Attachment_J_-_Quality_Assurance_Surveillance_Plan_(QASP).docx

Quality Assurance Surveillance Plan Attachment 3 Quarterly Performance Assessment Report (PAR) Template

November 1, 2016

Requesting Organization/Office Symbol: Pentagon Force Protection Agency / Leased Facilities Protection Directorate / Contract Operations Division (PFPA/LFPD/COD) Contracting Officer Representative, Program Manager: Brian Link

Accepted by: Washington Headquarters Services / Acquisition Directorate (WHS/AD) Contracting Officer: Stephanie Powell

TABLE OF CONTENTS

TABLES

ATTACHMENTS

1.0 SCOPE. The Quality Assurance Surveillance Plan (QASP) is applicable to personnel performing contract surveillance audits in accordance with (IAW) Federal Acquisition Regulation (FAR) Part 46, Quality Assurance; Department of Defense FAR Supplement (DFARS) Subpart and PGI 201.602-2, Contracting Officer Responsibilities; and organizational policy. It is designed to provide the Contracting Officer Representative (COR) a systematic surveillance method for each service identified in the Performance Work Statement (PWS) for each contract. The owning customer and COR develop the methods for administering and evaluating contract performance.

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

1.2 Application: This QASP is used by all parties involved with assessing Contractor performance. The Contractor may receive a courtesy copy in order to further enhance communications with the Contractor, but shall not be considered as part of the contract.

2.0 MANAGEMENT LOCATIONS AND KEY PERSONNEL.

2.1 The responsible Contracting Office is:

Washington Headquarters Services / Acquisition Directorate (WHS/AD) 1225 South Clark Street, Suite 1202 Arlington, VA 22202

2.2 Contracting Management Team.

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

2.2.2. Contract Specialist (CS) The CS is the Government agent within the contracting office who performs day-to-day administration of the contract. The CS may also be the CO if the person has a warrant.

2.2.3. Contracting Officer Representative (COR). The COR is ultimately responsible for implementing all QA matters and procedures. COR(s) should be at a level where other duties don’t prevent proper oversight of Contractor performance. The COR must maintain both technical competency and evaluation proficiency in Contractor surveillance procedures. The COR must also have enough knowledge of Contractor activities to properly review and disposition monthly invoices.

2.3 Contractor Key Personnel. Company Name - Office address, and Commercial Number

2.3.1 Project Manager. The Contractor’s Project Manager is responsible for the overall execution of the task order. This individual will serve as the focal point for the COR/CO assigned to the contract and will interface with the Government, as needed.

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

3.1 Surveillance Methods. Three primary methods of surveillance are normally used: one hundred percent inspection, periodic sampling, and customer complaints. Other methods of surveillance must be fully documented and approved by the CO before implementation. Information obtained from these activities may be used to ascertain whether or not Contractor performance is compatible with contract and mission objectives and by the CO for actions relating to the Contractor.

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

3.1.2 Periodic Audit. This type of surveillance consists of evaluating products/services not surveyed via one hundred percent inspection or by customer survey, and is implemented at a pre-defined frequency. An example of periodic audit is performing monthly inspections of class training conducted by the Contractor or weekly inspection of a Contractor’s process in developing training manuals.

3.1.3 Customer Survey or Customer Complaint. Although usually not a primary method, this is a valuable supplement to other, more systematic methods of surveillance. For example, in a case where random sampling indicates unsatisfactory service, customer complaints can be used as substantiating evidence. In certain situations, where customers complain consistently when the quality of performance is poor, customer surveys and customer complaints may be a primary surveillance method, and customer satisfaction an appropriate performance standard. In all cases, complaints will be documented, preferably on a standard form. All customer complaints will be forwarded to the COR. Information obtained from customer complaint activities may be used by the CO for actions relating to the Contractor.

3.2 Surveillance Documents.

3.2.1 Deliverables. All deliverables will be reviewed for timeliness, accuracy and format. If a deliverable due date falls on a weekend or holiday, the Contractor shall submit the deliverable on the last work day prior to the due date.

