Exhibit D - MBL QASP ver 1.1.doc

Ver 1.1

Ver 1.1

Quality Assurance Surveillance (QASP) GUIDE for Support Services to the Maneuver Battle Lab (MBL)

The following provisions provide the overall surveillance guidelines applicable to the Support Services to the Maneuver Battle Lab (MBL) contract. An Addendum is attached to provide contract specific provisions for support for surveillance not otherwise provided by these provisions. The Contracting Officer Representative (COR) contract file folder shall contain a complete copy of the QASP, all attachments, any addendums, a copy of all monthly metrics performance documents and all other reports the contract.

A. INTRODUCTION.

(1) Purpose. This plan provides a systematic monitoring, assessment, and reporting approach for the oversight of contract work performance and provides corrective procedures to be taken for deficient performance. Information gathered under the provision of this surveillance plan will be documented to support actions/ decisions such as exercise of an option, re-performance of defective work, termination of contract performance, increase/decrease of workload, reduction of payment for services not rendered, status of contractor performance, etc. Because this plan is a tool to be used by the Government, it can be modified at any time necessary, however shall not conflict with stated contract terms and conditions. Any decision to reduce oversight will be based on best interests of the government and on the contractor’s demonstrated capability to carry out its own quality control plan.

(2) Functions Surveyed.

(a) The Government maintains a broad overview of contractor performance by monitoring how the Contractor implements each contract task and the timeliness and quality of deliverables required. The Government will review all deliverables submitted by the contractor and will conduct in-process reviews (IPRs) with contract lead/supervisor IAW contract terms and/or upon identified need. These IPRs will be focused on work performance to include completed, in process, and planning.

(b) MBL policy supports the DOD and DA requirement for thorough customer supported contract administration documentation of contract performance. This role is assigned to the Government COR/Inspector who will maintain surveillance of the Contractor’s records and performance under the terms of the contract.

(c) The COR/Inspector is responsible for surveillance of all aspects of contract performance to include review of Contractor’s Progress reports, trip reports, deliverables, hours worked (if appropriate), and any reimburseable costs (other direct costs or travel), as appropriate.

(d) The COR/Inspector will develop, complete and submit an evaluation of contract performance using the attached worksheet entitled “Performance Metrics Worksheet.” The metrics worksheet will document acceptable or outstanding performance as well as lack of work progress or deficient performance. Evaluation will be assigned using color coded Green (superior), Amber (acceptable, but can be improved), and Red (Unacceptable) rating criteria with comments. The COR/Inspector may add or revise metrics to better address specific contract requirements. Changes made to these metrics will be provided to all parties (contractor, contracting officer, COR file, ARCIC PMD) prior to the beginning of the start of the next monthly evaluation period. Evaluation of all metrics is expected, however, if a specific metric does not apply, notate the reason and leave unrated.

(e) Evaluation of the “Overall Support” metric is mandatory for each reporting period and shall include a comprehensive comment addressing performance for the rating period.

(3) The Government COR shall assess the contractor's performance using the following metrics and standards:

· Timeliness - Completed products are delivered on time to support senior decision-makers.

· Green - 100% of the products delivered on-time IAW with contract schedule

· Amber - 90 - 99% of the products delivered on-time IAW with contract schedule – with all key deliverables completed on time.

· Red - less than 90% of the products delivered on-time IAW with contract schedule or one or more key deliverables not completed on time.

· Quality of Support – Meets quality standards.

· Green - 100% meets all standards

· Amber - 90 - 99% meets standards with minor discrepancies.

· Red - Less than 90% of deliverables meet standards or one or more have major discrepancies.

· Support is customer-focused - Assessment of Site-manager/leadership.

· Green - Contractor is proactive in identifying problems and recommending solutions. Receptive to government feedback, quick to solve problems and keeps the government informed.

· Amber - Proactive on key issues taking action on problems identified by the government in a timely manner.

· Red - Problems and/or issues are not dealt with or resolved at the lowest possible level with slow overall remedy response in key areas.

· In-Process Review (IPR) - Assures contractor performance is tracked and on target.

· Green - Contractor provides comprehensive status of in-process work to include planning for new work.

· Amber – Generally provides updates on key projects – with minor exceptions or does not address and/or plan for new projected work.

· Red – Unprepared and does not provide adequate update on in-process or new work.-

· Documentation - Deliverables to include informal documentation.

