QASP Interpretation-Translation_SFA PAN (3 May 21).pdf

Quality Assurance Surveillance Plan (QASP)

Security Forces Assistance Brigade (SFAB) Panama 21

Contract # New contract

TABLE OF CONTENTS

Subject

1. Overview

2. Description of Services

3. Roles and Responsibilities

4. Contract Quality Requirements

5. Government Surveillance

6. Non-Conforming Performance

7. Data Analysis

8. Acceptance of Services

9. Monthly COR Activity Report

10. Contractor Manpower Reporting (CMR)

11. Quality Assurance Surveillance File

12. Contractor Performance Assessment Reporting System (CPARS)

13. Record Retention

14. Combating Trafficking in Persons (CTIP)

15. QASP Changes

1. OVERVIEW

1.1 Purpose. The purpose of this plan is to identify the methods and procedures the Government will use to ensure it receives the services/products under this contract as identified in the Performance Work

Statement (PWS).

1.2 Intent. The intent of this plan is to hold the Contractor accountable for quality control and to encourage the contractor to take appropriate steps to control and improve quality. Contractor is responsible to develop an efficient methodology to ensure they meet and/or exceed the required thresholds of service as outlined in this acquisition. The Government intends to perform surveillance on this contract in accordance with this Quality Assurance Surveillance Plan (QASP), but reserves the right to monitor the contract in any manner necessary, at any times necessary, and at all places necessary to ensure that the rendered services conform to contract requirements. The Government reserves the right to perform quality assurance at the subcontract level and perform quality assurance at the contractor's place of business, if applicable. Non-conforming services discovered with subcontractors will be addressed with the prime contractor for resolution.

2. DESCRIPTION OF SERVICES

2.1 Scope of Work. Contractor shall provide non-personal services to include on-site language interpretation from Spanish to English and English to Spanish to include simultaneous interpretation and consecutive interpretation. The contractor shall accomplish on-site translation and off-site translation.

2.2 Contract. The Government will award a Firm Fixed Price contract.

3. ROLES AND RESPONSIBILITIES.

Contracting Officer (KO) - A person duly appointed with the authority to enter into, administer and terminate contracts on behalf of the Government. The KO is the only person who can legally commit the

Government and only the KO, as the Government’s agent, can modify the contract/order. The KO is the final authority for determining the adequacy of the Contractor’s performance. KO decisions arising under or relating to the contact are final.

Contracting Officer’s Representative (COR) – An individual designated in writing by the KO to perform specific technical and administrative functions within the scope and limitations of their written appointment (e.g., surveillance of Contractor’s performance, accept services). The COR is not empowered to make any contractual commitments or authorize any changes to the order/contract or in any way obligate additional funds by the Government; such authority rests solely with the KO.

Contract Administrator – N/A

Property Administrator – N/A

4. CONTRACT QUALITY REQUIREMENTS

4.1. Quality Control Program. N/A.

4.2. Government Quality Assurance. The Government will perform Quality Assurance oversight of the

Contractor IAW with this QASP to ensure acceptable levels of contract performance are achieved and that the contractor is performing acceptable levels of Quality Control to ensure fully acceptable services are provided.

5. GOVERNMENT SURVIELLANCE

5.1. Methods of Surveillance include but are not limited to:

• 100% Inspection - Reserved for the highest risk areas where consequence of failure is high (i.e.

life or limb are threatened) or there is likelihood of mission failure.

• Random Sampling - When a service is performed relatively frequently and a statistically valid sample can be selected for audit. The most appropriate method for frequently recurring tasks.

• Periodic Sampling - Planned sampling of a service at specific predetermined dates and times. May be appropriate for tasks that occur infrequently.

• Customer Feedback – Not necessarily a valid method of surveillance but a good indicator for areas surveillance should be conducted or intensified.

