1. Quality – A Contract Runs through It
EPA Quality Management Conference
Marion Kelly, EPA Office of Water
Lynn Walters, CSC
May 14, 2009

2. EPA QA Requirements
“No environmental data collection work shall be started until the QAPP has been approved and distributed...”
EPA Quality Manual CIO 2105-P-01-0
Applies to all work performed by or on behalf of EPA (i.e., contracts, grants, interagency agreements)
Environmental Data: “Any measurements or information that describe environmental processes or conditions, or the performance of environmental technology.”
Includes “any information collected directly from measurements, produced from models, and compiled from other sources such as databases or literature.”

3. Same Goal; Different Implementation
Contracts
Code of Federal Regulations (CFR), Title 48 (Federal Acquisition Regulations, FAR), Part 46 (Quality Assurance)
EPA Contracts Management Manual (CMM, EPA Order 1900)
Grants (PPAs and PPGs) and Cooperative Agreements
40 CFR Parts 30, 31, and 35
Interagency agreements
Negotiated
Graded approach applies to all

4. QA in Contracts Governed by
EPA Quality Policy
48 CFR 46
Allows Federal Agencies to select a national consensus standard as a basis for their quality specifications (EPA selected ANSI/ASQC E4)
Through tailoring language to 48 CFR 46, EPA requires that contractors submit a QMP and QAPP (or equivalent) to demonstrate conformance to the standard
EPA CMM
Describes EPA procedures for implementing 48 CFR 46
Addressed throughout the contracting process
Solicitation
Award
Implementation

5. QA in the Contracting Process
Includes contract QA clauses
Specify contract QA Needs
Pre-solicitation
Prepare PIN
Package
w/ Contract QA Review Form
OAM Review, Communications, & Resolution of Issues
Legal Review, Communications, & Resolution of Issues
OAM finalizes procurement (PIN) package & publishes synopsis
Proposal Review and Selection
RFP Published
Contractors submit proposals
TEP evaluates proposals & writes interrogatories/ cost proposal audit conducted
Negotiations and legal review prior to award
Submits QMP/QAPP
Evaluate QMP/QAPP
Contract Award & Implementation
Kickoff mtg. with contractor
EPA prepares WA and WA level QA Review Form
WA issued
Contractor prepares WP & CE
Contract awarded
Specifies WA QA req’ts
Includes QA plan/strategy
Refine QA plan/strategy as needed
Monitor technical performance & QA implementation
EPA reviews/approves WP & CE
Review & approve QA plan/strategy

6. Pre-Solicitation
Form specifies contract QA needs
Program Office prepares PIN Package with QA Review Form
Reviews involve dialog with program office and refinement of requirements
OAM Review, Communications, & Resolution of Issues
Legal Review, Communications, & Resolution of Issues
RFP details contract QA requirements and criteria (points) for scoring QA documentation
OAM finalizes procurement package & publishes synopsis

7. QA Review Form (Pre-solicitation)
Required for all solicitations and contracts
Standard form available in Contracts Mgmt Manual (CMM) Appendix 46.1D
Program offices may tailor form to their needs
Prepared by COR (i.e., contract or task order Project Officer), working with QAM

8. QA Review Form (cont’d)
Documents if contract involves environmental data
If yes, form requires identification of QA measures required for the contract
Form ensure offerors are required to provide the QA needed to support the contracts
Conveys these requirements to the CO

9. QA Elements considered via Contract Review Form
Strategy for technical evaluation of quality in contractor proposal
Pass/fail or a percentage of total points
Standards used in lieu of or in addition to ANSI/ASQC E4 (the basis for EPA’s Quality System)
Submission of written QA plans
QMP as part of proposal
QAPP as part of proposal
Contract QAPP
Project-specific QAPPs
Example QAPP (pre-award only)
QAPP upon award
Other Pre-award and Post-Award Quality Assessments
On-site evaluations/lab audits
Quality system audits
PT samples
Periodic QA reports
Certifications/corrective actions

10. PIN Package QA Review Form becomes part of PIN package
Routed through program office approvals and to OAM to initiate procurement
CO uses QA Review Form to select appropriate contract clauses into the solicitation (e.g. RFP)

11. Proposal Review and Selection
RFP is issued
Evaluate Contractor’s QA system & proposed strategies
Proposal includes QA documentation
Technical Evaluation Panel evaluates proposals & writes interrogatories/ Cost proposal audit is conducted
Negotiations and Legal review prior to award
Contractors submit proposals
QAM is part of TEP if contract >$500K

12. Contract Award and Implementation
QA Review Form needed for every WA, DO, TO
QA Review Form needed for every WA, DO, TO
Kickoff Meeting with contractor managers, QA staff, CBI Document Control Officer, Project Teams
WAM prepares WA, including applicable QA requirements (& Contract QA Review Form)
OAM awards contract
Requests revision if needed
WAM continually monitors contractor compliance with QA and technical requirements
Contractor prepares WP and CE, including applicable QAPP or equivalent
WAM Review
Approves
For WAs with QAPP, Monthly Progress Reports addres QA concerns/issues

13. Contract Award and Implementation
Contract Award is only the beginning!
QA requirements must be considered for every project, WA, TO, or DO involving environmental data
If new QA documentation is needed (e.g., a project QAPP) incorporate requirement into the WA/TO/DO.
If project is based already-approved quality documentation, incorporate requirement for adherence to that document in the WA/TO/DO.
QA Review Form must be filled out for each WA/TO/DO
Completed by COR and approved by QAM
Must be consistent with contract requirements

14. Is there a Catch-22?
“No environmental data collection work shall be started until the QAPP has been approved and distributed...”
Address this by including requirement for contractor to prepare QAPP as part of their WA/DO/TO
What about WA/DO/TOs that involve support for planning studies?
How do you approve and distribute a QAPP for projects or studies that are still being designed?
Answer: Dynamic (i.e., staged) QAPP and graded approach

15. PWS vs. SOW
FAR : Performance based service acquisition (PBSA) is preferred method for contracting
A performance work statement (PWS) describes services in terms of measurable outcomes and supports PBSA
Statement of work (SOW) is more traditional approach. It defines work in terms of specific services to be performed. Does not easily support PBSA
Car waxing example:
SOW defines exactly how to wax the car (apply wax with soft sponge, using a circular hand motion...)
PWS defines the required outcome (waxed car shall present a uniform glossy appearance and reflect 1 inch letters placed 5 inches in front of it...)
QA Surveillance Plan (QASP) required for PBSAs
Not a substitute for a QAPP

16. QASP vs. QAPP QASP: Government-developed & applied
Defines the procedures & metrics the government will use to evaluate contractor performance
Mechanism for surveillance oversight of the Contractor’s QC efforts to assure they are timely, effective and compliant with contract and WA/TO/DO requirements
QAPP: Contractor-developed & applied
Defines the management and procedures the contractor will take to meet the quality standards set forth in the contract or WA/TO/DO

17. For Additional Information
For additional information, contact:
Marion Kelly
EPA Office of Water
Engineering and Analysis Division
USEPA Headquarters
Ariel Rios Building (Mail Code: 4303T)
1200 Pennsylvania Avenue, N. W.
Washington, DC 20460
Phone: