MH_PRODUCTION_IPIA_AND_STATE_ADMINISTRATIVE_AGENCY_DRAFT_QASP.doc

Quality Assurance Surveillance Plan (QASP)

MANUFACTURED HOUSING PRODUCTION INSPECTION PRIMARY INSPECTION AGENCY AND STATE ADMINISTRATIVE AGENCY MONITORING AND INSPECTION SERVICES

08/23/2017

Version 1.0

31 Vision

1 INTRODUCTION

1.1 Purpose

1.2 Performance Management Approach

1.3 Performance Management Strategy

2 ROLES AND RESPONSIBILITIES

2.1 The Contracting Officer

2.2 The Contracting Officer Representative

3 IDENTIFICATION OF REQUIRED PERFORMANCE STANDARDS/QUALITY LEVELS

4 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 Surveillance Techniques

4.2 Customer Feedback

4.3 Acceptable Quality Levels

5 QUALITY ASSURANCE DOCUMENTATION

5.1 The Performance Management Feedback Loop

5.2 Monitoring Forms

6 ANALYSIS OF QUALITY ASSURANCE ASSESSEMENT

6.1 Determining Performance

6.2 Reporting

6.3 Reviews and Resolution

6.4 Surveillance Matrix

Appendix 1 - Surveillance Matrix Appendix 2 - Corrective Action Report (CAR) Appendix 3 - Customer Complaint Record Appendix 4 - Performance Assessment Report (PAR)

Quality Assurance Surveillance Plan (QASP) MANUFACTURED HOUSING PRODUCTION INSPECTION PRIMARY INSPECTION AGENCY AND STATE ADMINISTRATIVE AGENCY MONITORING AND INSPECTION SERVICES

1 Vision

The vision of the IPIA and SAA monitoring and inspection services is to provide verification that each HUD-approved Production Inspection Primary Inspection Agency (IPIA) and each State Administrative Agency has adequately performed all the relevant functions and responsibilities each organization is responsible for per regulations.

1 INTRODUCTION

This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the Performance Work Statement (PWS) entitled MANUFACTURED HOUSING PRODUCTION INSPECTION PRIMARY INSPECTION AGENCY AND STATE ADMINISTRATIVE AGENCY MONITORING AND INSPECTION SERVICES. This plan sets forth the procedures and guidelines the Office of Manufactured Housing will use in ensuring the required performance standards or service levels are achieved by the Contractor.

1.1 Purpose

1.1.1 The purpose of the QASP is to describe the systematic methods used to monitor performance and to identify the required documentation and the resources to be employed. The QASP provides a means for evaluating whether the Contractor is meeting the performance standards/quality levels identified in the PWS and the Contractor's Quality Control Plan (QCP), and to ensure that the Government pays only for the level of services received.

1.1.2 This QASP defines the roles and responsibilities of all members of the Integrated Project Team (IPT), identifies the performance objectives, defines the methodologies used to monitor and evaluate the Contractor's performance, describes quality assurance documentation requirements, and describes the analysis of quality assurance monitoring results.

1.2 Performance Management Approach

1.2.1 The PWS structures the acquisition around "what service or quality level is required", as opposed to "how the Contractor should perform the work" (i.e., results, not compliance). This QASP will define the performance management approach taken by the Office of Manufactured Housing to monitor and manage the Contractor's performance to ensure the expected outcomes or performance objectives communicated in the PWS are achieved. Performance management rests on developing a capability to review and analyze information generated through performance assessment. The ability to make decisions based on the analysis of performance data is the cornerstone of performance management; this analysis yields information that indicates whether expected outcomes for the project are being achieved by the Contractor.

1.2.2 Performance management represents a significant shift from the more traditional Quality Assurance (QA) concepts in several ways. Performance management focuses on assessing whether outcomes are being achieved and to what extent. This approach migrates away from scrutiny of compliance with the processes and practices used to achieve the outcome. A performance-based approach enables the Contractor to play a large role in how the work is performed, as long as the proposed processes are within the stated constraints. The only exceptions to process reviews are those required by law (federal, state, and local) and compelling business situations, such as safety and health. A "results focus" provides the Contractor flexibility to continuously improve and innovate over the course of the contract as long as the critical outcomes expected are being achieved and/or the desired performance levels are being met.

1.3 Performance Management Strategy

1.3.1 The Contractor is responsible for the quality of all work performed. The Contractor measures that quality through the Contractor's own Quality Control (QC) program. QC is work output, not workers, and therefore includes all work performed under this contract regardless of whether the work is performed by Contractor employees or by subcontractors. The Contractor's QCP will set forth the staffing and procedures for self-inspecting the quality, timeliness, responsiveness, customer satisfaction, and other performance requirements in the PWS. The Contractor will develop and implement a performance management system with processes to assess and report its performance to the designated government representative. This QASP enables the Government to take advantage of the Contractor's QC program.

