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Iowa NRCS - 2019
IOWA NRCS QUALITY
ASSURANCE PLAN
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1 TABLE OF CONTENTS
1 Table of Contents .................................................................................................................................. 1
2 Tables and Figures ................................................................................................................................ 3
3 List of Common Abbreviations and Acronyms .................................................................................... 4
4 Introduction ........................................................................................................................................... 5
Purpose .......................................................................................................................................... 5
Background ................................................................................................................................... 5
Policy ............................................................................................................................................ 6
Responsibilities ............................................................................................................................. 7
5 Guidelines for Area and Field Office Quality Assurance Reviews ...................................................... 8
Implementation ............................................................................................................................. 8
Field Office Quality Assurance Reviews (TO BE COMPLETED BY AREA OFFICE (REVIEW TEAM) .................................................................................................................................. 12
Area Office Quality Assurance Reviews (To be completed by IOWA LT (Review Team) ....... 13
6 Spot Checks ........................................................................................................................................ 14
Introduction ................................................................................................................................. 14
Personnel ..................................................................................................................................... 14
Key roles and responsibilities ............................................................................................. 14
Spot check cadre and spot check teams .............................................................................. 16
Spot Check Practice Lists ........................................................................................................... 17
Practice risk ......................................................................................................................... 17
Practices to check (state-wide criteria) ............................................................................... 18
Generating area practice lists .............................................................................................. 18
Practice list review and modification .................................................................................. 19
Technical Service Providers and contractors ...................................................................... 20
Conducting Spot Checks ............................................................................................................. 21
Preparation .......................................................................................................................... 21
Implementation ................................................................................................................... 21
Closeout, corrective actions and records ............................................................................. 22
Spot Check Timeline ................................................................................................................... 23
7 Ongoing Quality Assurance Efforts .................................................................................................... 23
Pre-obligation Review ................................................................................................................. 23
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Annual CSP Quality assurance Review ...................................................................................... 23
7.3 Quarterly Certifications ............................................................................................................... 23
8 Civil Rights Reviews .......................................................................................................................... 24
9 Conservation Compliance ................................................................................................................... 24
Introduction ................................................................................................................................. 24
Food Security Act Compliance Status Reviews .......................................................................... 24
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2 TABLES AND FIGURES
Table 1- Projected five year QAR Schedule (Year 1 = FY19) ................................................................... 10 Table 2- Spot check timeline (summary) .................................................................................................... 23
Figure 1- Example week-long QAR schedule for the Review Team ........................................... 11
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3 LIST OF COMMON ABBREVIATIONS AND ACRONYMS
Abbreviation or Acronym
Definition
ASTC-C Assistant State Conservationist – Compliance
ASTC-FO Assistant State Conservationist – Field Operations
ASTC-M&S Assistant State Conservationist – Management & Strategy
ASTC-P Assistant State Conservationist – Programs
ASTC-Partnerships
Assistant State Conservationist – Partnerships
AE Area Engineer
APS Area Program Specialist
ARC Area Resource Conservationist
DC District Conservationist
EcoSci Ecological Sciences
FOTG Field Office Technical Guide
HELWC Highly Erodible Land/Wetland Conservation
IDEA Integrated Data for Enterprise Analysis
JAA Job Approval Authority
LT Leadership Team
PRS Performance Results System
QAR Quality Assurance Review
SC Soil Conservationist
SCT Soil Conservation Technician
SRC State Resource Conservationist
SCE State Conservation Engineer
SSS State Soil Scientist
STC State Conservationist
TSP Technical Service Provider
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4 INTRODUCTION
PURPOSE
The purpose of the State Quality Assurance Plan is to document point of delivery oversight and evaluation activities for Iowa NRCS (Title 340, General Manual, Part 404, Subpart C).
Quality assurance is the monitoring of program, technical, civil rights, administrative and operational activities that ensure products and services are delivered in a consistent coordinated effort to adhere to statute, policy, standards, and criteria that include but are not limited to the following:
o Office of Management and Budget (OMB) Circular A-123, Management’s Responsibility for Internal Control (December 2004)
o Departmental Manual 1110-002, USDA Management Control Manual (November 2002)
o The Improper Payments Information Act of 2002 (IPIA) (November 2002) o The Improper Payments Elimination and Recovery Act of 2010 (IPERA) (July
2010)
BACKGROUND The policy applies to conducting reviews of NRCS programs and operations to determine
how well internal controls are functioning and how they can be improved.
Quality assurance reviews are designed to ensure internal controls are in place to:
o Identify, manage, and reduce risk to the agency. o Promote and maintain economical, efficient, and effective operations. o Produce quality products and services consistent with the agency mission. o Protect resources against loss due to waste, abuse, mismanagement, errors, and
fraud. o Ensure adherence to laws, regulations, and standards for the implementation of
conservation programs contracts. o Develop, improve, and maintain timely accurate financial and administrative data.
