LESSON 2 Quality Assurance Delegations

1. LESSON 2Quality Assurance Delegations

2. Lesson Introduction Given a contract, you will be able to delegate Quality Assurance (QA) responsibilities.

3. Lesson Introduction • It is the prime contractor’s responsibility to manage its subcontractors. • Functional specialists must assure prime contractors provide effective prime contractor management of subcontracted work, maintaining conformity of high consequence risk subcontracted products and services. • When delegations are considered, they will only be issued when in the best interest of the government, based on risk.

4. Lesson Objectives Upon completion of this lesson, you should be able to: • Determine the need for delegation of QA responsibilities. • Plan communication protocols to be used during the QA delegation period. • Determine the requirements for a QA delegation. • Determine the requirements for QA delegation execution/management. • Prepare a QA delegation via the Delegation eTool. • Respond to a received QA delegation. • Use the Delegation eTool to track a QA delegation. • Manage a QA delegation via the Delegation eTool. • Use the Electronic Contract Administration Request System (ECARS) to access a QA delegation. • Identify the ECARS QA delegation Document Control Number (DCN)

5. Lesson Topics This lesson covers the following topics: • Determining the Need for Delegation • Delegation Communication Protocols • QA Delegation Requirements • Responding to a QA Delegation • Executing and Managing a Delegation • Preparing a QA Delegation via Delegation eTool • Managing a QA Delegation via Delegation eTool • Accessing a QA Delegation via ECARS eTool

6. WIIFM? This lesson is important because: • You may occasionally require someone else to perform Government Contract Quality Assurance (GCQA) tasks for elements of your contract because you are unable due to location differences. • Likewise, you may be required to perform GCQA tasks for someone else’s contract due to similar reasons. • This lesson prepares you for both situations!

7. Definitions (1 of 4) • Delegator (Sender)QA personnel initiating the delegation • Delegatee (Receiver)QA personnel designated to receive, accept/reject, and execute the delegation Note: The delegator and the delegatee share a responsibility to fulfill the GCQA requirements of the contract.

8. Definitions (2 of 4) • Delegate/DelegationThe assignment and authority of other QA personnel to perform GCQA tasks at another location

9. Definitions (3 of 4) • Re-delegate/Re-delegationTo delegate further into the supply chain, e.g., 1sttier subcontractor to 2ndtier subcontractor • Term re-delegationapplies to delegations in which a single function is further delegated to a lower tier. Sub-delegationscan include multiple delegated functions. • Re-delegations or Sub-delegations create a parent-child relationship between the accepted delegation (parent) and the sub-delegation (child) at a lower tier.

10. Definitions (4 of 4) • Re-assignmentThe re-assignment of an accepted delegation within the Contract Management Office (CMO) by an Administrator • ForwardTo move a delegation at the receiving office between delegatees prior to acceptance

11. Delegation Process Analyze work and determine the need to delegate. Determine Need Open Lines of communication between the delegator and the delegatee. Open Communication Prepare and send the delegation using the Delegation eTool. Delegation Preparation Delegation receipt – acceptance and rejection. Delegation Receipt Re-delegation to lower tier support point. Re-delegations Execution and management of delegated workload. Delegation Execution Delegation closure and feedback. Delegation Closure

12. Determining the Need for Delegation Lesson Topics: Determining the Need for Delegation Delegation Communication Protocols QA Delegation Requirements Responding to a QA Delegation Executing and Managing a Delegation Preparing a QA Delegation via Delegation eTool Managing a QA Delegation via Delegation eTool Accessing a QA Delegation via ECARS eTool

13. Topic 1: Determining the Need for Delegation Reasons to delegate: • Surveillance considerations • Shipping/facilities requirements • Process/product characteristics

14. Determining the Need for Delegation (continued) Before issuing delegations for subcontract support, the functional specialist must consider: • The prime contractor’s plans for purchasing of materials and components (make or buy). • Adequacy of prime contractor management of subcontractors to mitigate risk to contract performance. • Critical path activities to identify potential long lead time processes that may impact production schedule and delivery. The QAS must ensure that the prime supplier is capable of performing QA oversight for all subcontractors!

15. Determining the Need for Delegation (continued) • Determine the need to issue delegations based on assessed risk associated with prime contractor supplier controls, subcontractor performance history, when surveillance may only be adequately accomplished through direct DCMA involvement at the subcontract level Delegations must not be issued unless the subcontracted effort has been identified as a risk on the prime CMO’s surveillance plan or program support plan

16. Why Delegate? • In Government’s best interest • Place of Performance (PoP) is at another location • Specific customer direction must be communicated • Other (non-QA) functions are required at PoP • When PoP CMO must re-delegate • To assist the prime CMO in determining conformance of subcontracted product Delegation does notrelieve the prime supplier of any contract responsibilities. DCMA and supplier inspectors examine refurbished U.S. Army vehicles in the Theater-Provided Equipment Refurbishment (TPER) program in Kuwait. (Photos courtesy of DCMA-ME)

17. Reasons to delegate • Customer-directed activity • Risk based surveillance considerations • Shipping/facilities requirements • Inadequate Prime contractor controls

18. Reasons to Delegate: Customer Directed Activity • Quality Assurance Letter of Instruction (QALI), Memorandum of Agreement (MOA), or Memorandum of Understanding (MOU) from the customer outlining required surveillance activities. • Surveillance can be accomplished only at the subcontract level The prime supplier is responsible for subcontractor performance!

