QASP.pdf

QUALITY ASSURANCE

SURVEILLANCE PLAN

QUALITY ASSURANCE SURVEILLANCE PLAN

FOR

TIME-LIMITED LOGING

INTRODUCTION

This Quality Assurance Surveillance Plan (QASP) has been developed to evaluate contracted programs’ activities while implementing this Statement of Work (SOW). It is designed to provide an effective surveillance method of monitoring Contractor performance.

The QASP provides a systematic method to evaluate the services the Contracted Program is required to furnish.

This QASP is based on the premise, the Government desires to maintain a quality standard in providing time-limited lodging and a substance free setting for its patients. The resulting contract is considered the best means of achieving that objective.

PURPOSE

The Contracted Program, and not the Government, is responsible for management and quality control actions to meet the terms of the contract. The role of the Government is quality assurance to ensure contract standards are achieved.

This QASP does not detail how the Contracted Program accomplishes the work. Rather, the QASP is created with the premise that the Contracted Program is responsible for management and quality control actions to meet the terms of the contract. It is the Government’s responsibility to be objective, fair, and consistent in evaluating performance. In this contract the quality control program is the driver for product quality. The Contracted Program is required to develop a comprehensive program of inspections and monitoring actions. The first major step to ensuring a “self-correcting” contract is to ensure that the quality control program approved at the beginning of the contract provides the measures needed to lead the Contracted Program to success. This QASP explains the following:

What shall be monitored How monitoring shall take place How often monitoring shall take place Who shall conduct the monitoring How monitoring efforts and results shall be documented

This QASP is a “living document” and the Government may review and revise it on a regular basis. However, the Government shall coordinate changes with the Contracted Program. Copies of the original QASP and revisions shall be provided to the Contractor and Government officials implementing surveillance activities.

Once the quality control program is approved, careful application of the process and standards presented in the remainder of this document shall ensure a robust quality assurance program.

PERFORMANCE STANDARDS

Performance standards define desired services. The Government performs surveillance to determine if the Contracted Program exceeds, meets or does not meet these standards. The Performance Requirements Summary Matrix is incorporated within this QASP to include performance standards and disincentives. The Government shall use these standards to determine Contracted performance and shall compare Contracted performance to the Acceptable Quality Level (AQL) defined below for each performance requirement.

SURVEILLANCE: The Government quality assurance (QA) person and the COR shall use the surveillance methods listed below in the administration of this QASP.

a. Direct Observation. Direct observation shall be performed periodically or through 100% surveillance. All Performance Standards

b. Periodic Inspection. Evaluate outcomes on a periodic basis. Inspections may be scheduled Daily, Weekly, Monthly, Quarterly, Annually or unscheduled, as required. All Performance Standards

c. Progress or status meetings. All Performance Standards

d. Complaints. Complaints from agency personnel shall be passed to the Contractor's quality control inspector (QCI) for correction. All Performance Standards

STANDARD: Customer complaints shall not exceed the thresholds cited above for each performance objective. The Government’s QA personnel shall notify the contracting officer for appropriate action in accordance with FAR 52.212.4, Contract Terms and Conditions-Commercial Items (May 1997) or the appropriate Inspection of Services clause, if any of the above service areas exceed the customer complaint thresholds.

DOCUMENTING PERFORMANCE

a. Acceptable Performance: The Government shall document performance. Any report may become a part of the supporting documentation for any contractual action.

b. Unacceptable performance: When unacceptable performance occurs, the COR shall inform the Contractor. This shall normally be in writing unless circumstances necessitate verbal communication. In any case the COR shall document the discussion and place it in the COR file.

When the COR determines formal written communication is required, the COR shall prepare a Contract Discrepancy Report (CDR), and present it to the Contracting Officer (CO). In turn, the CO shall present the CDR to the Contractor’s contracting personnel.

The Contractor shall acknowledge receipt of the CDR in writing. The CDR shall 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 CDR shall 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.

Any CDRs will become a part of the supporting documentation for any contractual action deemed necessary by the CO.

SURVEILLANCE: The Government evaluator, ATS, shall evaluate the services required by each delivery/task order to ensure complete compliance.

PROCEDURES: The Government evaluator shall inspect to ensure Contractor compliance with the appropriate section of the Statement of Work (SOW) periodically. The evaluator shall record results of inspection, noting the date and time of inspection. If inspection indicates unacceptable performance, the Government evaluator shall notify the CO and/or QCI of the deficiencies within 3 business days and have QCI correct said deficiencies. Contractor shall be given notification to correct the deficiencies within a reasonable amount of time, on a case-by-case basis. The CO shall have the final authority on the amount of time the Contractor has to correct the deficiency. The evaluator shall not issue a receiving report accepting the services for the month in question until all deficiencies have been corrected.

FREQUENCY OF MEASUREMENT: During contract performance, the COR shall periodically analyze whether the negotiated frequency of surveillance is appropriate for the work being performed. Performance Assessment Meetings will be conducted quarterly. The Government may, at its discretion, choose any time, announced or unannounced, to have VA personnel inspect the contractor’s files

The COR shall meet with the Contractor quarterly to assess performance and shall provide a written assessment.