1.3.2 The Government representative(s) will monitor performance and review performance reports furnished by the Contractor to determine how the Contractor is performing against communicated performance objectives. The Contractor will be responsible for making required changes in processes and practices to ensure performance is managed effectively.

2 ROLES AND RESPONSIBILITIES

The following personnel shall oversee and coordinate surveillance activities.

2.1 The Contracting Officer

The Contracting Officer (CO) is responsible for monitoring contract compliance, contract administration, and cost control and for resolving any differences between the observations documented by the Contracting Officer Technical Representative (COTR) and the Contractor. The CO will designate one full-time COTR as the government authority for performance management. The number of additional representatives serving as technical inspectors depends on the complexity of the services measured, as well as the Contractor's performance, and must be identified and designated by the CO.

2.2 The Contracting Officer Representative

The COR is designated in writing by the CO to act as his or her authorized representative to assist in administering a contract. COR limitations are contained in the written appointment letter. The COR is responsible for technical administration of the project and ensures proper government surveillance of the Contractor's performance. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government's behalf. Any changes that the Contractor deems may affect contract price, terms, or conditions, shall be referred to the CO for action. The COR will have the responsibility for completing QA monitoring forms used to document the inspection and evaluation of the Contractor's work performance. Government surveillance may occur under the inspection of services clause for any service relating to the contract.

3 IDENTIFICATION OF REQUIRED PERFORMANCE STANDARDS/QUALITY LEVELS

The required performance standards and/or quality levels are included in the PWS and in Appendix 1, "Surveillance Matrix". If the Contractor meets the required service or performance level, it will be paid the monthly amount agreed on in the contract.

4 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 Surveillance Techniques

In an effort to minimize the performance management burden, simplified surveillance methods shall be used by the Government to evaluate Contractor performance when appropriate. The primary methods of surveillance are:

· 100% Inspection - Each month, the COTR, shall review the generated documentation and enter summary results into the Surveillance Activity Checklist.

· Periodic Inspection - The COTR typically performs the periodic inspection of deliverables on a monthly basis.

· Customer Feedback

4.2 Customer Feedback

The Contractor is expected to establish and maintain professional communication between its employees and customers. The primary objective of this communication is customer satisfaction. Customer satisfaction is the most significant external indicator of the success and effectiveness of all services provided and can be measured through customer complaints.

Performance management drives the Contractor to be customer focused through initially and internally addressing customer complaints and investigating the issues and/or problems. The customer always has the option to communicate complaints to the CO and/or COR, as opposed to the Contractor.

Customer complaints, to be considered valid, must set forth clearly and in writing the detailed nature of the complaint, must be signed, and must be forwarded to the COR.

Customer feedback may also be obtained either from the results of formal customer satisfaction surveys or from random customer complaints.

4.3 Acceptable Quality Levels

The Acceptable Quality Levels (AQLs) included in Appendix 1, "Surveillance Matrix", for Contractor performance are structured to allow the Contractor to manage how the work is performed. For certain critical activities, such as those involving the Annual Management and Work Plan, Operation Procedures, Monthly Activity and Information Reporting, In-Plant Audits, IPIA Performance Reports, State Payments, In-Person SMAs, and Record Reviews, the desired performance level is established at 100 percent. Other levels of performance are keyed to the relative importance of the task to the overall mission performance.

5 QUALITY ASSURANCE DOCUMENTATION

5.1 The Performance Management Feedback Loop

The performance management feedback loop begins with the communication of expected outcomes. Performance standards are expressed in the PWS and are assessed using the performance monitoring techniques shown in Appendix 1.

5.2 Monitoring Forms

The Government's QA surveillance, accomplished by the COTR, may be reported using the following monitoring forms: Appendix 2 - "Corrective Action Report (CAR)", Appendix 3 - "Customer Complaint Record", and Appendix 4 "Performance Assessment Report" (PAR). The forms, when completed, will document the Government's assessment of the Contractor's performance under the contract to ensure that the required results are being achieved. The COTR will retain a copy of all completed QA surveillance forms.

6 ANALYSIS OF QUALITY ASSURANCE ASSESSEMENT

6.1 Determining Performance

The Government will use the monitoring methods cited to determine whether the performance standards/service levels/AQLs have been met. If the Contractor has not met the minimum requirements, it may be asked to develop a corrective action plan to show how and by what date it intends to bring performance up to the required levels.

6.2 Reporting

At the end of each month, the COTR will prepare a written report for the COR summarizing the overall results of the quality assurance surveillance of the Contractor's performance. This written report, which includes the Contractor's submitted monthly report and the completed quality assurance monitoring forms, will become part of the QA documentation. It will enable the Government to demonstrate whether the Contractor is meeting the stated objectives and/or performance standards, including cost/technical/scheduling objectives.

