Attachment 6 QASP.docx

FOR INTERNAL USE ONLY

Proliferated Low Earth Orbit (PLEO) Satellite-Based Services

Quality Assurance Surveillance Plan (QASP)

November 21, 2023

Department of Defense United States Space Force Commercial Satellite Communications Office

Table of Contents

1. Contract or Task Order Title:

Multiple Award Indefinite Delivery, Indefinite Quantity (IDIQ) Contract for Proliferated Low Earth Orbit (PLEO) Satellite-Based Services (SBS)

2. Purpose:

This Quality Assurance Surveillance Plan (QASP) has been developed to provide the Contracting Officer Representative (COR)and effective and systematic method to evaluate performance for the stated contract. This QASP explains the following:

· What will be monitored?

· How monitoring will take place.

· Who will conduct the monitoring?

· How monitoring efforts and results will be documented.

The role of Government quality assurance is to ensure contract standards are achieved. This QASP does not detail how the contractor accomplishes the work. Rather, the QASP is created with the premise that the contractor is responsible for management and quality control actions to meet the terms of the contract. In conducting surveillance, the COR is to be objective, fair, and consistent in evaluating performance. In addition, the QASP should recognize that unforeseen and uncontrollable situations may occur.

This QASP is a “living document” and shall be revised or modified by members of the multi-functional team as circumstances warrant, throughout the life of the contract, to ensure adequate oversight of Contractor performance is maintained. Updates shall ensure that the QASP remains a valid, useful, and enforceable document. Copies of the original QASP and revisions shall be provided to the contractor and Government officials implementing surveillance activities.

3. Roles and Responsibilities:

The following personnel shall oversee and coordinate surveillance activities.

Program/Project Manager (PM) – The PM provides program oversight and supports the COR’s performance assessment activities.

Contracting Officer – The Contracting Officer shall ensure performance of all necessary actions for effective contracting, ensure compliance with the contract terms, and shall safeguard the interests of the United States in the contractual relationship. The Contracting Officer shall also ensure that the contractor receives impartial, fair, and equitable treatment under this contract. Determine the final assessment of the contractor’s performance.

Additional responsibilities of the Contracting Officer are as follows:

a. Advise the multi-functional team on Quality Assurance Surveillance Plan (QASP) development.

b. Manages the listing of Contracting Officer Representative (COR) assigned to the contract, indicating their areas of responsibilities and limitation of authority, and ensures that the Contractor is notified of such.

c. Serve as multi-functional team advisor for developing incentives/remedies, as appropriate, tied to performance objectives and performance thresholds.

d. Maintain in the contract file documentation of training provided by contracting personnel and/or QAPC identified herein.

Contracting Officer’s Representative (COR) – The COR is responsible for managing, planning, provisioning, optimizing, providing and supporting timely COMSATCOM services to and across all Mission Partners. In addition, the COR is responsible for providing continuous technical oversight of the contractor’s performance. The COR uses the QASP to conduct the oversight/surveillance process. The COR shall keep a Quality Assurance file that accurately documents the contractor’s actual performance. The purpose is to ensure that the contractor meets the performance standards contained in the contract. The COR is responsible for reporting early identification of performance problems to the Contracting Officer. The COR is required to provide an annual performance assessment to the Contracting Officer which will be used in documenting past performance. The QASP is the primary tool for documenting contractor performance. The COR is not empowered to make any contractual commitments or to authorize any contractual change on the Government’s behalf.

Additional responsibilities of the COR are as follows:

a. Serves as a member of the multi-functional team.

b. Develops technical requirements and independent cost/Government estimates for contract services.

c. Conducts Government contract quality assurance by or under the direction of Government personnel.

d. Evaluates and documents the Contractor’s performance in accordance with the procedures set forth in this plan.

e. Notifies the Contracting Officer of any performance deficiencies.

f. Maintains surveillance documentation.

g. Recommends improvements to the Performance Work Statement (PWS) and Quality Assurance Surveillance Plan (QASP), throughout the life of the contract.

h. Maintains technical competency in the functional area surveyed.

i. Obtains proficiency in surveillance procedures.

j. Certifies acceptance of services.