5.2. Monthly Surveillance Schedule. The COR will develop a monthly schedule of surveillance activities based on the Performance Standards as outlined in the Performance Requirements Summary

(PRS)(PRS will be an attachment to this QASP) as well as any other critical contractual requirements determined to be higher risk requiring oversight. The surveillance outlined in the monthly schedule will be as detailed and in-depth as necessary to provide the Government with the objective quality evidence required to support acceptance of the services provided by the Contractor. The schedule will provide planned periodic surveillance during all required hours of the Contractor’s operation. The schedule is

“FOR OFFICIAL USE ONLY” and is not releasable to anyone other than authorized Government personnel. The schedule will identify the method of surveillance, the date of inspection, place of inspection, activity to be monitored, and who will conduct the surveillance (dates and times can be altered without a formal change to the schedule as long as all inspections are performed). The 410th CSB surveillance schedule shall be used to plan and scheduled monthly surveillance. The monthly schedule will be completed no later than seven calendar days prior to the beginning of the period it covers and a copy uploaded into WAWF-CORT.

5.3. Inspection instructions/checklists. The COR will develop inspection instructions/checklists for all planned inspections which may require special instructions on how to perform the inspection, what observations should be made with specific details of what to look for acceptable performance. The 410th

Surveillance Checklist shall be used for the above purpose.

5.4. Documentation of Inspections. All inspections/observations will be documented and will include as a minimum date and time, who performed the inspection, what was inspected, to what standard and the results. Successful or exceptional performance will be documented as well as deficiencies in Contractor performance. Documentation will be maintained for future reference, audit, proof of inspection and past performance documentation. The 410th Surveillance Checklist shall be used for the above purpose.

6. Non-Conforming Performance. The COR will notify the Contractor, in person, each time an unacceptable observation has been recorded and ask the Contractor to correct the problem or re-accomplish the service. All valid non-conformances observed by the Government will be documented! The COR will record the contract requirement, the specific deficiency to the requirement, the date and time it was discovered, and have the Contractor initial the entry. The Contractor will be given a time line after notification to correct the deficiency in accordance with requirements of the contract. Deficiencies that cannot be corrected within the indentified time line will be reported to the KO.

The approved 410th CSB nonconformance report (NCR) form shall be used to document all contractual nonconformance’ to include issues. All NCRs shall be logged into the NCR Log. Only KOs shall issue

NCRs to the contractor.

6.1. Customer Feedback. For customer feedback or complaints it is recommended that the Customer

Complaint Record DA Form 5477 http://armypubs.army.mil/eforms/pdf/A5477.PDF be used. However http://armypubs.army.mil/eforms/pdf/A5477.PDF customer feedback can be in any form, verbal or written but no matter the format the COR will maintain a record of the feedback positive or negative.

a. If immediate response to a complaint is required, the COR will provide the response to the requester as soon as practical.

b. The COR will conduct an investigation to determine the validity of any negative comments received.

c. If the negative comment is determined not to be valid, if possible, the COR will inform customer of the reason(s) as soon as practical.

d. For validated negative comments that are true contractual non-conformances see paragraph 6. If this non-conformance is a more serious (systemic in nature) deficiency or recurring deficiency that could indicate a trend the COR should see paragraph 6.2.

e. The COR will follow up with the customer of the corrective action taken by the contractor, if applicable.

6.2. Non-Conformance Reports (NCR). The COR will report more serious (systemic in nature) deficiencies or recurring deficiencies that could indicate a trend by using the 410th CSB non-conformance report. The Non-Conformance Report will state the Contract Requirement, the specific contract reference and the specific violation (s) to the requirement. The COR will forward copies of Non-Conformance

Report to the KO within one working day. The KO will notify the Contractor and request corrective action to the specific non-conformance, identification of the root cause and corrective action for the root cause with a required suspense date. The KO may require the Contractor to re-perform any services that do not meet contract requirements at no additional cost to the Government. The Contractor will return a copy of the completed and signed Non-Conformance Report along with their Corrective Action Plan

(CAP) to the KO for review, approval and inclusion in the contract/order file. The KO should include the

COR in the review of the CAP and re-inspection of services that were found deficient to ensure the CAP included adequate root cause analysis, corrective action for the root cause and that it was accomplished in the timeframe agreed upon. The KO and COR will not consider the NCR closed until all deficiencies have been corrected and all agreed upon actions of the CAP have been completed. Contractor’s failure to follow through and complete corrective actions will be reported immediately to the KO for further action.

