Attachment_7_-_Quality_Assurance_Surveillance_Plan.pdf

Attachment 7

Quality Assurance Surveillance Plan

DoDDS-Europe Germany and Belgium School Maintenance Program (GBSMP)

Solicitation No: HE1280-14-R-0008

THIS DOCUMENT IS PROVIDED

FOR INFORMATIONAL PURPOSES ONLY

1. Introduction: This Quality Assurance Surveillance Plan (QASP) provides guidance and procedures to government personnel responsible for the surveillance of the quality of contractor performance of work to be performed under the resultant IDIQ contract(s), hereafter referred to as “the contract”, for DoDDS- Europe Germany and Belgium School Maintenance Program (GBSMP) as solicited and awarded against Solicitation Number HE1280-14-R-0008. It is to ensure:

a. That contractor compliance and/or failure to comply with the terms and conditions of the contract are systematically identified, documented, and reported.

b. That a basis is provided to support contract administration decisions regarding the inspection and acceptance of services, payment for services, and contractual remedies for failure by the contractor to perform, as required.

c. The government's interests in its business dealings with the contractor are maintained, protected, and served.

2. Applicability: The QASP is to be utilized by government personnel in the surveillance of contractor performance in the provision of the required services for covered locations within DoDDS-Europe. The procedures, methods, and forms contained herein are provided to assist in the facilitation of this task.

Government personnel are encouraged to recommend changes, additions, and improvements to this QASP as lessons are learned.

3. Changes, Additions, and Improvements: Recommendations for changes, additions, and improvements to this QASP are encouraged and will be subject to the approval of the Contracting Officer.

Written or telephonic coordination for changes, additions, or improvements shall be initiated through DoDDS-Europe Procurement Office, ATTN: Mr. Andrew Christen, DSN 334- 2685, Andrew.Christen@eu.dodea.edu with a concurrent information copy to the duly appointed Contracting Officer Representative.

4. Contract Administration: This QASP is intended for use solely by government personnel during administration of the contract and is to be released to the contractor for “Informational Purposes Only”.

5. Definitions

a. Contract – A written agreement between the government and contractor enforceable by law.

b. Contract Administration - All interrelated activities with the purpose of ensuring contract terms and conditions are met by both the contractor and the government.

c. Contracting Officer (CO) - An official in a contracting office authorized by written appointment to enter into, administer, and terminate contracts.

d. Contracting Officer's Representative (COR) - This individual is duly appointed by the CO based on their technical knowledge of the services or supplies contracted for, and by written nomination from their Functional Area Chief. The COR is responsible for the surveillance, inspection, reporting, and acceptance of contractor performance and providing written recommendation for payment of services or supplies received to the CO. This individual shall mailto:Andrew.Christen@eu.dodea.edu have overall responsibility for the coordination of contractor performance in accordance with the Performance Work Statement for the DoDDS-Europe GBSMP contract(s). Duties also include technical assistance to the CO and surveillance and compliance duties as further delineated in this QASP and the COR Appointment Letter.

e. Inspection – Examination of services to determine conformance to contract requirements, terms, and conditions.

f. Quality Assurance (QA) – Actions taken by government personnel, including inspection, to determine if the products/services delivered by the contractor meet the contract’s performance requirements. Quality assurance involves a broader range of activities than just inspection.

g. Quality Control (QC) – Actions taken by a contractor to ensure that the product or service delivered under the contract satisfactorily meets the contract’s performance requirements.

h. Performance Work Statement (PWS) – Sets forth the minimum technical and management performance requirements of the contract including any applicable attachments, indexes, or technical exhibits essential to contract performance.

i. Performance Requirements Summary (PRS) – Establishes discriminatory performance standards of the PWS, metrics against which these standards will be measured, acceptable quality levels, method of inspection, and any positive or negative performance incentives.

j. Surveillance - Quality assurance and other actions taken by government personnel to determine contractor conformance and/or nonconformance with contract performance requirements.

Surveillance is a broader term than inspection or QA, because it encompasses the examination of the business relations as well as the technical aspects of the contract. However, the term "quality assurance surveillance" refers to those surveillance actions directly related to quality assurance.

6. Quality Control

a. The contractor is responsible for the quality of services performed under the GBSMP contract(s).