19. Reasons to Delegate: Surveillance Considerations • Risk Assessment results and surveillance planning decisions • Feature/characteristic or process with high or moderate risk consequence combined with high or moderate risk likelihood • Product/process conformity can only be determined at the subcontractor level. The prime supplier is responsible for subcontractor performance!

20. Reasons to Delegate:Process/Product Characteristics • High/Moderate consequence risk areas: • National Aeronautics and Space Administration (NASA) (when authorized) • Critical characteristics or processes associated with Mission Critical Items (MCIs) or Critical Safety Items (CSIs) • Safety of Flight (SOF) • First Article Test (supplier testing) Not all “critical” items require delegation

21. Reasons to Delegate: Shipping and Facilities Requirements • Requirements to: • Ship items directly to the user • Inspect at source • Contract specifies QA functions be performed only: • By the Government • At the subcontractor’s facility

22. Reasons to Delegate: Inadequate Prime Contractor Controls • Negative subcontractor performance • Prime contractor’s control of subcontracted work is contractually noncompliant • CAR has been issued to the prime contractor Expect the unexpected; delegation may be required at any point as the result of unforeseen circumstances

23. Reasons to Delegate: Other Considerations • Corporation Inter/Intra-Divisional Work Transfer • CMO cognizant of the division identified in the contract must coordinate delegation with CMO cognizant of the division involved with performance • Host Nation Delegations • delegations issued to/from a foreign government • DCMA Centers • other DCMA organizations whose assistance is necessary for contract oversight. • ITAR/EAR Restrictions • if subcontractor will generate or require access to export-controlled articles or technical data, subcontracts/purchase orders must identify ITAR/EAR restrictions

24. Reasons Not to Delegate • Items are: • Non-critical • Low complexity • Minimal influence on contract performance • Low-risk supplier with positive performance history • Exceptions exist [e.g., CSI, SOF, and First Article Testing (FAT)] Review every situation to determine whether delegation is required!

25. Question and Answer Which two GCQA functions drive delegation decisions? (Select two.) • Risk Assessment • Surveillance Planning • Negative subcontractor performance • Item criticality • Contract requirements

26. Question and Answer What is one reason to choose not to delegate? • First Article Testing (supplier testing) • Safety of Flight (SOF) is not compromised • Items are of low complexity • Contract specifies that QA tasks be performed by Government

27. Delegation Communication Protocols Lesson Topics: Determining the Need for Delegation Delegation Communication Protocols QA Delegation Requirements Responding to a QA Delegation Executing and Managing a Delegation Preparing a QA Delegation via Delegation eTool Managing a QA Delegation via Delegation eTool Accessing a QA Delegation via ECARS eTool

28. Topic 2: Delegation Communication Protocols Communication: • Is vital to the success of a delegation • Should occur throughout the delegation process

29. Open Communications • Delegator: • Establishes communication lines with delegatee • Maintains communication through delegation lifecycle • Communication should include: • Resource estimates • Scope of effort to be delegated • Supplier capabilities • Address all known gaps • All forms of communication acceptable • must be documented

30. Communication for PoP Delegations Prime CMO must: • Ensure sub-tier office receives contract and all other applicable information • Determine responsibility for customer engagement: • QAS • Prime supplier • Subcontractor Subcontractor Prime QAS Customer

31. Question and Answer Jon, the QAS for Wally’s Widgets, is reviewing a contract and notes the place of performance is Jimmy’s Scrapers. What is the first action Jon should take? • Issue a Contract Deficiency Report (CDR) • Call the QAS for Jimmy’s Scrapers • No action required • Issue a delegation

32. QA Delegation Requirements Lesson Topics: Determining the Need for Delegation Delegation Communication Protocols QA Delegation Requirements Responding to a QA Delegation Executing and Managing a Delegation Preparing a QA Delegation via Delegation eTool Managing a QA Delegation via Delegation eTool Accessing a QA Delegation via ECARS eTool

33. Topic 3: QA Delegation Requirements Delegation requirements for: • Specific Requirements • Purchase Order • Host Nation • Blanket

34. Delegation Methods Two methods for delegating once a decision to issue a delegation has been rendered: • Selective evaluation delegations • Subcontractor surveillance delegations A single delegation that includes both of these requirements may be issued when appropriate to minimize the need for multiple delegations

35. Selective Evaluation Delegations • One-time nature, short in duration, and do not require recurring surveillance • Used to determine level of confidence in prime contractor controls at the subcontractor • Used to spot check subcontractor performance data • Must include specific actions to be performed or information verified

36. Subcontractor Surveillance Delegations • QALI/MOA/MOU imposes required surveillance that can only be conducted at the subcontract level • Product/process characteristics of high/moderate risk are subcontracted out and conformance can only be determined at the subcontractor level • Issued to protect Government’s interests until the prime contractor’s corrective action plan is implemented • May be based on a single purchase order or in the form of a blanket delegation