· Green – meets all TRADOC and DA standards; no errors found; documentation helpful.

· Amber – generally meets standards; few errors; documentation satisfactory.

· Red – at least one key deliverable incomplete with significant rewrite required by US Government.

· Management - How well the contractor manages resources. (Government and contractor resources to include personnel retention.)

· Green – Contractor proactively manages workforce and workflow for maximum efficiency. Partners with the government to ensure best value.

· Amber - Generally provides good management, occasionally slow to react.

· Red - Slow to correct inefficient practices. Frequent employee turnover with slow replacement or fails to provide qualified replacements.

· Currency of Data - Measures relevancy of provided support.

· Green – Consistently provides relevant material, analysis, insights, and deliverables.

· Amber - Provides relevant material most of the time – always relevant for key/critical requirements.

· Red - Work often reflects a lack of relevancy and/or based on older concepts, outdated material, etc.

· Overall Support (Analytical, Technical, Administrative) - Provides an overall snapshot of contract performance.

· Green - Meets or exceeds all expectations for technical/analytical/administrative contract requirements.

· Amber – Meets all key requirements of the contract. Minor areas of improvement identified by the government.

· Red - Performance for rating period unsatisfactory based on failure of the contractor in at least one key element of this metric.

B. HOW TO USE THIS PLAN.

(1) Review of Deliverables: inspection of deliverables will be made by the COR/Inspector IAW below types of deliverables and frequency of inspections:

a. Contractor’s IPR (Progress, Status and Management Report) - Monthly

b. Contractor timekeeping records, if payment by hour - Monthly

c. Status of in-process deliverables - As submitted

d. Timeliness – as submitted/or as scheduled for receipt

e. Contractor invoices - monthly

f. Customer Comments - when received

(2) Surveillance Methods.

(a) Monthly IPR discussions based on contractor in-process monthly report addressing all deliverables. Discussions shall be documented and will include quality of deliverables, timeliness, assigned tasks/work in-process, etc.

(b) 100 Percent Inspection. This is an inspection method whereby all contractor tasks are monitored. This method provides the best indication of contractor performance and the most documented basis to support the exercise of an option. The Government will use the 100 percent inspection method for all contractor provided deliverables.

(c) Customer Complaints. This is an inspection method that is initiated by any individual working with or coming in contact with the contractor. A customer complaint concerns contractor’s performance. To be successful, this method must be well publicized to the customer. The Government may use the Customer Complaint method to review/verify performance.

(3) Surveillance Procedures. Surveillance of the contractor will generally be focused around a monthly evaluation period.

(a) The COR in coordination with the contractor lead/manager will complete the monthly metrics performance report using one or more of the above surveillance methods listed. A copy of the completed performance report will be provided the contractor, the contracting officer, PMD Acquisition, and a copy shall be included in the COR files. See paragraph (4) below for details.

(b) Defects found will be recorded on the checklist and on a Contract Deficiency Report (CDR) (DA Form 5479-R). A copy of the CDR will be provided to the contractor for comments. Upon receipt of contractor’s comments, the COR will notate any contractor corrective action and the CDR released to the Contracting Officer (KO) and ARCIC Program Management Division (PMD). Uncorrected deficiencies, lack of response or repetitive deficiencies shall be brought to the direct attention of the KO for assistance in resolution.

(c) Customer Complaints will be submitted to the COR on a DA Form 5477-R, as incidents occur. The COR will investigate the complaint and, if validated, document the unsatisfactory performance as a Contract Deficiency Report (CDR). The CDR will be processed through the contractor to the KO for resolution of the problem. Deficiencies will be annotated under the “Overall Support” metric.

(d) The contractor will be allotted time to resolve unsatisfactory performance. If the allotted time is exceeded this lack of action will also be documented on a CDR. In addition, if it involves a deliverable, review shall be made to determine if a reduction for services not rendered is appropriate under the terms of the contract clause for “Inspection of Services.”

(e) The Government expects the contractor to provide fully operational and satisfactory services. Negative contractor performance based on submitted documentation IAW this plan will be an agenda item at IPRs and addressed in the monthly status until resolved.