(Note: if the COR has to repeatedly perform re-inspection there could be a Government re-inspection cost which could be recovered from the Contractor). The COR will also follow-up after the Contractor has completed the corrective action to ensure that the Contractor’s corrective action was sufficient to preclude recurrence.

7. Data Analysis. COR shall perform and document analysis of available data monthly and make adjustments to surveillance schedule as required based on results of analysis. Analysis shall be used to look for and document trends in performance which may indicate shifts in performance risk that could result in increased or reduced surveillance. Data can be based on Government observations or Contractor observations. Negative trends noted using Government observations could result in issuing Contractor a

Contract Deficiency Report (CDR). Trends noted using Contractor data should never result in a CDR unless the Contractor is not addressing the negative trend. Documentation of data analysis will be in the

Monthly COR Activity Report.

8. Acceptance of Services. When all services have been deemed acceptable and there is documented objective quality evidence to support acceptable performance the COR will accept the services provided and authorize payment upon satisfactory completion of the work. This is done by approving the

Contractor’s invoice in the Procurement Integrated Enterprise Environment (PIEE) https://piee.eb.mil/xhtml/unauth/home/login.xhtml or DD250 (if applicable).

9. COR Monthly Status Report. By the last working day of the month, the COR will complete the

PIEE-CORT Online Monthly Report for KO review and acceptance or rejection. The COR will use the criteria listed below when rating the Contactor’s Quality of Work. In the Contactor’s

Quality of Work comment box the COR will include a summary of inspections performed, summary of customer complaints, summary of contract discrepancies, recommended adjustments to surveillance and any other pertinent contract activities. In the individual question comments box, the COR will include a detailed summary of observations as it pertains to the individual question.

Contractors Quality Of Work

Contractor quality of work ratings and criteria are described below:

Performance

Rating

Criteria

Exceptional Performance meets contractual requirements and exceeds many of the government’s benefits. 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 were highly effective.

Very Good Performance meets contractual requirements and exceeds some of the government benefits. The contractual performance element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor were highly effective.

Satisfactory Performance meets all minimum 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 serious problem(s) for which the contractor’s corrective actions appear or were ineffective.

10. Contractor Manpower Reporting. The COR shall verify the Contactor has complied with the required contractor manpower reporting and document any observations.

11. Quality Assurance Surveillance File: The official COR Quality Assurance Surveillance File will be maintained in the on-line COR Management Tool (CORT) via https://piee.eb.mil/xhtml/unauth/home/login.xhtml per ACC PAM 70-1. The Quality Assurance, or COR Surveillance file shall contain the following as applicable:

a. Copy of the COR designation letter from the KO, any changes to that letter, and any termination letters.

b. Training Certifications for COR and refresher training.

https://piee.eb.mil/xhtml/unauth/home/login.xhtml https://piee.eb.mil/xhtml/unauth/home/login.xhtml

c. Copy of the applicable Quality Assurance Surveillance Plan (QASP).

d. Copy of the contractor’s Quality Control Plan (QCP).

e. All correspondence initiated by authorized representatives (Contractor or Government) concerning performance of the contract.

f. Names, position titles and contact information of all key personnel assigned to this contract both

Government and Contractor.

g. Monthly surveillance schedules.

h. Surveillance Checklists

i. Records of all inspections performed and the results.

j. Customer Feedback.

k. Memoranda for record of minutes of any meeting, telephone conversations and discussions with the contractor or others pertaining to the contract or contract performance.

l. Documentation pertaining to acceptance of services, reports or data.

12. Contractor Performance Assessment Reporting System (CPARS). Documented surveillance data

IAW this QASP will be used as objective data to support CPARS ratings. The inclusion of detailed documented inspection results provides objectivity to CPARS reporting. CPARS will be accomplished annually or at the end of a Task Order whichever occurs first.

