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  • Question

    1) Is a QASP required for services under the SAT on less complex buys? 2) Is it necessary to solicit for 30 days opposed to 3-5 days if we have three qualified small businesses? 3) Can we set this aside specifically for a service disabled vet?


    Answer

    LT: Part 1
    Quality Assurance Surveillance Plans (QASP) are required for all Performance Based Service Acquisitions (PBSA).  They may be called something different, such as a Performance Plan.  Whatever it's called, it needs to identify the strategy that the government will use to assess the contractor’s performance against the performance thresholds, measurements, metrics, and incentives identified in the contract. 
     
    The should reference at FAR 46.401 is a suggestion that the QASP be prepared while the Statement of Work is prepared to ensure efficiency and effectiveness of the QASP.  It does not infer that a QASP is optional.  I believe the statement at FAR 46.401(a) clarifies the requirement to have a QASP because:  1. QA shall be performed...to determine that the supplies or services conform... and 2. QASPs are recommended to be prepared along with the SOW.  A QASP can be a simple document - it just needs to detail how the government will ensure the services received meet the requirements. 
     
    Agencies may have Agency Regulations that further detail requirements for performance monitoring on PBSAs. 

    CI:Part 2 and 3
    Quality Assurance Surveillance Plans (QASP) are required for all Performance Based Service Acquisitions (PBSA).  They may be called something different, such as a Performance Plan.  Whatever it's called, it needs to identify the strategy that the government will use to assess the contractor’s performance against the performance thresholds, measurements, metrics, and incentives identified in the contract. 
     
    They should reference at FAR 46.401 is a suggestion that the QASP be prepared while the Statement of Work is prepared to ensure efficiency and effectiveness of the QASP.  It does not infer that a QASP is optional.  I believe the statement at FAR 46.401(a) clarifies the requirement to have a QASP because:  1. QA shall be performed...to determine that the supplies or services conform... and 2. QASPs are recommended to be prepared along with the SOW.  A QASP can be a simple document - it just needs to detail how the government will ensure the services received meet the requirements. 
     
    Agencies may have Agency Regulations that further detail requirements for performance monitoring on PBSAs. 
     
    Under the Simplified Acquisition Threshold (SAT) of $150K you are always required to set your requirement aside for small business.  At FAR 19.203(b) it further states, “At or below the simplified acquisition threshold. The requirement to exclusively reserve acquisitions for small business concerns at 19.502-2(a) does not preclude the contracting officer from awarding a contract to a small business under the 8(a) Program, HUBZone Program, SDVOSB Program, or WOSB Program.”   At the contracting officers discretion and based on market research results, your acquisition may be set aside for SDVOSB. 
     
    The time frame for soliciting is not determined by the size of the businesses you are soliciting.  First you must look at FAR 5.101(a)(1) which requires transactions over $25,000 to be synopsized, unless it meets on of the exceptions at FAR 5.202.  Publicizing and response times can then be found at FAR 5.203 as follows:

    Whenever agencies are required to publicize notice of proposed contract actions under
    5.201, they must proceed as follows:
    (a) An agency must transmit a notice of proposed contract action to the GPE (see 5.201). All publicizing and response times are calculated based on the date of publication. The publication date is the date the notice appears on the GPE. The notice must be published at least 15 days before issuance of a solicitation, or a proposed contract action the Government intends to solicit and negotiate with only one source under the authority of 6.302, except that, for acquisitions of commercial items, the contracting officer may—
    (1) Establish a shorter period for issuance of the solicitation; or
    (2) Use the combined synopsis and solicitation procedure (see 12.603).
    (b) The contracting officer must establish a solicitation response time that will afford potential offerors a reasonable opportunity to respond to each proposed contract action, (including actions where the notice of proposed contract action and solicitation information is accessible through the GPE), in an amount estimated to be greater than $25,000, but not greater than the simplified acquisition threshold; or each contract action for the acquisition of commercial items in an amount estimated to be greater than $25,000. The contracting officer should consider the circumstances of the individual acquisition, such as the complexity, commerciality, availability, and urgency, when establishing the solicitation response time.


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