The contractor discharges this responsibility through the design and implementation of a previously approved and accepted quality control approach within the contract’s PWS, which is a material and binding term of the contract. The contractor is responsible for effectively implementing the quality control measures agreed to in the contract. It is imperative that the COR become well versed with the performance requirements in the contract’s PWS as well as its quality control aspect to effectively perform quality assurance surveillance duties.

b. Personnel responsible for surveillance, especially the COR, must ensure the contractor meets its quality control responsibilities by:

1) Reviewing the contractor's quality control terms within the contract’s PWS and becoming familiar with its contents;

2) Reviewing the contractor's quality control documentation and records periodically to verify they exist and constitute an accurate representation of the quality control effort required and performed by the contractor;

3) Determining meaningful quality control actions are being taken by the contractor;

4) Accompanying the contractor's quality representative(s) during the conduct of their duties to verify meaningful quality control actions are being undertaken by the contractor as required, the contractor is properly documenting the results, and the contractor is taking corrective action where needed; and,

5) Documenting and reporting the results of contractor quality control actions to the CO.

7. Quality Assurance (General)

a. The government has the right under the contract to perform quality assurance at any time or place as long as it does not unjustifiably impede the progress of the contractor’s performance. This means the government may conduct inspections at any point in performance including:

1) Inspection of the work or inspection of the contractor's preparations;

2) Inspection during the work process itself, especially where quality characteristics may not be readily obvious from a simple visual inspection of the output;

3) Inspection of the completed item or service; and,

4) Requiring the contractor to correct defective work (if possible) at no additional cost or taking monetary deductions to make well the government to any degree it has been harmed.

b. There are essentially five fundamental elements to quality assurance:

1) The output, service, or requirement the contractor is obligated to perform by the PWS;

2) The standard established by the PWS in conjunction with its associated PRS, whether relating to quality, schedule, cost control, technical, management, and/or other measures of performance;

3) The quality assurance surveillance method, including the frequency of its application;

4) The documentation and reporting of results, including checklists, work sheets, summary forms, and Contract Discrepancy Reports (CDRs); and,

5) Acceptance of the work performed or follow-up to ensure any required corrective action has been taken by the contractor.

c. The frequency and extent of inspection and other quality assurance actions are outlined in this plan, but they will vary according to a number of factors. The basic principle is to best allocate the necessary time and resources to maximize the results and best protect the government's interest. As applicable, the following factors should be considered in developing specific plans, schedules, and detailed itineraries for quality assurance actions:

1) Dollar value of the item or service;

2) Complexity of the item, service, or process;

3) Criticality of the item, service, process, or output;

4) Interdependency of the phases of work;

5) Performance history or trend data;

6) Contractor quality control approach and records;

7) Availability of data from management information systems;

8) Suitability of method of inspection (e.g., spot checks, validated customer complaint, etc.);

9) Customer complaint/user feedback systems;

10) Contractor performance schedule;

11) Incorporation of components into end-items; and,

12) Time and resources to perform surveillance of contract performance.

d. This plan is intended to cover inspection of all significant work to be performed under the contract. In cases where contract requirements or services are not included in this plan, the contractor is not relieved from performance of the requirement, and the requirement is still subject to inspection.

8. Quality Assurance (Specific)

a. This plan is written to provide guidance for the COR to perform their duties in the surveillance of the contractor in meeting contract performance requirements. A combination of methods should be utilized. These methods may include any combination of the following: Spot Checks and Validated Customer Complaints.

1) Spot Checks are impromptu evaluations of contract performance requirements. They may be done concurrently with other quality assurance actions or simply when the COR believes there is a need to observe a particular work instance. QASP Appendix A details how to use Spot Checks as a quality assurance surveillance method and provides an applicable form; see below for further information regarding preparation of the Surveillance Activity Schedule; QASP Appendix B.

2) Validated Customer Complaints are a quality assurance surveillance technique based on customer feedback and COR awareness. This method of inspection must be used in conjunction with another method of inspection; it cannot be used as a stand-alone method of inspection.

QASP Appendix D contains details for the application of this means of quality assurance.

b. Conducting quality assurance surveillance consists of four (4) basic steps; (i) building a monthly schedule of activities, (ii) conducting surveillance, (iii) completing the supporting documentation, and (iv), reporting the results to the CO. A discussion/briefing should be conducted with the contractor addressing any serious or minor problems or non-compliances, which require corrective action.

1) The person responsible for conducting quality assurance surveillance for this contract is the COR. The COR is responsible for the development of the monthly Surveillance Activity Schedule, which is based on the requirements contained in this QASP and the contract. The schedule helps the COR determine, on any given day, what is to be inspected and what quality assurance method is to be applied. In this way the COR can effectively and efficiently utilize their time and carry out their quality assurance responsibilities. The schedule should be completed at least five (5) days in advance of the beginning of the month in which surveillance is to be performed. Instructions and a sample format on how to complete a Surveillance Activity Schedule are provided at QASP Appendix B. Each schedule should be marked "FOR

OFFICIAL USE ONLY".

2) Quality assurance surveillance is conducted through the implementation of the Surveillance Activity Schedule in conjunction with the procedures outlined in this QASP and the specific contract performance requirements.

