31_Attachment_J-21_DRAFT_QASP.doc

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TRICARE Quality Monitoring Contract (TQMC)
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HT9402-15-R-0005
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Section J Attachment J-21

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Attachment J-21 Draft Quality Assurance Surveillance Plan (QASP)

Quality Assurance Surveillance Plan

TRICARE Quality Monitoring Contract (TQMC) Contract Number: HT9402-15-D-XXXX Contract Description: This contract provides for services and materials to support the management of clinical quality in the Military Health System (MHS). The activities focus on the continuous assessment, analysis and reporting on the quality of direct and purchased healthcare provided in the MHS.

The purpose of the TQMC is to assist the Clinical Support Division (CSD) in assessing and improving the quality of care delivered under the TRICARE benefit across the direct and purchased care systems. This contract will assist DHA in decreasing unwarranted variation in the quality of medical care, implementing proven clinical and business practices, and creating an environment for learning and continuous improvement across the MHS. This contract will also support DHA with the management of clinical quality performance measurement to validate the quality of care.

TRICARE quality monitoring is accomplished through a variety of tasks supporting the direct care and purchased care systems. These tasks include external, third-party data collection, analysis and reporting of clinical quality measures, and comparison with national healthcare benchmarks; reviewing, evaluating, and reporting on published clinical care studies, evolving practices, and other data to identify superior quality healthcare services and recommend means to transfer successes; and conducting comprehensive, timely medical peer reviews to ensure medically-appropriate healthcare is provided per 32 CFR 199.

Contractor’s name: (hereafter referred to as the contractor).

1.0 PURPOSE:

1.1 This Quality Assurance Surveillance Plan (QASP) provides a systematic method for the Government to evaluate the contractor’s 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

1.2 The contractor is responsible for implementing and delivering performance that meets contract standards using its Internal Quality Management Plan (CDRL AP020). The QASP provides the structure for the government's surveillance of the contractor's performance to assure that it meets contract standards. It is the Government's responsibility to be objective, fair and consistent in evaluating contractor performance.

1.3 The QASP is not part of the contract nor is it intended to duplicate the contractor's quality control plan. This QASP is a living document. Flexibility in the QASP is required to allow for an increase or decrease in the level of surveillance necessary based on contractor performance.

1.4 The Government may provide a copy of the QASP to the contractor to facilitate open communication. In addition, the QASP should recognize that unforeseen or uncontrollable circumstances might occur that are outside the control of the contractor. The QASP should ensure early identification and resolution of performance issues to minimize impact on mission performance.

1.5 Authority: Authority for issuance of this QASP is provided under Federal Acquisition Regulation (FAR) 46, Quality Assurance; which provides for inspection, acceptance and documentation of the service called for in the contract or order.

2.0 Government Roles and Responsibilities:

The following personnel shall oversee and coordinate surveillance activities:

a. Contracting Officer (CO).The CO 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 CO shall also assure that the contractor receives impartial, fair, and equitable treatment under this contract. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance.

Contracting Officer: Margaret Zancanella Organization or Agency: Defense Health Agency/COD-A, Aurora, CO Telephone: (303) 676-3451 Email: Margaret.A.Zancanella.civ@mail.mil

b. Contracting Officer’s Representative (COR).The COR is responsible for the technical administration of the contract and shall assure proper Government surveillance of the contractor’s performance. The COR shall keep a quality assurance file. At the conclusion of the contract or when requested by the CO, the COR shall provide documentation to the CO. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government’s behalf. The contractor shall refer any changes it deems may affect contract price, terms, or conditions to the CO for action.

Assigned COR: TBD Telephone:

Email:

c. Other Key Government Personnel – Title: Program Manager, Dr. Barry Cohen Telephone:

Email:

3.0 Contractor Representatives:

The following TQMC employees are the contractor’s designated point(s) of contact for contract performance:

a. Program Manager - Telephone:

Email:

b. Task Manager - Telephone:

Email:

c. Other Contractor Personnel -

Title:

Telephone:

Email:

4.0 Performance Standards:

4.1 The performance standards define the level of service required under the contract for the contractor to meet each performance objective in Section C, TQMC Performance Work Statement (PWS). The contract and task orders will specify quality performance metrics and the Acceptable Quality Levels (AQLs) as the standards the Government requires from the contractor’s performance of services. The Government will perform surveillance to determine if the contractor exceeds, meets or does not meet these standards.