Table 1 – Deliverables

10.2.8.

DD Form 2249, DoD Building Pass

Government Format

Within 30 days of start for each CSO

COR

As required

*Standard Distribution: 1 copy of the transmittal letter without the deliverable to the Contracting Officer; 1 copy of the transmittal letter with the deliverable to the Primary COR.

3.2.2

3.2.3 Services Summary. The Services Summary is a list of critical tasks that must be performed by the Contractor, the performance threshold, and the method of surveillance the COR will use to validate/inspect these tasks. Inspection of each task will be documented in the COR folder.

Table 2 – Services Summary

10.2.8.

DD Form 2249, DoD Building Pass

Government Format

Within 30 days of start for each CSO

COR

As required

*Standard Distribution: 1 copy of the transmittal letter without the deliverable to the Contracting Officer; 1 copy of the transmittal letter with the deliverable to the Primary COR.

3.2.4 Surveillance Checklist (Attachment 3). The COR is responsible for developing standard procedures for Surveillance Checklists; the Surveillance Checklist serves as the guideline for all inspections. As a minimum, the Surveillance Checklist will include the items in the Services Summary and Deliverables Tables. The COR may also add other inspection activities/surveillance items to the Surveillance Checklist, with applicable PWS references. These items may fluctuate throughout the course of the contract based on customer needs, identified risks, or issues related to Contractor performance. The COR will document all inspections conducted using the Surveillance Checklist and maintain them in the COR folder.

3.3 Assessing Performance. CORs must document Contractor performance on each contract, as well as the scope and purpose of any inspections. Documentation will be maintained in the COR’s monthly log. CORs will also assess and rate Contractor performance as it relates to contract requirements. Performance Assessment may take the form of notes in the monthly log, assessment results from the Surveillance Checklist, non-conformance notifications, and annual Contract Performance Assessment Reports (CPAR). Each builds on the other and provides a thorough documented history of Contractor performance.

3.3.1 Monthly Logs. The COR shall maintain a monthly log documenting Contractor performance for each month during the performance of the contract. These months should follow the period of performance of the contract. The monthly log should document both good and less than desirable performance issues, concerns, highlights or non-conformances and can be used to document any correspondence with the Contractor. This log serves as the basis for any formal documentation of non-conformances or deficiencies and provides the backbone for formal reports on Contractor performance. The log also provides continuity should COR duties shift in the course of contract performance.

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

3.3.3 Non-conformances and Deficiencies. Audit or Inspection results that fall below contractual standards shall be identified as non-conformances or deficiencies. The COR will notify the contactor IAW para 3.3.3.2 and document all non-conformances in the monthly log, referencing the specific PWS requirement that the Contractor did not meet, document the name of the individual contacted, and date and time of notification. If the Contractor fails to take corrective actions in a reasonable time-frame, the COR will notify the CO for further actions.

3.3.3.1 Types of Non-conformance.

3.3.3.1.1 Minor Non-conformance: A minor non-conformance is a non-conformance, which by itself does not adversely impact mission, safety of personnel and/or equipment, performance (quality), schedule (delivery), or cost. A minor non-conformance normally does not increase risk to the Government.

3.3.3.1.2 Major Non-conformance: A major non-conformance is a non-conformance that adversely impacts mission, safety of personnel and/or equipment, performance (quality), schedule (delivery), or cost. A major non-conformance also increases risk to the Government. An example of increasing risk would be significant number of recurring non-conformances, which indicates inadequate preventive measures or actions, thus lowering the Government’s confidence that quality services will be provided on time and at cost.

3.3.3.2 Non-conformance Notification. If a deficiency is found during inspection of the Contractor’s performance, the COR will determine the type of notification based on the category of the non-conformance (see Table 3) and pursue non-conformance resolution per paragraph 3.4.

TABLE 3 – NON-CONFORMANCE NOTIFICATIONS.