3) The Surveillance Activity Checklist is the generally accepted and utilized method of recording contract surveillance. The checklist is composed of the six columns and should be filled out each time surveillance is performed. A sample is provided at QASP Appendix C.

4) The results of quality assurance surveillance are recorded on the appropriate forms. In addition, a monthly requirements summary will be completed by each COR within five working days after the end of the month in which surveillance took place. This document should summarize significant results of surveillance. The COR is to retain the monthly requirements summary along with all back up documentation used to support the findings.

c. The COR or others performing the surveillance will keep the copy of the checklist. It will be available for periodic review by the CO.

d. A monthly COR report containing results of the completed checklist and other documentation as applicable will be provided to the CO for review and appropriate action. All documents will be annotated "FOR OFFICIAL USE ONLY".

9. Recording and Reporting Surveillance Actions

a. The surveillance checklist may reveal instances of serious or minor problems or areas on noncompliance with contract performance requirements by the contractor.

1) Serious problems or noncompliance requiring prompt contractor corrective action should be identified to the CO within three (3) business days using a Contract Discrepancy Report.

2) Minor problems or noncompliance may be reported when the monthly COR reports are submitted.

a. Validated complaints may be useful in quality assurance when the COR is not present. A "Customer Complaint Record", may be used to record the type of data needed to document customer complaints regarding contractor performance. Data includes the validity of the complaint, time, date and the responsible official notified, and the actions taken to correct the problem. The customer can prepare correspondence containing the complaint information and submit it through the COR to the CO. The correspondence will be verified and signed by the COR. If trends are noted in complaint correspondence, additional quality assurance measures should be considered.

b. A "Contract Discrepancy Report" (CDR) (DA Form 5479-R) is used to document serious performance problems or contract noncompliance on the part of the contractor. A blank CDR form can be found at QASP Appendix D and may be reproduced.

10. Remedies

a. The following actions are normally taken when poor performance is found as the result of quality assurance surveillance:

1) The COR will inform the contractors' project manager (or other contractor designated individual in charge of the effort) of the defect. If it is possible for the area of noncompliance or defect to be corrected, the contractor should be requested to do so.

2) If the government caused the contractor to perform in an unsatisfactory manner, the defect should not be counted against the contractor, and the COR will request that the CO ensure the government organization responsible takes corrective action. The government causes and corrective action will be documented.

3) If the area of noncompliance or defect is serious enough, a Contract Discrepancy Report (CDR) will be prepared by the COR and forwarded to the CO for resolution. The CO will be informed telephonically of the instance in advance of CDR submission. Instructions for completion of the CDR are contained at QASP Appendix E.

4) Depending on the type of noncompliance or defect, and whether or not it could be corrected immediately, the COR should schedule a follow-up inspection to ensure the problem does not continually reoccur.

QASP Appendix A Spot Checks

1. Spot checks are impromptu evaluations of contract performance requirements. They may be done concurrently with other quality assurance actions or simply when the COR feels there is a need to observe a particular work instance. Spot checks are a convenient and effective way to evaluate requirements that are performed on a regular basis, and can best be conducted during contractor performance.

2. Spot checks requiring contractor corrective action should be identified to the contractor's Project or Program Manager as soon as possible. Significant results or repetitive instances of noncompliance identified through spot checks should be reported on the monthly inspection report. The COR should consider supplementing spot checks with other methods of quality assurance surveillance when serious problems of noncompliance or poor quality trends are detected.

3. Spot check results should be accumulated weekly and reported monthly in the following format:

RESULTS OF SPOT CHECK

PWS Paragraph No.

Description of Requirement

Date/Time Satisfactory / Unsatisfactory

Remarks

QASP Appendix B Surveillance Activity Schedule

1. The DA Form 5475-R, "COR/QAE Surveillance Schedule", is prepared monthly by the COR. It indicates when the various contract requirements will be surveilled and should also indicate the method of surveillance. Any changes must be documented, posted to the schedule, and distributed in the same manner as the original schedule. Actual surveillance must be comparable to the monthly schedule. A complete audit trail should exist from the monthly schedule to the completed checklists to the monthly requirements summary.

2. To complete the schedule:

a. Insert the date prepared in the upper right hand block.

b. The left hand column should include the month and date of surveillance. After-hours, weekends and holidays should be scheduled when the contractor is performing. If desired, the COR may include the time of the various surveillance activities which will be conducted.

c. The five right hand columns are used to describe the work to be inspected and should also include the method of surveillance along with the PWS paragraph number. Additional copies of this form may be made for use as continuation sheets when needed to complete the schedule for a full month. When completed, the form is to be marked "For Official Use Only" and shall not be disclosed to the contractor. The form is to be prepared not less than five working days prior to the start of the month to be surveilled.