13. Record Retention. All records will be retained for the life of this contract. The COR/QAE shall ensure all record are uploaded into PIEE-CORT and all hard copies shall be forward to the KO upon completion of the contract/order.

14. Combating Trafficking in Persons (CTIP). See US Department of State website, http://www.state.gov/j/tip/rls/tiprpt/2012/192363.htm for Tier location requirements. The COR shall ensure that contractors are in compliance with FAR 52.222-50 at CTIP Tier 1 locations. For Tier 2, Tier 2

Watch List (WL), and Tier 3 locations, CORs shall ensure that contractors are in compliance with Tier 1 requirements in addition to performing spot checks, reviews, and assessments of contractor and subcontractor employees to identify indicators of CTIP. In the event indicators are identified, the COR shall notify the KO immediately.

The COR shall use the 410th CSB checklist when conducting CTIP surveillance. CTIP surveillance reporting will be completed biannually and submitted to the KO NLT the last working day of the months of June and November.

15. QASP Changes. The QASP is a living document and, as such, may be changed as needed. However, the KO must approve changes. The COR will submit recommended changes to the KO for approval.

Once approved, the COR will upload the newest version into PIEE-CORT.

http://www.state.gov/j/tip/rls/tiprpt/2012/192363.htm

Requirements Table

The contractor service requirements are summarized into performance objectives that relate directly to mission essential items. The performance threshold briefly describes the minimum acceptable levels of service required for each requirement. These thresholds are critical to mission success.

Performance Objective

(The Service required— usually a shall statement)

Standard Performance

Threshold

(This is the maximum error rate. It could possibly be “Zero deviation from standard”)

Method of Surveillance

% Deduction from monthly invoice for not meeting

Performance

Standards

1. Combating Trafficking in Persons

FAR 52.222-50 c

The Contractor shall Notify its employees of

a. The United States

Government's zero tolerance policy described in paragraph

(b) of this clause

The actions that will be taken against employees for violations of this policy.

Such actions may include, but are not limited to, removal from the contract, reduction in benefits, or termination of employment

100%

Compliance

100%

Inspection, COR

Validation

Example; 5% of total monthly price will be deducted

PRS # 1.

Reporting instructions. The

Contractor shall ensure that all interpreters are at the specific event location 15 minutes before scheduled time of event.

PWS paragraph 5.1.1

Interpreters shall be dressed in appropriate professional attire based on missions venue (at a minimum, suit, slacks and polo or collared shirt, blouse,skirt, etc).

100%

Compliance

COR

Validation;

periodic surveillance

PRS #2.

Qualifications. Service providers shall be qualified and experienced native speaking language specialists able to proof-read, edit, and provide the final product layout and output, in the required media format (i.e., hardcopy or electronic).

PWS Paragraph 5.2

Native speaking. 100%

Compliance

COR

Validation;

PRS # 3

On-site Interpretation

Services. The Contractor must provide interpretation from Spanish to English and from English to Spanish as required, enabling communication between the government and other entities.

PWS Paragraph 5.2.1

Interpreters shall be physically available during the duration of the Security

Forces Assistance Exercise and be ready to provide interpretation services for briefings, meetings, and social events.

100%

Compliance

COR

Validation;

PRS # 4

On-site Translation Services.

The contractor will receive documents for translation hard copy or by email from the government. Work will be primarily assisting with translation of documents and assisting working groups with back brief translations.

PWS Paragraph 5.2.4

Translated copies will be provided back to the government within a time period of 20 minutes per 500 words.

100%

Compliance

COR

Validation;

PRS # 5

Communication: The contractor shall maintain sufficient means of monitored communications

(telephone, E-mail, etc.) to enable rapid contact between the Government and contract manager (See Para. 1.6.10

Key personnel). The contract shall respond within 20 minutes of the government attempting to contact the contractor.

PWS Paragraph 5.3

The contractor shall respond within 20 minutes of the government attempting to make contact with the contractor.

100%

Compliance

COR

Validation;