Signature – Contractor Program Manager

Signature – Contracting Officer’s Technical Representative

Signature – Contracting Officer

Task Performance Measure Acceptable Quality Level

Method of Surveillance Incentive Disincentive

VA Coordination:

Contracted Program will provide collaboration with the VA program staff by conducting a meeting 2-4 times per month.

These meetings will be held by Contracted Program Staff and VA program staff to discuss how to coordinate services to clients enrolled in the program, outreach needs, and program development. In addition to working collaboratively with VA clinical staff, the Contracted Program will submit accurate billing to VA Payment Center by the 7th of each month.

Procedure for daily accountability:

Veterans to sign in daily during their stay for accountability.

Sign in sheets to be verified by staff, signed, and returned to VA staff for billing verification.

Procedure for intakes:

No admissions will be approved without consent of VA Liaison who will determine eligibility of Veteran prior to admission.

1) ROI to be signed and eligibility determined by VA staff prior to admission

1. Contracted Program will submit accurate billing to Payment Center by the 7th of each month.

2. 100% of Veterans sign in daily to receive payment for that billing cycle

3. 85% of Veterans who are discharged will be reported to the VA within 24 business hours of discharge

4. 90% of critical incidents related to assault, suicidality and death will be reported within 24 business hours

100% during quarterly rating period

• COR records

• SOW compliance

• Review of incident reports

• Review of HR documentation (CPRS)

• Invoices

• Sign-in logs

• Interview with Veterans

The Government may, at its discretion, choose any time, announced or unannounced, to have VA personnel inspect the Contracted Program’s records.

Positive Past Performance

Review

Contract reconsideration in Per Diem Rate or bed days

2) Admission information to be provided to VA staff within 24 business hours of admission.

Confirmation email and paperwork to be faxed.

Procedure for discharges:

VA staff to be notified of discharge within 24 business hours.

Confirmation email followed by discharge paperwork.

Timeliness of Response Contractor will have a dedicated phone line for VA.

Incident Reporting:

Program staff to report to VA staff incidents within 24 business hours.

INCIDENTS DEFINED AS:

Falls

Assault (to Vet or Staff) Elderly/Dependent Adult

Abuse or Neglect Sexual Assault

Fire- Patient involved Medical Emergency- 911 Calls

Hospitalization Sexual Assault

Suicide Suicide Attempt

Homicide Death

Infectious control (bed bugs, TB, etc.)

Active Substance Abuse Observation/Possession of weapons

Lodging The Contractor shall have reasonable rules governing life and a substance free facility. The facility will be a sanitary space for lodging, including bed and furniture to store belongings, and storage space in an onsite refrigerator for veterans to store personal food items. This includes reasonable accommodation compliance in accordance with the Americans with Disabilities Act, the Federal Fair Housing Amendments Act, and the California Fair Employment and Housing Act.

The facility is required to provide a copy of current passing County Health and Safety inspection report, facility Occupancy permit, and insurance with-in 30 days of contract start date and every six months for the duration of the contract.

• 100% facility will be substance use free

• 100% facility will be sanitary and safe

• 100% compliance with City, State and Federal requirements.

All policies pertaining to the above is posted conspicuously in contracted facility

100% during rating period

• Review of Health and Safety documents provided

• Interview with Veterans

• Validated Staff/Veteran complaints

The Government may, at its discretion, choose any time, announced or unannounced, to have VA personnel inspect the Contracted Program’s facility.

Positive Past Performance

Review

Contract reconsideration in Per Diem Rate or bed days

Personnel The contractor will employ sufficient personnel to carry out the policies, responsibilities, and the program for the facility. There must be, at a minimum, at least one administrative staff member, or Designee of equivalent professional capability, on duty on the premises or residing at the facility and available for emergencies 24 hours a day, 7 days a week. There is no medical support nor clinical staff at the location. The Contractor shall assign to this contract personnel that by education and are qualified to provide the Basic Services and Supplemental Services required by this SOW.

Staff Training: Contractor will always provide at least one qualified staff person on-site.

1. Facility Staff is fully trained and Staffed 24 hours a day, 7 days a week

2. 100% of House Manager(s) receive training on the following topics 1 time per year

• CPR

• First Aid

• Crisis intervention and de-escalation techniques

• Cultural sensitivity

• Sexual harassment

• Sensitivity to wider issues of homelessness

• Universal Precautions (disease transmission prevention)

• Child abuse/neglect reporting laws ( shelter provides services to children

• Search and Seizure/Probable

Cause

• Medication management

1. Key Personnel’s resumes must be submitted prior to contract being awarded and as Staff changes. Contractors must submit Staff resume for any key staffing changes within 14 days of Staff change.

100% during rating period

• Review of policies

• Interview with Veterans

• Validated Staff/Veteran complaints

The Government may, at its discretion, choose any time, announced or unannounced, to have VA personnel inspect the Contracted Program’s records.

Positive Past Performance

Review

Contract reconsideration in Per Diem or bed days