4.2 The Government shall compare the contractor’s performance to the minimum Acceptable Quality Levels (AQLs) in the Performance Standards Summary Matrix below.

Table 1, Performance Standards Summary Matrix

Task
Indicator
Standard
Acceptable Quality Level
Method of Surveillance
External Reviews of MTF SOC/QOC Cases
Completed by appropriate specialist in timely manner
The contractor provides a deliverable CDRL R010, Standard of Care and Quality of Care Reviews.
Completed within 30 days of receipt of the record from the respective service. 100% of reviews performed according to standard (CDRL R010)
Observation and review of completed SOC/

QOC cases

Posting of MHS Clinical Quality Measures to secure web site
Measures data posted for Hospital Quality Measures, and Population Health / Disease Management measures
The contractor provides deliverable CDRL Q010, Health Plan Data Reporting.
Behavioral health facilities certified according to guidance in attachment J-7. A monthly list of certified facilities shall be provided (CDRL M050) and a report of each on-site certification visit submitted (CDRL R030) 100% of reviews will be performed in accordance with standards
Review of completed certification reports and monthly facility listings
Annual HEDIS® Audit
Annual audit of Population Health Portal by certified HEDIS® auditor
The contractor provides deliverable CDRL A010, Annual HEDIS® Compliance Audit.
Annual audit of Population Health Portal by NCQA-certified auditor (CDRL A010). Audit will be conducted in full accordance with NCQA standards
Oversight of annual HEDIS® audit and audit process
Submission of ORYX® Data to Joint Commission and data posted to secure web based site
ORYX® Data Submission to Joint Commission meets accreditation requirements
The contractor provides deliverable CDRL Q020, ORYX® Data Reporting.
Ongoing data abstraction and collection with quarterly analysis and report of data (CDRL Q020); on-time quarterly data submission by certified vendor per Joint Commission guidelines. (CDRL Q030) 100% of charts will be abstracted correctly and all data submissions will be performed on time.
Monthly Clinical Measures Steering Panel reports and periodic inspections of secure web based site; customer feedback. Validation by Services that ORYX® data is received on time.
Medical Necessity Reviews (2nd Level Appeals)
Reconsideration reviews performed by appropriate staff according to timelines
The contractor provides a deliverable CDRL R020, Medical Necessity Appeals &Hearings Reviews.
Reconsiderations and reviews performed by appropriate personnel in accordance with TOM Chapters 12 and 24, and guidance prescribed in CDRL R020. 100% of reviews will be performed according to standard
Observation and review of completed Reconsideration cases
Behavioral Health Facility Certification
BH Facilities certified according to requirements
The contractor provides deliverable CDRL M050, Behavioral Health Certification List and CDRL R030, Facility Assessment Report.
Behavioral health facilities certified according to guidance in attachment J-7. A monthly list of certified facilities shall be provided (CDRL M050) and a report of each on-site certification visit submitted (CDRL R030) 100% of reviews will be performed in accordance with standards
Review of completed certification reports and monthly facility listings
Assessment of Evolving Practices, Devices, Treatments & Procedures
Long and Short technology assessments performed per requirements
Technology assessments conducted per guidance in CDRL R040
Assessments performed per requirements and in CDRL R040. 100% of assessments will be performed in accordance with the guidance given for the tasking.
Review of the short and long assessments
Clinical Quality Studies
Study work products including methodology, IRB approval, Data Use Agreement, Reports, manuscript and educational materials provided to the Scientific Advisory Panel in a complete and timely manner
The contractor provides deliverable CDRL R050, Clinical Quality Studies
Studies performed per requirements and in CDRL R050. 80% of work products will be submitted on-time.
Observation and monthly Scientific Advisory Panel Reports
Autism Care Demonstration Study
Conduct an annual study to assess the quality of Applied Behavior Analysis (ABA) provided to TRICARE beneficiaries with Autism Spectrum Disorder (ASD) by doctoral level Board Certified Behavior Analysts (BCBA-Ds), master’s level Board Certified Behavior Analysts (BCBAs), Board Certified Assistant Behavior Analysts (BCaBAs), and Behavior Technicians
The contractor provides deliverable CDRL A030, Autism Demo Quality Management Report.
Ongoing assessment of the quality of Applied Behavioral Analysis treatment provided to TRICARE beneficiaries with Autism Spectrum Disorder with annual report (CDRL A030). 100% of annual reports will be completed on-time in accordance with the guidance given for the tasking
Review of annual reports to ensure completeness.
National Healthcare Quality Measures (NHQM)
Prepare and analyze NHQM as required.
The contractor provides deliverable CDRL Q050, NHQM Data File.
Quarterly download of the NHQM data from the CMS Hospital Compare website with analysis and comparison of facilities by region (CDRL Q050) 100% of data will be downloaded and analyzed correctly
Review of quarterly reports and analysis of data
Knowledge Development and Meeting Support
Develop & post online educational materials. Meeting support for MHS Quality Forum, Risk Management, Clinical Measures Steering Panel and Scientific Advisory Panel completed on time
The contractor provides deliverables CDRL M070, Knowledge Development and R060, Meeting Support.
Knowledge development with monthly seminars affording CME/CEU as appropriate (CDRL M070), meeting support for DHA quality committees (CDRL R060), and maintenance of the Clinical Quality website. 80% of monthly seminars will be conducted on-time and be relevant to audience.
Observation and review of seminar material posted to website
Program Management
COOP & IQMP submitted annually as required; single program manager identified
The contractor provides deliverables CDRL AP010, COOP; CDRL AP030, Annual Program Management Plan; and Q080, Internal Quality Management Report.
Contractor has a single manager identified; COOP submitted 30 days after contract award; CDRL AP010, 10 days after contract award, CDRL AP030, 5 days after contract award, and CDRL Q080 submitted quarterly. 100% timely submission of all plans; program manager clearly identified and engaged. Further submissions identified in CDRLs.
Observation and interaction with PM
Complete Monthly Progress Report
Completed in a timely manner
The contractor provides deliverable CDRL M060, Monthly Progress Report.
Monthly progress reports submitted outlining progress, status, issues encountered, and workload (CDRL M060). 90% of monthly reports will be completed on time
Observation of monthly reports
Quality & Utilization Reviews
Review medical, surgical, and mental health cases to determine the medical necessity and appropriateness of care.
The contractor provides a deliverable CDRL Q070, Purchased Care Contractor Performance Report.
Reviews performed on all purchased care medical records in accordance with 32 CFR 199.15. Contractor performance with medical record submission and response to issues is reported to the Government quarterly. 98% of reviews will be performed according to standard (CDRL Q070) and the contractor shall demonstrate at least 95% Inter-Rater Reliability among its reviewers
Review of quarterly report and feedback from purchased care contractors
Institute for Healthcare Improvement (IHI) Global Trigger Tool (GTT)
Utilize the IHI GTT for review of inpatient records
The contractor provides deliverable CDRLs M020, GTT-MTF Report; M030, GTT-Service and System Level Reporting; M040, GTT FAQ Report
Monthly review of 20 inpatient records at all inpatient MTFs utilizing IHI methodology with report to MTF, Services and DHA (CDRLs M020, M030, M040) 100% of medical records will be reviewed according to IHI standards
Review of monthly reports and customer feedback; review of FAQs report from contractor