(4) Documentation/Reporting Procedures. Evaluation reports of Contractor performance shall be completed NLT 15 calendar days after the end of each month. All inspection documentation related to contract performance is an integral part of the file and must be maintained and stored properly. Supporting documentation may include but is not limited to meeting minutes, correspondence, trip reports, and deliverables. Furnish a copy of the completed monthly metric report NLT 15th of each contract month to: vendor/contractor lead/supervisor, ARCIC PMD, appropriate Contracting Officer, and COR file. Any unsatisfactory evaluation (Red) shall be fully documented on the DA Form 5479-R and submitted to the Contractor for comments. Upon receipt of comments, the COR shall complete action recommended and furnish to the Contracting Officer for any further action.

(5) Changes. The government may unilaterally change any of the surveillance processes/metrics in this plan prior to the start of the next monthly evaluation period. Changes may not conflict with the contract terms and conditions and shall not require modification to the contract.

Attachment: 1. Performance Metrics Worksheet

2. Addendum

ARCIC &

EXPERIMENTATION METRICS

PERFORMANCE METRICS

WORKSHEET

CONTRACT

Title of Contract: Support Sevices to the Maneuver Battle Lab Contractor Name: TBD

POP for Report:

(Remove Excess Color Codes)

A Key deliverables on-time

R One or more key deliverables late

A Generally meets stds with minor discrepancies

R One or more key deliverables don’t meet std.

3. Customer Focus

A Proactive on key issues.

R Slow remedy response

4. IPR Results

A Most in-process activities discussed

R One or more key actions missing.

A Generally meets stds

R At least one key deliverable doesn’t meet std

A Generally provides efficient management

R Deficient in one or more areas indicating inefficient management.

A Generally provides relevant, up to date information

R Provided out-dated, irrelevant info on at least one occasion.

8. Overall Support: Analysis/ Technical/ Administrative etc

A Meets all key technical and analytical requirements

R Failed to provide satisfactory key tech or analytical reports/advice during rating period.

Date:

Submitted by (COR):

ADDENDUM

Quality Assurance Surveillance Plan

Support Services to the Maneuver Battle Lab Period of Surveillance: Date of Award – Base Year and 4 Option Years

1. DESCRIPTION OF CONTRACT: Provide the program management, technical, and analytic skills in support of the MBL experimentation plan. Provide a skilled workforce to conduct experimentation in all tasks related to experimentation: planning, preparing, executing, analyzing, and documentation. Provide the skilled work force to meet experimentation requirements that have a long lead time typical found in the ArCP Campaign plan and meet short term requirements that are measurable in months. Provide a sustainable integrated simulation capability that is DIACAP compliant and can surge technical capability as required to meet experimentation requirements.

2. METHOD OF INSPECTION: FAR 52.246-4 Inspection of Services -paraphrased as follows: requires the contractor to provide and maintain an inspection system acceptable to the Government covering the services under the contract. Complete records of contractor inspection work performed shall be maintained and made available to the Government during contract performance. The Government has the right to inspect & test all services called for by the contract, to the extent practicable at all times and places during the term of the contract. The Government shall perform inspections and tests in a manner that will not unduly delay the work. If services do not conform to contract requirements, the Government may require re-performance at no increase in contract amount. If defects cannot be corrected by re-performance the government may require the contractor to take necessary action to ensure future performance conforms; and reduce the contract price to reflect the reduced value of the services. If the contractor fails to perform or to take necessary action to ensure future performance in conformity with contract requirements the Government may: perform the services and charge to the contractor any costs incurred or terminate the contract for default.

3. EVALUATION OF CRITICAL TASKS: The following tasks will be evaluated IAW provisions of FAR 52.246-4. (See Section 4.1 thru 5.4 of the performance work statement.)

4.1 Plan, Prepare, Execute operations to support and conduct experimentation.

4.2 Implement Live, Virtual, Constructive, or mixed simulation architectures for experimentation to address gaps and deficiencies across all Doctrine, Organization, Training, Materiel, Leadership, Personnel, and Facilities (DOTMLPF) areas.

4.3 Provide network services support various Local Area Networks (LANs) and Wide Area Networks (WANs).

4.4 Ensure that the experimentation network complies with the requirements of AR 25-2 (Information Assurance) and remains accredited IAW DoD Information Assurance Certification and Accreditation Process (DIACAP) so that it supports MBL events and that there is no interruption of experimentation.