k. Promotes business decisions to meet customer requirements by researching the marketplace to remain current with the most efficient and effective performance assessment methods and techniques. Performs market research throughout the life of the requirement to ensure the team is knowledgeable of the commercial marketplace.

l. Identifies opportunities to improve performance throughout the life of the contract, including benchmarking against industry, identifying initiatives, assessing the risk associated with these initiatives, using the QASP for implementing initiatives brought forward, and monitoring the success of implementation.

m. Recommends any changes necessary to the contract, specifications, instructions, or other requirements that will provide more effective operations or eliminate unnecessary costs

Quality Assurance Program Coordinator (QAPC) - Roles and Responsibilities of the QAPC are as follows:

a. Supports the multi-functional team in the development of contract requirements specifically ensuring that requirements are clearly stated and enforceable.

b. Trains CORs on the contracting requirements associated with the quality assurance program.

c. Trains Functional Commanders/Directors (FC/FD).

d. Provides training, documents CORs acknowledgement of their requirement to:

(1) Evaluate and document Contractor’s performance in accordance with the Quality Assurance Surveillance Plan (QASP).

(2) Notify the contracting officer of any significant performance deficiencies and provide any recommendations to improve the QASP or PWS.

(3) Maintain surveillance documentation.

e. Assists in development of quality assurance related training as requested.

f. Processes/maintains/updates quality assurance appointments and delegations memos.

g. Maintains documentation of training provided by contracting personnel identified herein.

h. Assists the market research efforts of the multi-functional team in determining commercial quality assurance practices.

i. Assists as required with the evaluation of the Contractor’s Quality Control Plans.

j. Provides refresher training annually if, necessary, to ensure the CORs are up to date with all required changes.

Contractor – Roles and Responsibilities of the Contractor as related to quality assurance are as follows:

a. Complies fully with the terms and conditions of the contract.

b. Participates as a member of the multi-functional team after contract award.

c. Maintains and implements a quality control plan that is acceptable to the Government.

d. Ensures that non-conformance of contract requirements are identified, corrected, and prevents recurrence.

e. Tenders to the Government for acceptance only those services that conform to contract requirements.

f. Recommends any changes to the contract that will provide more effective operations or eliminate unnecessary costs.

4. Primary Method of Surveillance:

A combination of random sampling, 100% inspection and customer input will be used to evaluate contractor performance for this BPA. The performance standards, acceptable quality level (AQL) and surveillance methods are outlined in Section 5. In addition to the Performance Standards defined in Section 5 below, the Government shall perform annual surveillance for contractor compliance as required by FAR 52.222-50, Combating Trafficking in Persons (see Section 7 below).

· 100 Percent Inspection. This is usually only the most appropriate method for infrequent tasks or tasks with stringent performance requirements, e.g., where safety or health is a concern. With this method, performance is inspected/evaluated at each occurrence. One hundred percent inspection is too expensive to be used in most cases.

· Random Sampling. This is usually the most appropriate method for recurring tasks. With random sampling, services are sampled to determine if the level of performance is acceptable. Random sampling works best when the number of instances of the services being performed is very large and a statistically valid sample can be obtained. Computer programs may be available to assist in establishing sampling procedures.

· Customer Input. Although usually not a primary method, this is a valuable supplement to more systematic methods. For example, in a case where random sampling indicates unsatisfactory service, customer complaints can be used as substantiating evidence. In certain situations where customers can be relied upon to complain consistently when the quality of performance is poor, e.g., dining facilities, building services, customer surveys and customer complaints may be a primary surveillance method, and customer satisfaction an appropriate performance standard. In all cases, complaints should be documented using the Customer Complaint Record (Appendix 2).

5. Performance Standards:

In addition to the Contractor's standard commercial terms as agreed under a TO for any commercial items as defined in FAR 2.101, the following performance standards apply to this contract:

Table 8-1. Performance Standards

6.4.1 Weekly Order Update

6.4.2 Equipment Shipment

Standard Shipment - within 5 calendar days ARO Priority Shipment - within 2 calendar days ARO Overnight Shipment – within 24 hours ARO on 100% of task orders Periodic inspection of task order date vs ship date.