5.0 Incentives:

5.1 As defined in the Section H, Special Contract Requirements, paragraph 1.0, Performance Guarantees, the government will assess performance guarantees to the Section C, tasks defined in paragraphs 6.3.3 and 6.5.

6.0 Methods of QA Surveillance:

6.1 Various methods exist to monitor performance. The COR may use the surveillance methods listed below in the administration of this QASP.

6.2 Regardless of the surveillance method, the COR will contact the contractor's designated point of contact when a defect is identified and inform the manager of the specifics of the problem. The COR shall be responsible for monitoring the contractor’s performance in meeting a specific performance standard/AQL.

a. Direct Observation: (Can be performed periodically or through 100% surveillance.)

· Study work products including methodology, IRB approval, Data Use Agreement, Reports, manuscript and educational materials provided to appropriate recipients in a complete and timely manner

· Meeting support for MHS Quality Forum, Risk Management, Clinical Measures Steering Panel, Scientific Advisory Panel, Perinatal Advisory Group, Infection Prevention and Control Panel, and Medical Directors’ Forum completed on time

· On-line educational materials from the studies developed and posted timely

· Behavioral Health Facility surveys complete and well-written with appropriate recommendations for certification, recertification or decertification

· Standard of Care reviews and reconsideration reviews performed by appropriate peer reviewers within prescribed timelines

b. Management Information Systems (MIS): (Evaluates outputs through the use of management information reports. Best used for general surveillance and may need to be supplemented by periodic inspections.) DHA E-Commerce Extranet Performance Assessment Tool

· Study work products including methodology, , Data Use Agreement, Reports, manuscript and educational materials provided to the Scientific Advisory Panel in a complete and timely manner

c. Periodic Inspection: (Uses a comprehensive evaluation of selected outputs. Inspections may be scheduled [Daily, Weekly, Monthly, Quarterly, or annually] or unscheduled, as required.)

