Attachment_2_JMRC_QASP_20-SEP-2018.DOCX

Quality Assurance Surveillance Plan

(QASP)

For

Joint Multinational Readiness Center (JMRC)

W900KK-19-R-0020

Dated: 1 November 2018

Contents

1. Introduction

The purpose of this Quality Assurance Surveillance Plan (QASP) is to ensure the contractor satisfactorily performs the contract requirements, that the government receives quality services as defined in the Performance Work Statement (PWS) and to provide a planned process for assessing the contractor performance in a systematic manner. Performance assessment will be accomplished in accordance with this document, and the terms of the contract.

This plan is a “living” document that can be revised or modified by the Government as circumstances warrant. It is based on the premise that the contractor, not the government, is responsible for managing and ensuring that contract requirements are met, and that quality controls meet the terms of the contract. It is not intended to provide details of how the contractor accomplishes the work.

The surveillance/evaluation methods identified in the QASP, in concert with the contractor’s quality management and quality improvement procedures, provide a comprehensive approach to contract performance assessment. The COR will review the QASP to ensure that it will work in concert with the contractor’s Quality Control Plan (QCP). In areas where gaps or increased surveillance is warranted, adjustments may be made to the QASP.

In the event of a conflict between this QASP and contractually stated inspection requirements, the Order of Precedence (contract) shall prevail. (FAR 52.215-33) Items that are observed IAW this QASP may be used as input for documenting contractor past performance.

2. Roles and Responsibilities

The following individual direct roles for monitoring contract performance:

2.1 Contracting Officer (KO): The individual with a prescribed authority to enter into, administer, and/or terminate contracts and make related determinations and findings.

KO responsibilities:

1) Ensure appropriate contractual remedies and solutions are applied when contractors fail to meet contract requirements.

2) Ultimately responsible for final determination of the adequacy of the contractor’s performance in accordance with Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS), DoD directives, instructions and policy letters.

2.2 Contracting Officer’s Representative (COR): The COR for this effort is the deputy director of the JMRC’s Instrumentation Training Analysis Computer Simulations and Support Center (ITACSS). This individual will be designated and authorized in writing by the KO to perform specific technical or administrative functions, and is the senior organization contract administrator responsible for adequate surveillance of contractor performance. A COR does not have the authority to change the contract terms, as this can only be accomplished by the KO.

COR Responsibilities:

1) Defines, guides, and coordinates surveillance activities to ensure satisfactory contractor performance of contract requirements

2) Ensures adequate resolution of contractor technical performance issues

3) Reviews SME documentation

4) Reviews the Contractor’s Quality Control Plan (QCP) in coordination with SMEs for acceptable quality level in all areas of the contract

5) Maintains consolidated quality assurance files and current SOPs

2.3 Alternate Contracting Officers Representatives (ACORs): ACORs will be assigned during the transition period and updated semiannually. The Government will provide the Contractor with an approved list of ACORs, identified by the service section for which they are responsible. An ACOR can be responsible for more than one service category. Each ACOR will be responsible to determine that the level of service provided meets or exceeds the PWS and the approved service sections SOP. The ACOR is the first person to review a services section SOP but they cannot approve the document. The ACOR does not have the authority to change the contract terms, as this can only be accomplished by the KO.

3. Contract Requirements

The contract requirements applicable to this QASP are listed in the Performance Work Statement and Appendix D. However, the Government is not limited to contract monitoring/surveillance for only those contract requirements included in this QASP. The contractor is responsible for satisfactory performance of all contract requirements and the Government will modify methods and requirements subject to monitoring as necessary.

3.1 Safety: The ACORs and the COR will observe and determine if the contractor is abiding by safety rules and regulations. All safety issues must be rectified as they are identified. All data shall be reported via the Management Interface System (MIS).

3.2 Other General Requirements: The ACORs and the COR will observe general on-site contractor performance. These areas include professional conduct and maintaining an orderly work space.

4. Authority

Quality assurance surveillance will be performed IAW the policies and procedures described in FAR Subpart 46.4, Government Contract Quality Assurance. Authority for issuance of QASPs is provided under the following clauses:

5. Quality Assurance Surveillance

FAR Part 5 46.103(a) requires a Quality Assurance Surveillance Plan (QASP) for all service contracts. FAR 52.246-4 gives the Government the right to retest and inspect all services called for by the contract at any time so long as such tests and inspections do not unduly delay the contractor.

Quality assurance surveillance is prioritized to survey major outputs of the Performance Work Statement. The focus of the surveillance plan is on quality of the service, not on the procedures used to provide the service. The surveillance plan includes appropriate use to measure and/or conduct: progress/performance on the contract for (5.1), customer input (5.2), pre-planned inspections (5.3), meetings (5.4), and contractor reporting. The level of effort involved with the surveillance is commensurate with the criticality of a given phase of training and/or Governments concern over the execution of a given phase of the Performance Work Statement or the Performance Work Statement in its entirety.