37. eTools for Delegations • Delegation eTool is used for subcontract delegations • ECARS eTool is used for International (incoming) and NASA delegations • Product Deficiency Reporting & Evaluation Program (PDREP) for PQDR support investigation requests

38. Delegation Documentation Requirements – DCMA Policy • Risk statements • Instructions related to product release • Source of customer directed activity [Memorandum of Agreement (MOA), Quality Assurance Letter of Instruction (QALI)] • Personnel, system, process, or material certifications • First article inspection and/or specific testing requirements • ITAR/EAR restrictions • Contracts or purchase orders • Specific regulatory requirements • System safety risks • Authority relative to waivers and deviations • Identification of SOF, CSI, critical characteristics/process • Requirements relative to frozen/ locked configurations • Requirements relative to subcontractor generated plans • Quality/inspection system requirements The functional specialist must upload appropriate supporting documents

39. Specific Delegation Requirements • Delegations must be specific to include tasks that must be performed. • These tasks result from the sender and receiver communications. • Avoid generic statements, such as: • Perform GCQA. • Conduct surveillance activities.

40. Purchase Order Requirements Purchase Orders (POs) shall include: • Government right of access clause • Appropriate quality/inspection system requirements • Appropriate/accurate technical requirements or reference QAS ensures the prime supplier includes all applicable requirements in the PO.

41. Host Nation Delegations • Continental United States (CONUS) CMOs to Outside the Continental United States (OCONUS) • Delegations are sent to the cognizant DCMAI CMO • DCMA can either perform the delegation or re-issue the delegation to the cognizant Host Nation • Delegations shall identify International Traffic in Arms Regulation/Export Administration Regulation (ITAR/EAR) restrictions, as applicable • Delegations received from a foreign Government are processed through the Department of Defense Central Control Point (DoDCCP) to the field via ECARS Guidelines for International and Host Nation tasks are outlined in the DCMA Policy

42. Blanket Delegations • Issued when multiple individual delegations to a specific facility will be an administrative burden • Issued for: • A group of POs • Surveillance of repetitive processes or tasks • All purchases of the same or similar items • Reviewed annually • Blanket delegations with expired final delivery dates must be closed and reissued based on active contracts with future final delivery dates

43. Question and Answer Susan is a QAS at a manufacturing plant in Savannah, GA. She must issue a delegation asking Jerry (a QAS in Jacksonville, FL) to perform a product examination on aluminum aircraft rivets at Widget Wonder’s Jacksonville facility.Which eTool should Susan use to create the delegation? • ECARS • Delegation eTool • Plant Clearance Automated Reutilization Screening System (PCARSS) • Preaward Survey System (PASS)

44. Question and Answer Widget Wonder is a supplier of aircraft components used in multiple U.S. military aircraft. As such, the company is a subcontractor for many Government contracts.What must be included in every purchase order to ensure timely Government access to the supplier’s facility for QA purposes? • Right of access clause • Memorandum of Agreement (MOA) • Letter of Delegation (LOD) • Quality Assurance Letter of Instruction (QALI)

45. Question and Answer Widget Wonder is a subcontractor of aircraft rivets for a large ACAT I military aircraft contract. Multiple POs will be issued for similar items to Widget Wonder by the prime supplier over a 3-year period. Can a blanket delegation be issued to the DCMA QAS at Widget Wonder for all POs issued to Widget Wonder on that aircraft contract? • Yes, because issuing separate delegations for each PO is an administrative burden. • Yes, but separate blanket delegations must be issued every year. • No, because each PO requires a separate delegation. • No, because blanket delegations can only be issued for prime suppliers.

46. Responding to a QA Delegation Lesson Topics: Determining the Need for Delegation Delegation Communication Protocols QA Delegation Requirements Responding to a QA Delegation Executing and Managing a Delegation Preparing a QA Delegation via Delegation eTool Managing a QA Delegation via Delegation eTool Accessing a QA Delegation via ECARS eTool

47. Topic 4: Responding to a QA Delegation Upon receipt of a delegation, the receiver must: • Review the work requirements • Accept • Reject • Re-delegate

48. Delegation Receipt Receiver shall: • Review delegated work requirement(s) • Assign a lead for a multi-functional delegation • Accept, accept with limitations, or reject the delegation • Decisions must be made within 14 calendar days  • Only the receiving CMO Commander/Director or designee can reject a delegation

49. Delegation Acceptance with Limitations • AKA: Accepting and supplementing • Uncommon occurrence • Proper communication should prevent limited acceptance of a delegation • If considered, sending and receiving CMOs must negotiate a mutual agreement and avoid escalation • If used, inform all involved parties of the rationale

50. Delegation Rejection • Insufficient personnel is not a valid reason to reject a delegation! • Consequences and risks still exist • Surveillance is still required • Escalate the situation so a solution can be found: Head Quarters (HQ) Technical Directorate h Regional Commander h • CMO Commander • h First Line Supervisor (FLS) • h Receiving QAS Use the Contract Management Team (CMT) eTool to locate DCMA personnel at subcontractor’s location.