6.5.2 NetOps Monitoring

6.5.2 NetOps Monitoring

6.5.3 Service Availability Reporting

6.5.4 Service Activation Reporting

6.5.5 Monthly Status Reporting

6.5.6 Quarterly Usage Report

6.5.7 Fault Reporting

6.5.7 Service Outage Reporting

6.5.8 Information Assurance Reporting

6.6.1 Customer Service Support Requirements

6.6.1 Field Service

6.6.2 Field Service

6.6.4 Service Activation Plan

6.6.5 Communications and Escalation Plan

6.6.7 EMI/RFI Identification, Characterization, and Geo-Location

6.6.8 Frequency Clearances and Approvals

7.1 PLEO Operational Services

7.1.1 PLEO Services

7.1.2 Priority Service

7.1.3 Priority Activation

7.1.4 Terminal Provisioning

7.1.5 Terrestrial Interconnect Services

7.2 Initial, Limited Use PLEO Services

6. Documenting Performance:

Acceptable Performance.

The Government shall document positive performance. A Performance Assessment Report (PAR) template is attached (Appendix 1). Any report may become part of the supporting documentation for fixed price payments, award/incentive fee payments, Contractor Performance Assessment Reporting System (CPARS) entries, or other actions. Government acceptance of services permits the contractor to invoice for the service fee.

Unacceptable performance.

Unacceptable contractor performance can be identified by customer complaints (Appendix 2) or upon schedule surveillance evaluations. When unacceptable performance occurs, the COR shall inform the contractor and attempt to determine the cause of the unacceptable performance. If any Government action, or lack of action, caused the unacceptable performance, the unacceptable performance shall not be counted against the Contractor. The COR shall take action to ensure Government action, or lack of action, does not interfere with the Contractor’s performance in the future. This will normally be in writing unless circumstances necessitate verbal communication. The COR shall document the discussion and place it in the COR file and provide a copy to the Contracting Officer.

When the COR determines formal written communication is required, the COR shall prepare a Corrective Action Report (CAR). The CAR is forwarded to the Contracting Officer for dissemination to the contractor. A CAR template is attached to this QASP (Appendix 3).

The contractor shall acknowledge receipt of the CAR in writing. The CAR will specify if the contractor is required to prepare a corrective action plan to document how the contractor shall correct the unacceptable performance and avoid a recurrence. The CAR will also state how long after receipt the contractor has to present this corrective action plan to the Contracting Officer and COR. The Government may withhold payment for services until corrective action is taken. The Government shall review the contractor's corrective action plan to determine acceptability. Upon Government acceptance of the corrected services the contractor will be permitted to invoice for the service fee.

Any CAR may become a part of the supporting documentation for contract payment deductions, fixed fee deductions, award fee nonpayment, CPARS or other actions deemed necessary by the Contracting Officer.

The Contractor shall be required to re-perform the service, if possible, without additional cost to the Government. Unacceptable performance re-performed by the Contractor shall still count as unacceptable performance. If the Contractor challenges the validity of the CORs unacceptable surveillance findings, and the COR and Contractor cannot come to an agreement, the matter shall be referred to the Contracting Officer for resolution. The Contractor shall be required to return all completed CARS to the COR, no later than the suspense date indicated on the CAR. The COR shall maintain a CAR Log (Appendix 5) of all CARS issued to the Contractor. The CAR log shall contain the CAR number, date issued, Contractor, description of unacceptable performance, suspense date, and closeout date. All CARs and CAR logs shall be maintained by the COR for the life of the contact. A CAR Log will be maintained and is included as Appendix 4 to this document.

Contracting Officer Notification.

Findings are broken down into two categories, Major and Minor. Definitions for Major and Minor Findings as well as notification requirements are as follows:

0. Major Finding. If at any time COR identifies a condition as having a significant adverse effect on the quality of the activity, such as those stated below, COR shall document their findings and notify the Contracting Officer immediately in writing.

0. Contractor failure to meet a Performance Threshold.

0. A significant morbidity or mortality involving Contractor personnel,

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

0. Failure to provide corrective action to deficiencies identified by the Contractor within a prescribed suspense period.

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

0. Revocation of clinical privileges.

0. Minor Finding. A departure from established standards having little bearing on the service provided. When COR identify a minor finding, the COR shall document the findings, but is not required to notify the Contracting Officer. However, if the same minor finding is repeatedly identified, it may be an indication that a major finding is occurring or has occurred because the Contractor has not taken proper steps to prevent recurrence. In this case, the COR shall notify the Contracting Officer in writing.