Periodic (scheduled or non-scheduled) performance assessments will be accomplished utilizing a combination of assessment methods and metrics as identified in Appendix B. The methods used for surveillance on this contract are contractor self-reporting, customer input, periodic performance meetings, periodic inspection, and observations.

5.1 Customer Input. The COR may receive customer input about the quality of services performed under the contract. These inputs maximize the government’s resource potential and are considered in regular assessments as they may identify contractor process improvement opportunities or required corrective actions; however, unsolicited input must be validated. Customer input requires documentation. The COR will document or obtain documentation from the customer and validate any input before commending the contractor or before writing a discrepancy report. One of the first things a COR does after receiving a customer commendation or complaint is to notify the contractor that it is being given consideration.

5.1.1 Validation of Complaints - The ACOR must investigate all customer complaints in order to verify whether or not the complaint is valid. If the complaint is found to be valid, the ACOR must document it in their file by preparing a formal Contract Discrepancy Report (CDR) (Appendix D) and submit it to the COR who will submit it through the KO to the Contractor.

5.2 Pre-planned Inspections will evaluate tasks selected on other than a 100% basis as shown in Appendix D.

The COR will receive reports from the person conducting inspections. The KO or ACOR, will conduct inspections during their Government oversight visits. Inspections will be conducted for the items specified in the surveillance checklist (Appendix C). The effectiveness of Program Management is reflected in the quality of the products and services that will be evaluated with this checklist. It is recommended the inspectors print the documents out for use during inspections.

At the completion of the inspection, the inspector will document the inspection and, in an email, forward the completed checklist to the COR within ten (10) working days after the inspection. The documents will be maintained in the inspector’s files as described in paragraph 6.

5.2.1 Observation - Observation of contractor performance by the inspector can provide useful indicators of the contractor meeting contractual requirements. The COR and ACORs will be guided by their observances as to whether additional actions are required which could include, but are not limited to, repeat performance of work, more frequent periodic meetings/reviews, and coordination with the KO as to further steps.

For the purpose of observation and inspections, the Contractor shall allow agencies or individuals authorized by the Government access to work performance areas. The CORs will conduct all observations or inspections in such a manner that it does not interfere with the contractor accomplishing PWS tasks.

5.3 Meetings Performance meeting/reviews are an effective tool for keeping performance on course, measuring performance levels, and making adjustments as necessary to avoid more serious deficiencies. Training event planning and other contractor performance related meetings attended by the KO or COR assist the Government with its oversight role. The contractor shall produce meeting minutes and forward them to the KO and COR for retention. The minutes are a useful source to review for surveillance and past performance purposes.

5.4 Contractor reporting The government will use the contractor’s reports as part of its surveillance process for monitoring the performance of the contract requirements.

6. Documentation Procedures

DOD guidance maintains the surveillance documentation constitutes an official record, and the surveillance personnel assessing performance are to use a checklist to record their observations of the contractor’s performance. The guidance also concludes that all performance should be documented, whether it is acceptable or not. All surveillance records will be maintained on file (digital preferred, with back up) for the length of the contract. The COR files will also contain documents listed in the COR and this QASP. The COR will maintain copies of all inspections and performance issues of the contract.

Adequate surveillance and documentation of surveillance results, together with timely discrepancy reporting, are important activities in correcting Contractor errors, and acknowledging Contractor superior performance.

The COR will upload a Monthly Surveillance Report (MSR) to the CORT Tool (https://wafw.eb.mil) that includes a summary and rating of inspections performed with results, summary of any customer complaints with analysis, summary of contract discrepancies, results of data analysis (risk), recommended adjustments to surveillance, invoices accepted, next month’s surveillance schedule and anything else pertinent to that month’s contract surveillance. The COR will upload the MSR in the CORT Tool by the 10th day of the month following the month of surveillance being reported on.

On closure of the contract, the COR and ACOR files will be submitted to the KO.

7. Acceptance of Services

The COR will review the contractors performance, deliverables, and other submittals (reports or plans). When performance does not meet standards, the CORs shall notify the KO. When performance exceeds standards, the COR and ACOR must document the performance in the monthly reports. The level of service is directly tied to potential incentive fees and the Contactors annual performance reports.

7.1 Deficiencies

If deficiencies are found during surveillance or through observation at any other time, the contractor must be notified. There are two reasons to notify the contractor of deficiencies:

1) The Government wants the contractor to correct the problem. The Government has contracted for the performance of a needed service and wants the service performed correctly, and in accordance with the contract provisions.

2) The Government has a responsibility to mitigate damages to the contractor. Therefore, the Government will seek to advise the contractor of the problem so it can take corrective action prior to the service being declared unacceptable for the surveillance period.

3) All deficiencies and corrective actions will be documented in the monthly COR report in the CORT Tool.