4.5 Install, operate, configure, maintain, inventory, and account for Government Furnished Property.

5.1 Plan, coordinate, synchronize, identify resources for, execute, and document experiments in support of prototype experimentation.

5.2 Perform operational analyses utilizing Government-approved models, threat characteristics, and deployment and employment protocols in accordance with appropriate doctrine.

5.3 Manage McKenna Urban Site for training and experimentation.

5.4 Support Experimentation in current and future operations, and provide information and logistics management.

4. DELIVERABLES: The following table reflects the deliverables that will be generated and forwarded to the COR during execution of this subtask.

4.1 Task Area: Plan, Prepare, Execute operations to support and conduct experimentation.

4.1.1 Simulation Environment Planning. Provide personnel who develop simulation environments, develop planning and preparation products for experiments, demonstrations, studies, or tests that support experimentation events.

4.1.2 Simulation Environment Preparation. Develop and publish preparation products for simulation events, and execute preparation activities for simulation events.

4.1.3 Simulation Environment Execution. Provide personnel who can execute simulation events in accordance with planning and preparation guidance.

All documents deliverables meet standards of AR 25-50, TRADOC Reg. 1-11, and MBL SOP.

All document deliverables must be approved by the MBL Director and as required to the CDID and Experiment Director.

All training will be conducted to standard with the task conditions and standards identified in the training plan.

All Simulation inter-actors must pass with 100 percent proficiency before allowed to assume their duty position.

Deliverables approved NLT 100 days prior to execution, or IAW approved milestones.

· Conference schedule:

· Initial E-150

· Mid E – 90

· Final E – 45.

· IPR schedule:

· After IPC: Monthly

· After MPC: Bi-Weekly

· After FPC: weekly

Additional IPRs will be conducted as required providing 14 days notice before execution.

Training and certification completed NLT 5days prior to E-Day or as per experiment schedule

4.2 Simulation Environment. Implement Live, Virtual, Constructive, or mixed simulation architectures for experimentation to address gaps and deficiencies across all Doctrine, Organization, Training, Materiel, Leadership, Personnel, and Facilities (DOTMLPF) areas.

4.2.1 Provide personnel with the appropriate engineering and technical skills to perform simulation systems integration, development, and engineering services to enable MBL experimentation.

4.2.2 The Contractor shall provide support to integrate and establish Distributed Interactive Simulation (DIS) protocols, High Level Architecture (HLA), HLA Run Time Integrator (RTI) systems, Battle command architecture.

4.2.3 Provide the capability to trouble-shoot simulation software and hardware for the virtual and constructive simulations and simulators used by the MBL.

4.2.4 Provide the capability to assess the impact and associated requirements related to the addition and integration of a simulation or simulator not previously used by the MBL and its associated modeling and simulation tools.

4.2.5 Provide the capability to create or modify capabilities and parameters of simulators and simulations, including performance, environment, visual, sensor, and other characteristics as required to demonstrate and assess experiment related capability for the virtual and constructive simulations used by the MBL.

4.2.6 Provide the capability to develop new simulation models, compositions, entities, and force structure data-bases for the virtual and constructive simulations used by the MBL.

4.2.7 Provide the capability to conduct technical research, make recommendations, and with Government approval; implement improvement, enhancement, or replacement of constructive, virtual, and instrumented live simulations and simulators used by the MBL.

4.2.8 Configure, control, configuration management, database management, and tasks required to maintain software source code version control and properly document all software and database changes made to the virtual and constructive simulations used by the MBL.

4.2.9 Provide and maintain simulation data bases consisting of current and directed future task organizations.

4.2.10 Provide the capability to support development, modification, and management of simulation terrain databases and virtual models for the virtual and constructive simulations and simulators used by the MBL.

All documents deliverables meet standards of AR 25-50, TRADOC Reg. 1-11, and MBL SOP.

All document deliverables must be approved by the MBL Director and as required to the CDID and Experiment Director.

Deliverables approved NLT 100 days prior to execution, or IAW approved milestones.

4.3 Network Services. Provide network services support various Local Area Networks (LANs) and Wide Area Networks (WANs).

4.3.1 Provide technical support and execute LAN/WAN installation, configuration, operation, troubleshooting, monitoring, and maintenance within MBL facilities.

4.3.2 Provide technical support to maintain network connectivity required to conduct live, virtual and constructive experimentation between MBL simulatiuon facilities the McKenna Urban Operations Facility.