Minor

Step 1: First Notice Step 2: Second Notice

3.3.3.2.1 First or Second Notices (see Attachment 1). As shown in Table 3, First and Second Notices provide written notification from the Government to the Contractor of minor non-conformances. Initial minor non-conformances should be addressed with a First Notice to the applicable Contractor representative. The COR will notify the CO of the issue, and prepare the notice. The COR will provide a final, signed copy to the CO. The CO will provide First and Second notices to the contractor with a suspense date for the contractor’s reply. If the Contractor fails to respond by the specified due date, the COR will notify the CO for action and annotate the Contractor’s non-responsiveness. If the Contractor fails to resolve the issue as documented in the Notice, the COR should elevate the issue to the next level (Second Notice or CAR). Corrective/preventive actions initiated and/or completed by the Contractor will be verified by CORs on the scheduled inspection and documented accordingly.

3.3.3.2.2 Corrective Action Requests (CAR) (see Attachment 2). As shown in Table 3, a CAR provides written notification from the Government to the Contractor of significant performance discrepancies. The Primary COR will recommend to the CO that a CAR be issued when previous notifications failed to result in corrective actions or when severe deficiencies exist. The draft CAR will be routed NLT ten duty days after the event to the CO for review and signature, as the CO is the only person who has authority to issue a CAR to the Contractor.

3.3.3.2.2.1 To satisfactorily close-out a CAR, the following criteria must be met: the Contractor must meet the suspense; the corrective action must have already begun; and the Contractor's actions must correct the deficiency and if applicable, be within specified standards.

3.3.3.2.2.2 If the corrective action is deemed UNSATISFACTORY by the COR, annotate the CAR accordingly and forward it to the CO with a brief explanation, including an estimate of the Government's loss due to the deficient performance. The estimate may account for loss or destruction of property, supplies, or equipment, and hours lost to re-perform the task. If the task cannot be re-performed, indicate the number of hours it ordinarily would have taken to do the task.

3.3.3.2.3 The COR will maintain a non-conformance log documenting all First and Second Notices and CARs. The log will include the date sent to the Contractor, issue, due date for response and actual response date. If a detailed response is required, include a link to the response and include the response in the applicable COR folder tab.

3.3.4 Monthly Services Summary Reporting – CORs will perform services summary inspections (table 2) and update monthly.

3.3.5 Quarterly Performance Assessment Report (PAR) (Attachment 4). The COR will accomplish quarterly PARs documenting Contractor performance for the preceding quarterly performance period. This is a critical document giving the CO performance oversight on all services and ensures all products during the quarterly period were provided to the Government IAW all contract requirements. The COR will provide the CO a copy of the completed report.

3.3.3.3 Quarterly PAR Evaluation Categories. The quarterly PAR will also provide a brief summary of Contractor performance covering, as applicable, the categories in Table 4 below.

TABLE 4 – PERFORMANCE ASSESSMENT REPORT (PAR) EVALUATION CATEGORIES

3.3.3.4 Performance Rating Definitions. The COR rates each of the quarterly PAR categories, as applicable, based on the Contractor’s actual performance during the reporting period (see Table 5 below). These ratings can also be used for inputs to the monthly log and serve as a basis for CPARs. Ratings will not be arbitrary or reflect an emotional assessment of the Contractor’s performance. Any ratings other than ‘Meets Standards’ must be appropriately justified. For instance, if the COR rates the Contractor’s performance as ‘Exceeds Standards,’ the COR must show what part of the PWS was exceeded and how that benefitted the Government.

TABLE 5 – PERFORMANCE RATING DEFINITIONS

3.3.4 Annual Contract Performance Assessment Reporting System (CPARS) – The Contractor Performance Assessment Reporting System (CPARS) http://www.cpars.gov is the Department of Defense (DoD) Enterprise Solution for collection of Contractor Past Performance Information (PPI) as required by the Federal Acquisition Regulation (FAR). CPARS is a web-enabled application that collects and manages a library of automated Contractor report cards. An annual CPAR will be written on all contracts that exceed $1M total contract value. The COR will be designated as the Assessing Official Representative (AOR) in CPARS; the written assessment in CPARS will begin annually from the start date of the contract and forwarded to the Contract Manager within 60 days of the contract start date anniversary. The AOR will use objective evidence from previous quarterly PARS, monthly Services Summary, inspection logs, 1st/2nd notices, CARS, and correspondence letters for CPARs assessment. A CPARS quality checklist is available at the following link: http://www.cpars.gov/cparsfiles/pdfs/CPARSQualityChecklist.pdf