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POLICY State Quality Assurance Plan
o By September 30 of each year, the State Conservationists (STC) will develop a state quality assurance plan for implementation in the coming fiscal year. The plan must identify and address state quality assurance processes, quality control issues, and producer compliance activities and specify offices, field offices, counties, and practices to be spot checked during the upcoming year. Iowa should use the latest available risk assessment as input into the state quality assurance plan.
o By January 31 of each year, the STC must submit a state quality assurance summary of the results of the previous fiscal year’s review. The summary will be submitted to their respective Regional Conservationist and the director of compliance. A standardized template provided by Strategic Planning and Accountability will be used to ensure consistency throughout the agency.
State Quality Assurance Reviews
o Iowa will conduct state quality assurance reviews of at least 5 percent of offices in the state each fiscal year.
o Offices to be reviewed will be identified by the first quarter of the current fiscal year.
o The team leader and team members will be selected by the end of the first quarter of the current fiscal year.
o Offices selected for review will be notified during the first quarter of the current fiscal year.
o All offices selected for review will be scheduled by the end of the first quarter of the current fiscal year.
o Recommendations for corrective actions must be completed within 1 year of completion of the review.
o The team leader will provide the STC and the appropriate line officers, a written report within 30 days of the review.
o The designated conservationist has 30 days to respond to the agreed upon corrective action plan. The designated conservationist’s supervisor and the designated conservationist will prepare and agree to a plan for corrective action. The plan will include a schedule for completing corrective actions and submitting quarterly reports. A copy of the report will be provided to the STC.
o NHQ must review each state on a 5-year basis to ensure that states are following policy, processes, and procedures in conducting state quality assurance reviews.
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RESPONSIBILITIES The Regional Conservationist is responsible for:
o Oversight of state quality assurance review processes. o Providing monitoring to address results from the quality assurance reviews,
audits, risk assessments, and evaluations to appropriate staff for corrective actions.
o Correcting and addressing findings, deficiencies, risks, vulnerabilities, fraud, waste, and abuse revealed by audits, reviews, assessments, or evaluations.
The STC is responsible for: o Ensuring program accountability and fund integrity. o Ensuring quality and integrity of technical assistance within the state. o Tracking corrective actions or identified problems. o Requesting functional reviews, if necessary, from the Regional Conservationist
and Director of Compliance, Strategic Planning and Accountability, if significant quality problems occur.
o Providing a year-end state quality assurance report to their Regional Conservationist and the Director of Compliance.
State Leadership Team responsibilities: o The ASTC-M&S facilitates the development, updating and implementation of the
state quality assurance plan. o Leadership Team members are responsible for implementation and follow-up
within their areas of responsibility. NRCS employees and partners assisting with NRCS work have a responsibility for:
o Ensuring quality in NRCS activities. o Providing input to improve delivery, productivity, and services. o Completing corrective actions resulting from appraisals and reviews.
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5 GUIDELINES FOR AREA AND FIELD OFFICE QUALITY
ASSURANCE REVIEWS
IMPLEMENTATION Each Iowa field office and area office will be reviewed at a minimum of every 5 years
(Table 1). The field office review will be led by the ASTC-FO with assistance from the area staff,
Partner Leadership, and ASTC-M&S staff. The ASTC-FO will communicate dates, times, and expectations of all participants. (Figure 1) The area office review will be led by the ASTC-M&S with assistance from the Leadership Team. The ASTC-M&S will communicate dates, times and expectations of all participants. (Figure 2)
The field office review will be conducted by the area quality assurance review team (Review Team), which will be comprised of a mix of specialists. This will provide an areawide perspective, as well as an opportunity for participants to communicate and share knowledge on activities being reviewed. The area office review will be conducted by the Iowa Leadership Team.
Generally, four to five field offices per area will be reviewed each year by the Area Review Team committing to three to four weeks to complete all reviews.
The LT will annually review areas of risk, previous quality assurance review (QAR) activities, and national and state priorities prior to finalizing the annual review schedule to ensure any needed adjustments or modifications are incorporated. The ASTC-M&S will keep a record of the prior year review schedules.
The review will focus on the type and quantity of work that is a representative sample of ongoing activities performed for the 12 months prior to the review. The review is not to be used for spot checks. However, spot check information from spot checks should be used to generate discussion for the QAR. The intent of the review is to focus on issues that may be systemic in nature.
Information collected during the QAR will be shared with appropriate staff at all levels. The QAR will document issues to be resolved, as well as record commendable items and processes. The results of the QAR will be assembled and distributed to facilitate the sharing of knowledge and to coordinate training to resolve any widespread deficiencies.
Synergy of the Review Team is critical. Generally, the Review Team will operate as a whole, rather than fragmented across multiple offices over the course of the week.
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The LT staff will develop standardized questions to be used in conducting the reviews in their areas of responsibility.
o The questions will be reviewed and updated annually (led by the ASTC-M&S) to ensure accuracy and relevance.
o The questions will be entered into the MS Access database (QAR Tool) for use by the Review Team.
o For the complete list of questions see the appropriate version of the QAR Tool. o Current year questions will be made available to area and field offices prior to the
beginning of the QAR season. Personnel conducting QARs are responsible for reviewing all pertinent aspects of the
work to ensure conformance with national and state policy and procedure. Any training needs identified during the QAR process will be documented and requested
through the supervisor using the Individual Development Plan. This includes training to LT, area, and field office personnel to ensure understanding of agency policies, improve technical capacity, the need for reviews of installations, and the requirements for conservation practice certification.