· Availability of secure web-based access

· ORYX® Data Submission to Joint Commission meets accreditation requirements

· Annual HEDIS® audit performed by certified auditor in appropriate manner

d. User Survey: (Combines elements of validated user complaints and random sampling. Random survey is conducted to solicit user satisfaction. Appropriate for high quantity activities that have historically been satisfactory. May also generate periodic and 100% inspections.)

· On-line educational materials from the studies develop and post timely.

e. Validated User/Customer Complaints and Compliments: (Relies on the user of the service to identify deficiencies. Complaints are then investigated and validated. Highly applicable to services provided in quantity and where quality is highly subjective.)

· Availability of secure web based access

· ORYX® Data Submission to Joint Commission meets accreditation requirements

f. Progress or status meetings:

· All tasks

g. Analysis of contractor's progress reports: (Evaluate cost, schedule, etc.)

· All tasks

h. Surveillance results may be used as the basis for actions (to include payment deductions) against the contractor: In such cases, the Inspection of Services clause in the Contract becomes the basis for the KO’s actions.

7.0 Ratings:

Metrics and methods are designed to determine if performance exceeds, meets, or does not meet a given standard and AQL. A rating scale shall be used to determine a positive, neutral, or negative outcome. The following ratings shall be used:

Rating
Definition
Exceptional
Performance meets contractual requirements and exceeds many to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with few minor problems for which corrective actions taken by the contractor was highly effective.
Very Good
Performance meets contractual requirements and exceeds some to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor was effective.
Satisfactory
Performance meets contractual requirements. The contractual performance of the element or sub-element contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory.
Marginal
Performance does not meet some contractual requirements. The contractual performance of the element or sub-element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented.
Unsatisfactory
Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The contractual performance of the element or sub-element contains a serious problem(s) for which the contractor’s corrective actions appear or were ineffective.

8.0 DOCUMENTING PERFORMANCE:

a. Acceptable Performance: The Government shall document positive performance as part of its ongoing surveillance.

b. Unacceptable Performance: Unacceptable performance is contractor performance that is less than satisfactory or fails to meet the stated AQLs or other contract requirements. When unacceptable performance occurs, the COR shall notify the contractor in writing unless circumstances necessitate verbal communication. In any case the COR shall document the discussion of unacceptable performance with a courtesy copy to the CO and place it in the COR file.

The COR 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 COR will also state how long after receipt the contractor has to present this corrective action plan to the COR. The Government shall review the contractor's corrective action plan to determine acceptability.

The contractor shall acknowledge receipt in writing of the COR’s notification of unacceptable performance. Any COR notifications of unacceptable performance may become a part of the supporting documentation for contract payment deductions, or other actions deemed necessary by the CO.

c. The COR and CO will use all performance documentation to complete the annual contractor’s performance evaluation in the Contractor Performance Assessment Report System (CPARS) per FAR 42.15, Contractor Performance Information.

9.0 Frequency of Measurement:

a. Frequency of Measurement:

During contract/task order performance, the COR shall take periodic measurements, as specified in the AQL column of the Performance Standards Summary Matrix, and shall analyze whether the negotiated frequency of measurement is appropriate for the work being performed.

b. Frequency of Performance Assessment Meetings:

The COR shall meet with the contractor as often as necessary to assess performance. If performance is less than satisfactory, the COR shall meet more frequently until the contractor’s performance is at least satisfactory. The COR shall document all performance assessment meetings, including the topics discussed, action items and their status until closed. The COR shall provide a copy of performance meetings to the CO

Prepared by:

Signature – Contracting Officer’s Representative

Performance Report

1. CONTRACT NUMBER:

2. Prepared by: (Name of COR)

3. Date and time of observation:

4. Observation:

Prepared by:

Signature – Contracting Officer’s Representative

Date

TQMC HT9402-15-R-0005, Section J, Attachment J-21

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