Remedies for Unacceptable Performance.

a. In accordance with the contract Inspection of Services Clause 52.246-4, if any of the services do not conform with the contract requirements; the Government may require the Contractor to perform the services again in conformity with contract requirements, at no increase in contract amount. This includes but is not limited to (if applicable) the termination of health care workers and recruitment of substitute health care workers that are equally qualified within established timeframes. When the defects in services cannot be corrected by re-performance, the Government may:

1. Require the Contractor to take necessary action to ensure that future performance conforms to contract requirements; and

1. Reduce the contract price (e.g. CLINs) to reflect the reduced value of the services performed. This may include a reduction in the number of paid hours to reflect the total non-performance period.

b. If the Contractor fails to promptly perform the services again or to take the necessary action to ensure future performance in conformity with contract requirements, the Government may:

(1) By contract or otherwise, perform the services and charge to the Contractor any cost incurred by the Government that is directly related to the performance of such service; or

(2) Terminate the contract or task order for default.

7. Mandatory or regulatory compliance items:

The contractor will provide initial proof of compliance with regulatory and compliance items contained in the contract. The Contracting Officer's Representative (COR) and the Contracting Officer will evaluate the initial submission and will conduct ad hoc reviews of the contractor's compliance throughout the remainder of the contract. The contractor will monitor compliance as required by FAR 52.222-50, Combating Trafficking in Persons, and report any issues to the Contracting Officer.

8. Acceptable Quality Level (AQL):

AQL for tasks on this IDIQ are detailed in Section 5 above.

9. Evaluation Method:

The COR will document the time of verbal notification to the contractor. The COR will document the official time and date of notification on the Maintenance Call Record. The COR will review self-diagnostic systems logs, conduct a comparison with actual maintenance performance and otherwise verify and validate contractor performance. The contractor shall enter in the record the official time the system is restored to full operational status. The COR will confirm the date and time of problem resolution in the record.

10. Performance Rating:

In evaluating the quality of contractor’s performance, the following performance ratings may be used (same as CPAR ratings).

Performance Rating Criteria

Appendix 1 – Performance Assessment Report

PERFORMANCE ASSESSMENT REPORT (PAR)

(If more space is needed, use reverse and identify by number)

4. QUALITY ASSURANCE PERSONNEL (COR) SIGNATURE AND DATE

I. PERFORMANCE

7. |_| DEFICIENCY (CHECK ALL BOXES THAT APPLY)

|_| NEW

|_| REPEAT

|_| NO DEFICIENCY NOTED

8. SERVICES SUMMARY or PWS PARAGRAPH ITEM REVIEWED

II. CONTRACTOR VALIDATION

11. CONTRACTOR REPRESENTATIVE |_| CONCUR |_| NON-CONCUR

12. CORRECTIVE ACTION ESTIMATED COMPLETION DATE

13. CONTRACTOR REPRESENTATIVE CORRECTIVE ACTION AND PREVENTION OF RECURRENCE OR REASON FOR NON-CONCURRENCE OF COR CITED DEFICIENCY

III. ACTION CORRECTED

14. |_| CONCUR |_| NON-CONCUR COR SIGNATURE AND DATE

15. COR REMARKS (REQUIRED)

6. CONTRACTOR REPRESENTATIVE REMARKS

Appendix 2 – Customer Complaint Record

CUSTOMER COMPLAINT RECORD

DATE/TIME OF COMPLAINT

SOURCE OF COMPLAINT

ORGANIZATION

BUILDING NUMBER

INDIVIDUAL

PHONE NUMBER

NATURE OF COMPLAINT

CONTRACT REFERENCE

VALIDATION

DATE/TIME CONTRACTOR INFORMED OF COMPLAINT

ACTION TAKEN BY CONTRACTOR

RECEIVED/VALIDATED BY

Appendix 3 – Corrective Action Report

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. DEFICIENCY |_| 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. If date was not entered in Block 5, the contractor is not required to provide a response.

8. QUALITY ASSURANCE PERSONNEL (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. COR DETERMINATION

|_| ACCEPTED |_| REJECTED

12. CLOSE DATE

Appendix 4 – Corrective Action Log

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