02-17
Procurement
Information Circular
Procurement
Information
National
Aeronautics and Circular
Space
Administration
Washington, DC
20546
PIC
02-17
September
13, 2002
GOVERNMENT QUALITY
ASSURANCE SURVEILLANCE PLAN (QASP) GUIDANCE
PURPOSE: To provide QASP development and implementation guidance.
BACKGROUND: An Agency-wide assessment of NASA's Performance-Based Contracting (http://ec.msfc.nasa.gov/hq/library/PBC.Team.Rpt.html) recommended the enhancement of surveillance guidance. In response, the Office of the Chief Engineer developed a draft NPG 7121.xx, Procedures and Guidelines for Surveillance Planning on NASA Programs and Projects, recently released for NODIS review.
Additionally, Inspector General Inspection Report G-02-011, Review of Performance-Based Service Contract Quality Assurance Surveillance Plans, dated July 2, 2002, recommended that guidance be issued to remind technical and procurement personnel of the regulatory requirements and policies regarding the implementation and utilization of service contract QASPs.
GUIDANCE:
1. What is a QASP? A QASP defines what the Government will do
to ensure that contractor performance is in accordance with contract
requirements and performance standards. Government surveillance activities
defined in the QASP can range from a one-time test or inspection of a product
or service to periodic in-process monitoring of on-going contract performance. Surveillance is
needed to ensure the Government receives the quality of supplies or services
called for under the contract, provide a basis for assessing on-going performance
to assure fair payment of costs and fees (e.g. milestone payments, fee
payments, etc.), and assure that appropriated funds are expended properly.Surveillance
is needed to ensure the Government receives the quality of supplies or services
called for under the contract, pays only for the acceptable level received, and
to assure that appropriated funds are spent wisely.
2. What types of contracts require a QASP?
- Performance Based Contracts (FAR 37.601(b))
- Service Contracts (FAR 46.103(a))
- Other Types of Work (FAR 46.401)
In addition to performance-based and service contracts, Government contract quality assurance surveillance may also apply to other types of contracted work. FAR 46.401(a) states that Government contract quality assurance shall be performed at such times (including any stage of manufacture or performance of services) and places (including subcontractor’s plants) as may be necessary to determine that the supplies or services conform to contract requirements. The schedule and method of this surveillance shall be documented in the appropriate QASP. The responsible technical office(s) in conjunction with the contracting officer are required to maintain suitable records that reflect surveillance observations conducted under the QASP, resulting contract administration actions and the outcomes of those actions.
3. How does a QASP help us? A QASP can provide a baseline for project monitoring and scheduling. It provides a mechanism for assessing and assuring contract compliance, and the results help to identify areas requiring corrective actions. Moreover, a QASP provides a mechanism for identifying, assessing, and documenting risks of contract performance, as well as tracking and mitigating risks. It also facilitates the transition from one Contracting Officer’s Technical Representative (COTR) to another by helping to ensure that the appropriate level of monitoring and surveillance continues. Additionally, records of surveillance conducted help document the basis for informed contract administration decisions, and provide support for contract actions taken.
4. Who prepares a QASP and when is a QASP developed? The technical office responsible for the requirement prepares the QASP (FAR 46.103). For many NASA requirements, the COTR is delegated the responsibility via the NASA Form 1634 to establish and deliver a QASP to the contracting officer. Surveillance, however, should be a collaborative integrated effort that includes consideration of all areas of contract management (engineering, quality, procurement, finance, property, environmental, export control, safety and health, etc.) as appropriate. Contract administration services associated with the contract, such as those delegated to the Defense Contract Management Agency (DCMA) or Defense Contract Audit Agency (DCAA) should also be reflected in the contract QASP.
Since the QASP is intended to measure performance against contract requirements and standards, coordinating and writing the Statement of Work (SOW) and preliminary QASP documents simultaneously is both effective and efficient. Consequently, NFS 1846.401 requires the development of a preliminary QASP prepared in conjunction with the SOW. The preliminary QASP reflects the Government's surveillance approach relative to the initially perceived programmatic risk, and is written at a general rather than specific level because the risks will not be completely identified at that time.
Prior
to the start of contractor performance, contracting officers shall ensure that
the responsible technical office revises the preliminary QASP to reflect the
risks that the Source Evaluation Board or Acquisition Team has identified as
being associated with the successful proposal.
This revised QASP, and subsequent updates implemented during the course
of contract performance is not included in the contract, but is included in the
Official Contract File.