7.2 Discrepancy Reports

If any aspect of performance does not conform to the requirements of the contract, and is not immediately resolved, the Contracting Officer will issue a Contract Discrepancy Report (CDR) to the contractor. Guidance and an example is contained in Appendix C. Upon receipt of a CDR, the contractor shall immediately sign and return one copy. The contractor shall explain to the Contracting Officer/COR, in writing, and within three working days of receipt of the CDR, why performance did not conform with the requirements of the task. The contractor shall also report corrective and preventative actions in its response to the COR. The COR and the contractor shall maintain a file copy of the CDR. All CDRs will be included in the COR’s monthly reports and uploaded to the CORT Tool.

Each CDR will be annotated as a critical nonconformance, major nonconformance, or minor nonconformance. A blank CDR is included at Appendix C for illustrative purposes and an electronic format is available via the Web.

8. Remedies

The COR will consult with the KO for nonconforming services remedies. FAR Part 46, Quality Assurance, Subpart 46.407 – Nonconforming Supplies and Services, paragraph f, states “For services, the contracting officer can consider identifying the value of the individual work requirements or task (subdivisions) that may be subject to price or fee reduction. This value may be used to determine an equitable adjustment for nonconforming services. However, when supplies or services involving minor non-conformances are accepted, the contract need not be modified unless it appears that the savings to the contractor in fabricating the nonconforming supplies or performing the non-conforming services will exceed the cost to the Government for processing the modification.”

9. QASP Changes

As a living document, this QASP is subject to change based on the PWS, mission, or other changes. Suggestions for improvements or changes should be sent to the COR. Recommended changes to the QASP will be sent to the Contracting Officer for approval.

10. References

The documents listed below form the basis for Quality Assurance Surveillance

1) Federal Acquisition Regulation (FAR)

2) Defense Federal Acquisition Regulation (DFARS)

3) Army Federal Acquisition Regulation Supplement (AFARS)

4) Performance Work Statement (PWS) JMRC PWS

Appendix A – Publications

FAR Part 46, Quality Assurance Subpart 46.4, Government Contract Quality Assurance 52.246-4 and 52.246-5 Inspection- Firm, Fixed Price with Cost Provisions (FFP + Cost) contract.

Appendix B – Methods and Metrics

Periodic performance assessments will be accomplished using a combination of assessment methods and metrics as identified in this appendix. Performance objectives in the Surveillance Checklist have been extracted from the PWS. All of the three rating categories are acceptable with the exception of “unsatisfactory.”

Frequencies:

The COR will conduct monthly inspections using the attached Surveillance Checklist and documenting results on the checklist. The ACORs will also conduct inspections and provide documentation to the COR. The checklist data and COR observations will be condensed into the COR Observation Report Format, which will include, at a minimum:

1) Date, time and place of inspection

2) Who conducted the inspection and contractor personnel, by name, on hand for the inspection

3) Overall contractor performance

4) Details of excellent contractor performance

5) Details of less than adequate contractor performance (including any contractor responses and possible impact of performance to mission accomplishment).

The checklist contains a column for noting discrepancies for each inspected task Metrics:

The results of the inspection will be recorded in the respective columns of the checklist. When the results are satisfactory, that is all that needs to be recorded. When the results are excellent or unsatisfactory rating is recorded in the comments column. If more space is required, use the back of the checklist. All unsatisfactory ratings will be brought the attention of the contractor and forwarded to the COR and KO.

If unsatisfactory service must be performed by the contractor, the re-inspection of the performed service will be recorded on the checklist initially used. When the performance is satisfactory, this cancels the previous unsatisfactory rating. The COR will then line out and initial the unsatisfactory rating (being sure not to obliterate the entry). The COR will forward a copy of the revised checklist to the KO.

Appendix C – Contractor Discrepancy Report (CDR)

Nonconforming services will be documented on a DA 5479. Contract Discrepancy Report (CDR) IAW with paragraph 7.2 of this QASP. Each CDR will be annotated as a Critical, Major, or a Minor nonconformance.

A CDR officially documents unsatisfactory performance by a contractor. It includes a description of the deficiency, contractor response as to cause, contractor’s corrective action plan, the Government’s evaluation of the corrective action plan and any Government corrective action taken with the contractor.

Any life or mission threatening safety issue must be corrected immediately

*Definitions of nonconformance are derived from FAR 46.101

Some notes on filling out the CDR are shown at the end of the document

Appendix D – Surveillance Checklist JMRC Rotational Mission Support (JMRC-RMS) Services

Date and Time of Inspection:______________________________________

Place of Inspection:______________________________________________

Inspector(Name/Rank):___________________________________________

Contractor Personnel Present:_____________________________________

Inspector Contact Information:_______________________________________

Organization: ____________________________________________________

Email:__________________________________________________________

Phone:_________________________________________________________

E = Excellent*

VG = Very Good*

G = Good

SAT = Satisfactory

UNSAT = Unsatisfactory*(does not meet standard)

*The comments should provide details of Excellent, Very Good, and Unsatisfactory ratings (No Comments required for Good & Satisfactory)

Circle or mark overall rating

Attachment (2)

Appendix E – Performance Requirements Summary

The Contractor service requirements are summarized into performance objectives that relate directly to mission essential items.

1) Training was effective

2) Trainer was effective

3) Training was relevant for today and future image1.emf