4.3.3 Provide technical support for connectivity using the Defense Research and Engineering Network (DREN), Battle Lab Collaborative Simulation Environment (BLCSE) Network, and any required project related installed WAN and LAN networks.

4.3.4 Relocate WAN and LAN equipment in order to provide any temporary network services and equipment to support the MBL efforts locally or off site as required by specific events or demonstrations.

4.3.5 Provide network design engineering services, development support, node operations support, acquisition recommendations, and system qualification requirements in support of simulation experimentation, demonstrations, and tests.

Adhere to Fort Benning, TRADOC, DA, and DoD Information Assurance and Security Policies and Regulations. This includes the DoD Information Assurance Certification and Accreditation Process (DIACAP).

IAW with the MBL Information Assurance and Accreditation Procedures and the following regulations:

AR 25-2, Information Assurance

AR 380-5, Department of the Army information Security Program

AR 380-40, Communications Security

USAIC 25-89, Information Assurance

MBL Security SOP

DoD 8500.1, Information Assurance

DoD 8510.1-M, Department of Defense Information Technology Security Certification and Accreditation Process

Additional specific policies and regulations are outlined in the MBL SOP.

Weekly and Monthly reports required as outlined in MBL Security SOP as well as executing in accordance with the timings of inspections as outlined in the identified regulations

4.4 Information Assurance and Physical Security:

4.4.1 Ensure that the experimentation network complies with the requirements of AR 25-2 (Information Assurance) and remains accredited IAW DoD Information Assurance Certification and Accreditation Process (DIACAP) so that it supports MBL events and that there is no interruption of experimentation.

4.4.2 Provide a subject matter expert trained IAW AR 25-2 by name to assist the MBL Information Assurance Security Officer (IASO).

4.4.3 Ensure that the MBL facilities comply with the requirements of facility physical security so that there is no interruption of experimentation.

Adhere to Fort Benning, TRADOC, DA, and DoD Information Assurance and Security Policies and Regulations. This includes the DoD Information Assurance Certification and Accreditation Process (DIACAP).

IAW with the MBL Information Assurance and Accreditation Procedures and the following regulations:

AR 25-2, Information Assurance

AR 380-5, Department of the Army information Security Program

AR 380-40, Communications Security

USAIC 25-89, Information Assurance

MBL Security SOP

DoD 8500.1, Information Assurance

DoD 8510.1-M, Department of Defense Information Technology Security Certification and Accreditation Process

Weekly and Monthly reports required as outlined in MBL Security SOP as well as executing in accordance with the timings of inspections as outlined in the identified regulations

4.5 Government Furnished Property (GFP). Install, operate, configure, maintain, inventory, and account for Government Furnished Property.

4.5.1 Provide an efficient process to manage equipment lifecycle utilization, and recommend new equipment and software version updates for lifecycle replacement.

All documents deliverables meet the standards of installation resource regulations and policies, and the MBL SOP.

All document deliverables must be approved by the MBL Director and as required to the CDID and Experiment Director.

IAW with installation resource regulations and policies, and the MBL SOP and project milestones.

5.1 Plan, coordinate, synchronize, identify resources for, execute, and document experiments in support of prototype experimentation.

5.1.1 Experiments may include a wide array of DOD experimentation activities including JCTDs and Army Technology Objectives (ATOs).

5.1.2 Experiments are conducted in accordance with memorandums of agreement and associated milestones between the customer and the Director, MBL.

5.1.3 Participate at various official forums such as Integrated Product Teams (IPTs), Integrated Concept Teams (ICTs) working groups, technology assessments, seminars and other similar forums.

5.1.4 Document reports with findings and recommendations that fully support the experimentation objectives.

5.1.5 Conduct New Equipment Training (NET) for all experiment participants where prototype equipment and new operational concepts are involved. Provide input, advice, and recommendations to the Government for development of handbooks, manuals, and training courses. Be prepared to assist the Government with new MBL equipment training (NET) of operationally suitable and ready prototypes (emerging technologies) to the Current Force.

5.1.6 Provide a fully expandable team of subject matter experts to the MBL in the areas of future concepts, operations, analysis, data collection, training, and modeling/simulation/wargaming as a non-personal service. Be capable of supporting experimentation that is focused on the individual Soldier up to and including the Brigade Combat Team (BCT). Be knowledgeable in current Army doctrine and Joint/Army Warfighting concepts.