5. What should a QASP contain?
A good QASP should include a surveillance schedule and clearly state the
surveillance method(s) to be used. The
detail in the QASP regarding specific work requirements should be consistent
with the importance and risk associated with that requirement. The QASP shall
recognize the responsibility of the contractor to carry out its quality control
obligations and shall focus on the level of performance required by the
contract, including the performance requirements and standards (e.g. quality,
quantity, and timeliness, etc.).
A
common approach to developing a QASP is to use the Work Breakdown Structure
(WBS) as a basis for establishing the surveillance structure for the
contract. This can be quite effective
in cases where the WBS provides a clear picture of the contractor’s approach
based on the type of work.
6. What surveillance methods should be used?
Selecting the most appropriate and efficient surveillance method(s) for
the effort involved is important. You should take into consideration risk,
size, time period, performance requirements and standards, availability and
effective utilization of government surveillance resources, and surveillance
value in relation to cost/criticality. Careful selection of appropriate
surveillance methods enables the government to determine the amount of
resources and associated costs needed to perform surveillance.
Examples
of surveillance methods include:
· Test/Inspection: This may be appropriate for infrequent work (e.g. one time fabrication to print) or for stringent, high-risk performance requirements (e.g. safety or health). With this method, contractor performance is verified by the Government at appropriate stages within the development, manufacturing, and/or delivery of the product or service. Test/inspection approaches can range from mandatory test/inspection, to periodic sampling depending on the risk related to the product/service being delivered and the demonstrated performance of the contractor.
·
Process/System/Product Monitoring: Monitoring of
contractor critical process, system, and/or product performance is a
surveillance method. This type of
monitoring is typically conducted to supplement test and inspection results,
but can also be used in lieu of test and inspection where appropriate. This monitoring can be achieved through
evaluation of contractor provided performance metrics, a periodic independent
review of contractor performance conducted by a designated Government
representative (participation in a design review, an evaluation of a product or
service delivery, or Government on-site assessment of a contractor process or
system), and/or by a recognized “third party” certification body (for example,
a quality system registrar).
Utilization of non-intrusive techniques such as use of contractor
reporting, shared access to data systems, and the use of data accession (data
available upon request) are recommended approaches to consider when defining
this surveillance method.
·
Customer Input: Although usually not a primary
method, this is a valuable supplement to more systematic methods. For example, in a case where sampling
indicates unsatisfactory service, customer complaints can be used as
substantiating evidence. In certain situations where customers can be relied
upon to complain consistently when the quality of performance is poor, e.g.,
dining facilities and building services, customer surveys and customer
complaints may be a primary surveillance method, and customer satisfaction an
appropriate performance standard. In all cases, complaints should be
documented, preferably using a standard form.
Whatever form of surveillance used, take care to ensure that no undue interference with contractor operations occurs. Relying on cumbersome and intrusive surveillance methods should be avoided whenever possible.
7. What kind of coordination should occur
between the Government and the Contractor regarding surveillance?
Contractors should be briefed on surveillance requirements and
responsibilities at a post-award conference. The surveillance methods to be
used should be discussed to confirm that they are fully understood. Surveillance
should be comprehensive, systematic, and well documented. Reviewing and
discussing the contractor's plan for maintaining an acceptable quality level
under the contract is important. In some cases, contractors may be required to
submit a Quality Control Plan to the Government prior to the post-award
conference. Although communication
regarding surveillance occurs between the Government and the contractor, the
Government still has responsibility for QASPs.
8. Do the surveillance activities ever change during the contract? The responsible technical organization and the contracting officer should periodically review the QASP once performance has begun to determine if changes in surveillance levels or methods are necessary, and update the QASP accordingly. When a change in the required work (e.g. - a change of design) or change in work performance results in a change in risk, potential surveillance changes should be considered. Static surveillance deployment (such as a delegation that does not change or routinely providing a monthly technical report without consideration of need) should be avoided.
Where
surveillance results consistently show good performance, the amount of
surveillance should be adjusted accordingly. This saves the government money,
reduces oversight burdens on the contractor, and recognizes the contractor's
achievement of performance. Conversely,
when performance is deficient, the contracting officer should notify the
contractor promptly, track corrective actions, and consider appropriate
surveillance adjustments.
9. Safety. When developing a surveillance approach, never lose sight of the fact that safety is NASA's highest value.
EFFECTIVE DATE: This PIC is effective as dated and shall remain in effect until canceled or superseded.
HEADQUARTERS CONTACT: Jeff Cullen, Code HK, (202) 358-1784, e-mail: jcullen@hq.nasa.gov or Tom Whitmeyer, Code QS, (202) 358-2228, e-mail: twhitmey@hq.nasa.gov.
R. Scott Thompson
Director,
Contract Management Division
DISTRIBUTION:
PIC List
HK/cbo/x1248/9-9-02;
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