pass/fail criteria as defined in the applicable area of the PWS.

12.3.1. Routine evaluation is a planned surveillance activity; however, no-notice evaluations may be conducted. Members of the MFT will identify specific performance characteristics to observe or evaluate during routine evaluation of a selected performance area.

12.4. Quality System Evaluation (QSE). QSE is a tool used by the Government QA representative to evaluate the acceptability and effectiveness of the Contractor's QPP.

12.4.1. Quality System Evaluations are conducted in two phases.

12.4.1.1. Phase I of the QSE consists of a review of the Contractor's program characteristics to determine if they adequately cover contractual performance requirements.

12.4.1.2. Phase II of the QSE consists of an actual observation of the Contractor's in-process performance to verify whether or not procedures and processes are actually followed by Contractor personnel. Completed work is then verified against the contract objectives. See Addendum 5, Classroom Evaluation Checklist. This document will be used by the Government evaluator during observation.

12.4.2. QSEs may be assessed by a random sample of the Contractor's procedures and/or processes or may cover an entire performance area or site. Additionally, the PCO may initiate a QSE if the Contractor's performance is in question.

12.5. Data Analysis (DA). DA is a surveillance tool used to detect trends; provide for the identification of areas for process improvement; and allow for the detection of out-of-control Contractor processes. Data may be collected from a number of resources to include Government surveillance records, Contractor records and customer feedback. DA consists of systematic reviews, charting and calculations. The results of data analysis may be used as the basis to adjust the frequency of surveillance, identify trends and Contractor continuous improvement areas, as well as discrepancies in the Contractor's quality system.

The identification of trends of unsatisfactory performance without the subsequent correction of the root cause may be identified as a discrepancy requiring corrective action. As a result of any unresolved corrective action, the contract price will be reduced to reflect the reduced valued of the services performed.

13. CONTRACT SURVEILLANCE

13.1. Effective contract surveillance relies on two methods for the identification of unacceptable performance: (a) Contractor identified discrepancies (CIDs) and, (b) Government identified discrepancies (GIDs). Discrepancies will be resolved at the lowest possible level.

13.2. Contractor Identified Discrepancies (CIDs). CIDs are generated as a result of the Contractor's detection of discrepancies when conducting inspection of their quality system or plan. When CIDs are identified, the Government will take the following actions:

13.2.1. Review the corrective actions taken by the Contractor to resolve the discrepancy.

13.2.2. Determine whether the discrepancy has been corrected.

13.2.3. If the discrepancy has been resolved, the QAP will review the corrective action taken; in addition to any applicable procedures the Contractor has established to preclude a recurrence of the problem.

13.2.4. Note the discrepancy as well as the Contractor corrective actions in monthly surveillance reports.

13.2.5. If the CID has not been resolved, but the Contractor has identified estimated completion dates for resolution of the discrepancy, the Government will track the Contractor's efforts in resolving the discrepancy. Additionally, the discrepancy will be noted on monthly Quality reports until such time as the discrepancy has been closed. If the Government feels the dates the Contractor has set forth for resolution of the problem are lengthy or excessive based on the nature of the discrepancy, he/she will notify the PCO. The PCO will evaluate QA recommendations to determine the appropriate course of action.

13.2.6. If the CID has not been resolved, and following a thorough inspection of the Contractor's records, the Government determines that the Contractor has not identified estimated completion dates or follow-up action for resolution of the discrepancy, the Government will document the discrepancy against the Contractor's Quality Program. QA will notify the Contractor of the discrepancy in writing, and a copy of the letter will be included in monthly quality reports.

13.3. Government Identified Discrepancies (GIDs). GIDs are generated as a result of the Government's inspection of Contractor performance resulting in unacceptable outcomes relative to the contract. All GIDs will be brought to the attention of the QAM prior to notifying the Contractor. Additionally, QAP will ensure the QAM receive copies of all GID documentation. The Government will address GIDs as follows:

13.3.1. GIDs as a result of CEIs. GIDs that are identified as the result of a CEI inspection will be addressed in writing to the Contractor and obtain the Contract Manager or Contractor's Representative signature on the memo and included in the quarterly quality report provided to the contractor by the QAPC. Urgent problems will result in an earlier quality report to be provided to the contractor.

13.3.1.1. The Contractor will be given 10 working days to provide a written response to the Government's findings that outlines the Contractor's plan to preclude repeat discrepancies.

13.3.1.2. The Government will have 10 working days to evaluate the Contractor’s response and respond back in writing whether it is acceptable.

13.3.2. GIDs that are identified as a result of REIs will be addressed as follows:

13.3.3. If re-performance of the REI task is acceptable, the Government will notify the Contractor in writing of the discrepancy and obtain the Contract Manager or Contractor Representative's signature on the memo. If re performance cannot be accomplished on-the-spot, the QA representative will set a date or time for re-inspection. If Contractor re-performance efforts are acceptable, the Government will state so in writing, obtain the Contract Manager or Contractor Representatives concurrence by written signature, and the discrepancy will be closed.

13.3.4. If re-performance of the REI task is not viable, the Government will notify the Contractor in writing of the discrepancy and obtain the Contract Manager or Contractor's Representative signature on the memo. Additionally, the discrepancy will also be identified in the Government's quarterly quality reports.

13.3.4.1. The Contractor will be given 10 working days to provide a written response to the Government's findings that outlines the Contractor's plan to preclude repeat discrepancies.

13.3.4.2. The Government will have 10 working days to evaluate the Contractor’s response and respond back in writing whether it is acceptable.

14. QUALITY ASSURANCE MANAGEMENT SYSTEM DOCUMENTATION

14.1. Quality Surveillance Files. Documentation is required to record, evaluate and report Contractor performance. Each functional area will maintain a record keeping system that contains the following items.

14.1.1. A copy of the contract with all modifications posted.

14.1.2. A copy of the QASP.

14.1.3. Applicable Instructions.

14.1.4. QAM, QAP appointment letters and QAP training certificates.

14.1.5. Government Point of Contact (POCs) for the contract.

14.1.6. Contractor organizational chart and POCs.

14.1.7. Inspection Checklist.

14.1.8. Area Surveillance Plans.

14.1.9. Open discrepancies.

14.1.10. Closed discrepancies.

14.1.11. Memos for Record (MFRs), copies of letters to the Contractor and other applicable correspondence.

14.1.12. Quality Assurance Quarterly Report (QAQR). [Maintained by QAM]

15. ACCEPTANCE OF SERVICES

Government will certify acceptance of the services rendered by the Contractor using Wide Area Work Flow (WAWF). The QAM will complete WAWF acceptance within 30 calendar days from receipt of an acceptable invoice. If the invoice is not acceptable, it will be rejected in WAWF and the contractor must re-submit their invoice.

16. QUALITY ASSURANCE QUARTERLY REPORT (QAQR)

QAQRs will be completed by the QAM within fifteen (15) working day of end of each quarter. The QAQR provides an overall performance rating, significant items related to performance and additional comments.

17. MEMORANDUM FOR RECORD (MFR)

17.1 Monthly surveillance reports from QAP need to be written as Memo for Records. MFRs for a given month will be completed, signed and delivered to the QAM by the fifth (5) working day of the following month (see exception in paragraph 17.2). This MFR should be a summation of the month’s activities with attachments (such as quality assurance surveillance sheets, etc.) that are applicable.

17.2 Along with the QAQR, the QAM will submit all signed MFRs to the PCO and FD/FC by the seventh

(7) working day of each month. This will allow a review of QAP documentation and allow the PCO to include QAP documents in the official contract file.