3. The form may be adapted to better suit the needs of the COR. Any such changes, however, are to be coordinated through the CO for approval and implementation.

QASP Appendix C Activity Surveillance Checklist

The following instructions are provided for completing this form:

a. The COR inserts the month and year in the upper right hand corner in the block entitled "DATE".

b. Place a brief description of the contract requirement in the block marked "CONTRACT

REQUIREMENT".

c. Insert the PWS paragraph number.

d. The COR inserts the method of surveillance and follows the instructions contained in the QASP for the column entitled "METHOD OF SURVEILLANCE".

e. The COR inserts the date that the inspection was completed in the column "DATE

ACCOMPLISHED".

f. The COR inserts in the column "WHERE ACCOMPLISHED" the place where surveillance was conducted.

g. In the column entitled "COMPLIANCE", the COR must note whether the contractor met the contract requirement and briefly give all pertinent details. Attach additional sheets as necessary.

(Contractor initialing is not required).

QASP Appendix D Validated Customer Complaints

1. DA Form 5477-R, "Customer Complaint Record", is used to record the type of data needed to document customer complaints regarding contract performance. Data includes the validity of the complaint, time and date the responsible official was notified, and the actions taken to correct the problem.

2. The contract requires the contractor have a customer complaint system. Use of the customer complaint procedures in this Appendix should supplement and validate the contractor's system, rather than duplicate it.

3. An aggressive customer complaint program assists the COR in focusing attention on weak performance areas or those that, due to time or criticality constraints, are not monitored as thoroughly. In addition, a customer complaint program builds rapport with the customers.

4. Once established, the program should be briefed to all district personnel involved. Operating instructions should be provided outlining the customer complaint program, the format and desired content of a complaint, and the action that can be expected as a result of the complaint.

5. The first four blocks of the customer complaint record can be executed either by the customer or by the COR based on customer input. The COR will complete the next four blocks. The COR will state in the block "Validation" an explanation of whether the complaint is considered valid or not, and the reasons why. The information included in "Action Taken by the Contractor" may be completed directly by the contractor's site manager or by the COR based on the contractor's input.

6. The form should be signed and dated by the COR in the block "Received and Validated by". A copy of the completed and validated complaint should be provided to the contractor for file, and the original retained by the COR. Significant validated complaints should be included in the monthly requirements summary as should any repetitive validated complaints. Where trends are noted through the complaint program, the COR should consider instituting additional quality assurance surveillance measures.

CUSTOMER COMPLAINT RECORD

Date of Complaint: ____________________ Time of Complaint: ___________________

Source of Complaint: __________________ School/Facility: ______________________

Individual: ___________________________ Contract Reference: __________________

Nature of Complaint:

Validation:

Date/Time Contractor Informed: ________________

Action Taken by Contractor:

Date Received/Validated by:

QASP Appendix E Contract Discrepancy Report

1. The DA Form 5479-R, "Contract Discrepancy Report", is used to document discrepancies in performance by the contractor and to describe those discrepancies. When used, it should be signed by the contracting officer. The contents should include the contractor's explanation for the problem and the corrective action he or she intends to take, as well as the government's evaluation of the contractor's response, and the action the government intends to take. When completed and signed, the DA Form 5479-R, along with any supporting documentation, forms a documentary base supporting any action deemed necessary to ensure the contractor's compliance with the contract provisions.

2. The form is to be completed and processed essentially as follows:

a. The COR ("QAE" on the form) will complete blocks 1-4 on the report, including date prepared and oral notification date, and forward the report through the COR to the contracting officer. (Note: In some cases the QAE may be serving the position of COR.)

b. The blocks assigned for dates are used to track the completion and disposition of all actions required by the CDR.

c. The contracting officer will sign in block 5 and forward the original of the report to the contractor, suspense a copy for contractor response within two calendar weeks.

d. The contractor will complete blocks 6-10 and return the report to the contracting officer.

e. The contracting officer will annotate the date returned by the contractor and forward the report for the COR’s response. The COR will complete block 11 within five working days.

f. After block 11 is completed, the COR will return the original of the report to the contracting officer, who will complete block 12, insert date action complete, and close out the form by forwarding copies to the contractor and COR, noting name, title, and date of notification. Only the signature of the contracting office is needed to close out the report.

g. The final block entitled "Close Out" is completed by each of the individuals specified so that completion of the CDR process is acknowledged by all parties.

3. Letters of transmittal will accompany the report only to the extent it is necessary to ensure positive accountability is maintained through the mail, and that instructions and suspense dates are clear.

4. Care must be taken that procedures are established to ensure the report is completed and closed out within 30 calendar days from date of preparation, unless an exception is warranted due to complexity of the issue.

5. All instances where a CDR is issued will be reported in the monthly COR report and brought to the attention of the CO.

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