4.0 WIDE AREA WORK FLOW (WAWF). The COR will accept or reject all Receiving Reports submitted by the Contactor in WAWF within 7 days of submittal by the Contractor.

To access the receiving report, log into WAWF, select the Government, Acceptor, Acceptance Folder tab; then type in the contract number. The Shipment Number column in WAWF is the Receiving Report number.

4.1 Validating Receiving Reports. The COR will review and validate all WAWF receiving reports (Shipment Number in WAWF) ensuring that:

· The Contractor submitted a combination invoice/receiving report

· The report reflects the correct contract number

· Beginning and ending dates being billed are stated and accurate

· The correct CLIN(s) is(are) charged for billing period

· A description of the services is provided (Firm Fixed Price)

· The correct amount is charged, only charged for hours worked

· Back-up documentation is attached that includes a Contractor invoice with current and cumulative hours and amounts, as applicable

· A breakout of any other charges, as agreed to by the CO or required by the contract, is attached in WAWF or has been provided to the COR

4.1.1 COR Expenditure Log. After certification of an invoice in WAWF, the Primary COR will update the expenditure log documenting/tracking certified invoice expenditures against funds allocated on the contract against each CLIN. Funding belongs to the organization where the COR resides; the COR expenditure log allows the COR to ensure that funds are available for the work performed, to include travel and materials.

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

· List details regarding all unsatisfactory services or incorrect invoice information

AND

· Instruct the Contractor to contact DFAS to have the invoice rejected back to the Contractor; this will allow the Contractor to make the same correction on both the receiving report and invoice, since combination invoices/receiving reports are required

4.3 The rejecter will then return to the Header tab and click the “Reject to Initiator” block. Anyone other than the COR may reject receiving reports in WAWF, but only when services/invoices have been reviewed and rejected by the COR in writing per the paragraph above. After rejecting the receiving report, e-mail the CO the contract number, receiving report number, and reason for rejection.

5.0 COR FOLDER. The Primary COR will establish and maintain a COR folder for each task order. The COR folder must contain the tabs and contents outlined below in Table 6. ALL surveillance records are considered FOR OFFICIAL USE ONLY documents, and must be marked and safeguarded as such. Documentation is kept for the life of the contract and provides necessary continuity should COR duties transition during the course of the contract. The COR will receive instructions from the CO on disposition or archival procedures upon contract completion.

TABLE 6 – COR FOLDER TABS & CONTENTS

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

FROM: WHS/AD

SUBJECT: First/Second Notice for Contract for (brief name for non-conformance) on FA4890-11-D-000X)

1. Contracting Officer Representative: Brian F. Link

2. Office: PFPA/LFPD/COD

3. Date of First Notice: (if 2nd notice)

4. Date response due from Contractor: (dd-mmm-yyyy)

5. Requirement Reference: (PWS section and paragraph; Deliverable, Services Summary (SS))

6. Performance Requirement: (State what action the Contractor should have performed IAW the reference above)

7. Description of Non-Conformity: (provide objective evidence of the Contractor’s performance discrepancy(ies))

(CO signature block))

Attachment 1 Corrective Action Request (CAR) Template Quality Assurance Surveillance Plan

Quarterly Performance Assessment Report (PAR) Template

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

CSO Surveillance Checklist

Report #:

CSO Name:

CSO’s Company:

Location:

Date/Time:

Reporting LFPD Officer or Physical Security Inspector:

Standard and Reference Cited:

___ Below Standard / ___ Above Standard

Brief Summary:

When complete, email this page to: pfpa.pentagon.lfpd.mbx.cod@mail.mil