6.3 Reviews and Resolution

6.3.1 The COR may require the Contractor's project manager, or a designated alternate, to meet with the CO, COR and/or other Government IPT personnel as deemed necessary to discuss performance evaluation. The COR will define a frequency of in-depth reviews with the Contractor, including appropriate self-assessments by the Contractor; however, if the need arises, the Contractor will meet with the COTR as often as required or per the Contractor's request. The agenda of the reviews may include:

· Monthly performance assessment data and trend analysis,

· Issues and concerns of both parties,

· Projected outlook for upcoming months and progress against expected trends, including a corrective action plan analysis,

· Recommendations for improved efficiency and/or effectiveness.

6.3.2 The CO and COTR must coordinate and communicate with the Contractor to resolve issues and concerns regarding marginal or unacceptable performance.

6.3.3 The COTR and Contractor should jointly formulate tactical and long-term courses of action. Decisions regarding changes to metrics, thresholds, or service levels should be clearly documented. Changes to service levels, procedures, and metrics will be incorporated as a contract modification at the discretion of the CO.

6.4 Surveillance Matrix

The Surveillance Matrix (Appendix 1) is the list of performance objectives and standards that must be performed by the Contractor. This matrix details the method of surveillance the COTR will use to validate and inspect these performance elements. Inspection of each element will be documented in the COTR file.

Performance objectives define the desired outcomes. Performance standards define the level of service required under the contract to successfully meet the performance objective. The inspection methodology defines how, when, and what will be assessed in measuring performance. The Government performs surveillance, using this QASP, to determine the quality of the Contractor's performance as it relates to the performance element standards. The PRS should be used to form the foundation of the COTR's inspection checklist.

In evaluating the quality of contractor’s performance, the following performance ratings may be used.

Performance

Rating Criteria

Appendix 1 - Surveillance Matrix

5.1 Management and Administration

5.1.1 Final Transition Plan

Deliverables:

A001 Final Transition Plan

5.1.2 Annual Management Work Plan

Deliverables:

A002 Annual Management Work Plan

a) Timeliness - Draft plan submitted within 10 days after contract award. Option year plans submitted at least 30 days prior to expiration of option period.

AQL: Zero deviation

b) Completeness - Plan addresses 100% of contract Tasks, Subtasks, resources, and deliverables.

AQL: Zero deviation

What: Deliverables

How: Review of deliverable

Frequency: after completion of task

Who: COTR

Incentive: 10% of Invoice CLIN for late delivery.

Standard(s): a

What: Deliverable

How: Review of deliverable

Who: COTR

Standard(s): b

5.1.3 Operating Procedures

Deliverables:

A003 Operating Procedures

a) Timeliness - Draft procedures submitted within 30 days of contract award. Updated procedures provided within 10 business days before the start of each option period.

AQL: Zero deviation

b) Completeness - The procedures address all auditing activities included in the PWS.

What: Deliverable

How: Review deliverable receipt date for compliance with PWS requirements.

Frequency: after completion of task

Who: COTR

Incentive: 5% of Invoice CLIN for late delivery.

Standard(s): a

What: Deliverable

How: Review deliverable for address of all audit activities.

Frequency: after completion of task

5.1.4 Attend Contract Activity Meetings

A004 Monthly Activity and Information Report

5.1.5 Provide Monthly Activity and Information Report

Deliverables:

A004 Monthly Activity and Information Report

a) Completeness - Monthly reports include 100% of contract tasks, subtasks, and required attachments.

AQL: Zero deviation.

b) Timeliness - Each report is provided at least 5 business days before the correlating monthly meeting.

AQL: 1 business day.

What: Deliverables

How: Review date of monthly report in comparison to PWS requirements.

Frequency: Continuous

Who: COTR

Standard(s): a

What: Deliverable

How: Review of deliverable receipt date in comparison to monthly meeting date

Frequency: Continuous

Who: COTR

Incentive: 5% of Invoice CLIN for late delivery after AQL.

5.1.6 Provide Data Management and Written Security Plan

A005 Data Management and Written Security Plan

5.1.7 Provide for State Participation on IPIA Monitoring Teams Conducting In-Plant Audits

A006 Roster of State Personnel

5.2 IPIA Monitoring

5.2.1 Schedule In-Plant Audits

5.2.2 Perform In-Plant Audits

Deliverables:

A007 Preliminary In-Plant Audit Reports

5.2.3 Resolution of In-Plant Audits

A008 Final In-Plant Audit Reports

5.2.4 Handling Disputes

A009 Dispute Report

5.2.5 Review of IPIA Plant-Specific Plans of Corrective Action

A010 Plant-Specific POCA Review Report

5.2.6 Post Production Follow-Up Audits/Consumer Sites

A011 Post Production Site Inspection Report

5.2.7 IPIA Performance Assessment and Written Performance Reports

Deliverables:

A012 IPIA Performance Report (IPR)

a) Timeliness - 100% of preliminary IPR reports shall be provided within 30 days after the headquarters visit or conference call.