5.1.7 Have a demonstrated ability to work with a variety of DoD commands and Government agencies.

5.1.8 Replicate selected higher headquarters role players and exercise controllers for the Army Expeditionary Warrior Experience (AEWE) experiment and other experiments as required. Operate an experiment control cell ensuring execution of the experimental design and analysis plan. Facilitate After Action Reviews (AARs) and conduct hot washes. Provide an intelligence fusion and effects cell along with other key staff, as determined by the experiment design plan.

5.1.9 Support technical integration of associated experimental technologies.

5.1.10 Be capable of evaluating industry and Government documentation related to Army requirements, capability generation, and developing recommended MCOE positions to the Government.

5.1.11 Develop the scenarios, road-to-war, operations orders, event list, and other necessary documents in preparation for experiments.

5.1.12 Provide additional surge personnel to meet experimentation support requirements once they are identified and to meet experimentation support requirements for new experiments that cannot be met with incumbent personnel.

5.1.13 Perform all range support operations functions in order to operate a range as outlined in U.S. Army Infantry Center Regulation 210-4 (Range and Terrain Regulation).

All documents deliverables meet standards of AR 25-50, TRADOC Reg. 1-11, and MBL SOP.

All document deliverables must be approved by the MBL Director and as required to the CDID and Experiment Director.

Deliverables approved NLT 100 days prior to execution, or IAW approved milestones.

· Conference schedule:

· Initial E-150

· Mid E – 90

· Final E – 45.

· IPR schedule:

· After IPC: Monthly

· After MPC: Bi-Weekly

· After FPC: weekly

Additional IPRs will be conducted as required providing 14 days notice before execution.

All document deliverables must be approved by the MBL Director and as required to the CDID and Experiment Director.

Deliverables approved NLT 100 days prior to execution, or IAW approved milestones.

Ensure that instrumentation supports experimentation objectives

Develop facility modernization plan IAW budgeting process.

IAW with installation resource regulations and policies, and the MBL SOP and project milestones.

5.4Support Experimentation in current and future operations, and provide information and logistics management. Provide overall operational and resource support planning, coordination, and synchronization of external support requirements for all MBL experiments.

5.4.1 Information Management. Provide information management in support of MBL experimentation.

5.4.2 Operations. Responsible for operations management (planning, coordination, and execution) of all MBL experimentation. The Contractor shall provide oversight of overall operational and resource planning, coordination, and synchronization of all resources for experiments.

5.4.3 Logistics. Provide logistics management in support of all MBL experimentation.

Adhere to Fort Benning, TRADOC, DA, and DoD Information Assurance and Security Policies and Regulations. This includes the DoD Information Assurance Certification and Accreditation Process (DIACAP).

IAW with the MBL Information Assurance and Accreditation Procedures and the following regulations:

AR 25-2, Information Assurance

AR 380-5, Department of the Army information Security Program

AR 380-40, Communications Security

USAIC 25-89, Information Assurance

MBL Security SOP

DoD 8500.1, Information Assurance

DoD 8510.1-M, Department of Defense Information Technology Security Certification and Accreditation Process

Weekly and Monthly reports required as outlined in MBL Security SOP as well as executing in accordance with the timings of inspections as outlined in the identified regulations

5. A Monthly assessment checklist based on above standards will be completed by the COR with a copy to the local contractor manager. Checklist will provide whether performance is superior, meets requirements or does not meet requirements. Deficiencies/details for why performance requirements were not meet to be included. Comments required only for performance above or below standards and for "overall support."

· Timeliness

· Quality of Support

· Customer Focus

· IPR Results

· Documentation

· Management

· Currency of Data

· Overall Support

6. INVOICE REVIEW: Contractor will submit invoices via WAWF clause of the contract performance work statement. The invoice will be reviewed and approved by the COR to determine if payable. Once approved, invoices will be submitted electronically to DFAS for payment.

7. DISCREPANCIES:

Discrepancies will be noted on DA Form 5479R (Report of Discrepancy) by the COR and provided to the contractor for comments/correction. Copy of the completed form will be provided to the Contracting Officer for retention and/or corrective action, as necessary.

Exhibit D, Quality Assurance Surveillance Plan (QASP)