I am looking for a Professor who teaches QA or CON and can tell us at the current time as to what is being taught to students about who is responsible for building a QASP (e.g... require...COR.. etc..) knowing the KO/CO is responsible for a QASP to support surveillance of a Services contract.
Also, wondering what is being taught to CON students as to what is a Service today (besides the Service Contract definition in Part 37) in the face of the COR and QASP being part of an applicable service contract.
Case-in-point, when contracting to lease items, e.g., vehicles, hotel rooms, vehicles, and portable latrines, why is it a service today when, for example, it is not necessarily connected literally to CMRA reporting. Finally, some requirers do not believe a Service Contract Approval from their local 1-Star or MACOM even depending on the threshold for the aforementioned; can you clarify this too.
The definition of “service contract” in FAR Part 37 is the standard. I admit, your examples (portable latrines, vehicle rentals, hotel rooms) don’t necessarily sound like services according to the FAR definition. But, the Government doesn’t own the latrine, vehicle, or hotel room. Also, the weekly cleaning of portable latrines, servicing of vehicles, or food service connected with hotel accommodations can easily fall under the Service Contract Act. GSA, as the Executive Agent for Federal Procurement Data System (FPDS), identifies rentals/leases with Product Service Codes (PSC) instead of supply codes.
Open full Question Details
The comments about CMRA and approval levels will be unique to your Agency. However, these types of databases track manpower equivalents resulting from service contracts and it makes sense that your examples might be exempt from this requirement.
DFARS 246.401 makes the Contracting Officer responsible for developing a QASP under service contracts. The FAR allows the Contracting Officer to consider QASP proposals from the contractor in the development of the Government plan. Additionally, the contract file must address the need for a surveillance plan; even if the requirement is a supply.
FAR 37.101 “Service contract” means a contract that directly engages the time and effort of a contractor whose primary purpose is to perform an identifiable task rather than to furnish an end item of supply.
DFARS 246.401 -- The requirement for a quality assurance surveillance plan shall be addressed and documented in the contract file for each contract except for those awarded using simplified acquisition procedures. For contracts for services, the contracting officer should prepare a quality assurance surveillance plan to facilitate assessment of contractor performance, see 237.172. For contracts for supplies, the contracting officer should address the need for a quality assurance surveillance plan.