AQL: Zero deviation

b) Completeness - 100% of IPR reports address the minimum elements specified in the PWS.

What: Deliverables

Frequency: Upon receipt of each deliverable.

Who: PM

Incentive: 5% of Invoice CLIN for late delivery.

Standard(s): a

What: Deliverable

How: Review of each deliverable.

Frequency: Upon receipt of each deliverable.

Who: PM

5.2.8 Review of IPIA Plans of Corrective Action for IPR Recommendations

A013 IPR POCA Review Report

5.2.9 Perform IPIA Headquarters/Manufacturing Plant Visits

A014 Special IPIA HQ/Plant Visit Report

5.2.10 Manage Certification Label Distribution and Reporting

A015 Certification Label Reports

5.2.11 Coordinate State Fee Accounting and Payment Process

Deliverables:

A016 State Payment Invoices

a) Quality - Invoices for state payments are accurate based on production and shipment reports.

AQL: Zero deviation.

What: Deliverables

How: Review of deliverables

Standard(s): a

5.3 SAA Monitoring

5.3.1 In-Person State Monitoring Assessments

Deliverables:

A017 in-Person SMA Reports A019 SMA POCA Review Report

a) Timeliness - 100% of In-Person SMAs shall be delivered within 30 days after the SMA visit.

AQL: Zero deviation.

What: Deliverables

Frequency: Upon receipt of each deliverable.

Who: PM

Incentive: 5% of Invoice CLIN for late delivery.

5.3.2 Remote State Monitoring Assessments

Deliverables:

A018 Remote SMA Report A019 SMA POCA Review Report

5.3.3 Review SAA Plans of Corrective Action

5.3.4 Conduct Post-Production Audits

5.3.5 Perform In-Plant Reviews of Manufacturer Records

Deliverables:

A020 Record Review Report

a) Timeliness - 100% of Record Review Reports shall be delivered within 5 business days after the record review.

What: Deliverables

Who: PM

Incentive: 5% of Invoice CLIN for late delivery.

5.3.6 Review Manufacturer Plans of Corrective Action

A021 Record Review POCA Review Report

5.3.7 Review and Report on New or Revised State Plans

A022 State Plan Review Report

5.4 Ancillary Services

5.4.1 Coordinate and assist in Review of Alternate Construction and On-Site Completion Approvals

A023 AC/SC Inspection Report

5.4.2 Perform Special Investigations and Studies

A024 Special Investigation Report

5.4.3 Provide Regulatory Specialist Services

5.4.4 Provide Freedom of Information Act (FOIAs) Assistance

A025 FOIA Documentation

5.4.5 Evaluate New Manufactured Housing Partner Applications

A026 New PIA Application Review Report

5.4.6 Provide Technical Meeting Support

A027 Technical Meeting Materials

5.4.7 Provide Technical Information Exchange and On-Site Assistance

A028 Information Exchange Materials

5.4.8 Provide Internet Materials and Data Access

A029 Internet Materials

5.4.9 Coordinate with other HUD Manufactured Housing Contractors

A030 Coordination Meeting Minutes

5.4.10 Ad-Hoc Reports

A031 Ad Hoc Report

5.4.11 On-Site Administrative Assistance

Appendix 2 - Corrective Action Report (CAR)

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 FORMCHECKBOX

MAJOR FORMCHECKBOX

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

FORMCHECKBOX

ACCEPTED FORMCHECKBOX

REJECTED

12. CLOSE DATE

Appendix 3 - Customer Complaint Record

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 4 - Performance Assessment Report (PAR)

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. FORMCHECKBOX

DEFICIENCY (CHECK ALL BOXES THAT APPLY)

FORMCHECKBOX

NEW

FORMCHECKBOX

REPEAT

FORMCHECKBOX

NO DEFICIENCY NOTED

8. SERVICES SUMMARY or PWS PARAGRAPH ITEM REVIEWED

II. CONTRACTOR VALIDATION

11. CONTRACTOR REPRESENTATIVE FORMCHECKBOX

CONCUR FORMCHECKBOX

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. FORMCHECKBOX

CONCUR FORMCHECKBOX

NON-CONCUR COR SIGNATURE AND DATE

15. COR REMARKS (REQUIRED)

6. CONTRACTOR REPRESENTATIVE REMARKS