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SURVEILLANCE PLAN. March 23, 2010. What is Surveillance?. The FAR, Part 46 refers to Government contract quality assurance as surveillance. Quality assurance is necessary to determine that the supplies or services conform to the contract requirements.
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SURVEILLANCE PLAN March 23, 2010
What is Surveillance? • The FAR, Part 46 refers to Government contract quality assurance as surveillance. • Quality assurance is necessary to determine that the supplies or services conform to the contract requirements. • It is the Government’s duty to assure that appropriated funds are spent wisely. That duty is fulfilled in part through surveillance.
What Does Surveillance Mean? • As stated in NASA FAR Supplement 1846.000 SCOPE OF PART, Surveillance may be conducted through “insight” or “oversight.” • The decision to use insight or oversight is based on an assessment of the risk inherent in the activity being surveilled. • Surveillance must be conducted whether or not the contract effort has been structured as performance –based acquisition.
Government Surveillance Requirements (FAR 46.4) (A) • Government quality assurance shall be performed as necessary to determine that the supplies or services conform to contract requirements. • Each contract shall designate the place or places where the Government reserves the right to perform quality assurance.
Government Surveillance Requirements (FAR 46.4) (B) • Government inspection shall be performed only by or under the direction or supervision of Government personnel. • In determining the type of quality assurance, the Contracting Officer shall consider the criticality of the supplies or services.
Government Surveillance Requirements (FAR 46.4) (C) • Government quality assurance on subcontracted supplies or services should be performed only when in the best interest of the Government. • Government quality assurance performed for foreign governments or international agencies shall be administered according to the foreign policy and security objectives of the United States.
Who Creates and Maintains the Government Surveillance Plan? • Contract Specialists should work with PM’s to ensure plans are developed, prepared and updated and ensure that oversight practices are consistent for the specific programs and projects. • COTRs should have the training, qualification and experience necessary to perform the delegated duties and responsibilities. • Document and maintain information necessary to support contract oversight activities
Guidance for Preparation of a Government Surveillance Plan • Prepare a preliminary surveillance plan in conjunction with the statement of work. • Plans should contain performance indicators. • Common performance indicators are: timeliness, quality, documentation, procedures/safety, and cost control. • The surveillance plan is provided with the solicitation as a courtesy copy.
Guidance for Preparation of a Government Surveillance Plan (C) • After contract award, Contract Specialists shall ensure that the surveillance plan is revised to reflect the risks associated with the successful offeror's proposal. • The final surveillance plan shall not be incorporated into the contract, but should be periodically reviewed and updated to ensure its currency.
Contractor Quality Assurance Surveillance Plan • When higher level quality standards are required for a complex acquisition, request the contractor submit a contractor quality surveillance plan. • The contractor’s plan should be evaluated, negotiated if appropriate, and incorporated into any resulting contract as an attachment.
Best Practices • Do your research to determine if the Government surveillance plan and the contractor quality surveillance plan are required. • Check box 3(a) in the COTR Delegation Checklist (NF 1634) • Attach the Government surveillance plan to the COTR Delegation Checklist and explain the procedures to the COTR.
Lessons Learned • The Government surveillance plan is provided as a courtesy copy with all solicitations. The Government surveillance plan is not an attachment to the contract. • Only the contractor quality surveillance plan is incorporated in the contract as an attachment. • After contract award, the COTR shall perform its surveillance activities in accordance with the Government surveillance plan. • The COTR shall keep documentation of Government surveillance activities and shall provide copies to the Contract Specialist. • The Contract Specialist shall keep a file with all the Government surveillance documentation.