Generally, action items should be those that have significant effect on the operations of the offices being reviewed. Recommended actions will be discussed with the area and field office during the review process.
Administrative files relative to quality assurance will be maintained by the ASTC-M&S.
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Table 1- Projected 5 Year QAR Schedule (Year 1 = FY 2019)
Area 1 Office - Field Rotation
Year 1 Year 2 Year 3 Year 4 Year 5
Sac City. Sac Co Cherokee, Cherokee Co Sergeant Bluff, Woodbury Co Ida Grove, Ida Co Le Mars, Plymouth Co
Rockwell City, Calhoun Co Primghar, O'Brien Co Spirit Lake, Dickinson Co Denison, Crawford Co Rock Rapids, Lyon Co
Storm Lake, Buena Vista Co Carroll, Carroll Co Estherville, Emmet Co Spencer, Clay Co Sibley, Osceola Co
Pocahontas, Pocahontas Co Orange City, Sioux Co Emmetsburg, Palo Alto Co Onawa, Monona Co
Area 2 Office - Field Rotation
Year 1 Year 2 Year 3 Year 4 Year 5
Guthrie Center, Guthrie Grundy Center, Grundy Co Marshalltown, Marshall Co Algona, Kossuth Co Hampton, Franklin Co
Ankeny, Polk Co Iowa Falls, Hardin Co Nevada, Story Co Boone, Boone Co Allison, Butler Co
Masson City, Cerro Gordo Co Knoxville, Marion Co Adel, Dallas Co Humboldt, Humboldt Co Webster City, Hamilton Co
Northwood, Worth Co Clarion, Wright Co Thompson, Winnebago Co Jefferson, Greene Co Ft Dodge, Webster Co
Garner, Hancock Co Indianola, Warren Co
Area 3 Office - Field Rotation
Year 1 Year 2 Year 3 Year 4 Year 5
Toledo, Tama Co Anamosa, Jones Co Maquoketa, Jackson Co Manchester, Delaware Co Independence, Buchanan Co
West Union, Fayette Co Epworth, Dubuque Co Charles City, Floyd Co Decorah, Winneshiek Co Cresco, Howard Co
Waterloo, Black Hawk Co Waukon, Allamakee Co New Hampton, Chickasaw Co Vinton, Benton Co Osage, Mitchell Co
Waverly, Bremer Co Elkader, Clayton Co Marion, Linn Co
Area 4 Office - Field Rotation
Year 1 Year 2 Year 3 Year 4 Year 5
Chariton, Lucas Co Audubon, Audubon Co Osceola, Clarke Co Winterset, Madison Co Harlan, Shelby Co
Corydon, Wayne Co Atlantic, Cass Co Leon, Decatur Co Malvern, Mills Co Oakland, East Pottawattamie Co
Red Oak, Montgomery Co Creston, Union Co Corning, Adams Co Sidney, Fremont Co Logan, Harrison Co
Clarinda, Page Co Mt Ayr, Ringgold Co Bedford, Taylor Co Greenfield, Adair Co Council Bluffs, West Pottawattamie Co
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Area 5 Office - Field Rotation
Year 1 Year 2 Year 3 Year 4 Year 5
Malcom, Poweshiek Co Burlington, Des Moines Co Albia, Monroe Co Mount Pleasant, Henry Co DeWitt, Clinton Co
Oskaloosa, Mahaska Co Donnellson, Lee Co Bloomfield, Davis Co Sigourney, Keokuk Co Davenport, Scott Co
Williamsburg, Iowa Co Washington, Washington Co Centerville, Appanoose Co Fairfield, Jefferson Co Iowa City, Johnson Co
Wapello, Louisa Co Ottumwa, Wapello Co Muscatine, Muscatine Co
Keosauqua, Van Buren Co Tipton, Cedar Co
State Office - Area Rotation
Year 1 Year 2 Year 3 Year 4 Year 5
Area 4 Area 5 Area 1 Area 2 Area 3
Figure 1- Example Field Office QAR Schedule
Day 1
o 8:00‐8:30 AM Travel to Office.
o 8:30‐9:00 AM Opening discussions and expectations. ASTC‐FO will explain purpose
of QAR and set the direction for the week.
o 9:00‐9:30 AM County Presentation by DC.
o 9:30‐4:00 PM Review Team meets with staff, documents responses to
questions.
Day 2
o 8:30‐11:30 AM Review team carpools to field sites with field staff.
o 1:00‐3:00 PM QAR Closeout.
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FIELD OFFICE QUALITY ASSURANCE REVIEWS (TO BE COMPLETED BY
AREA OFFICE (REVIEW TEAM) All members of the field office staff including DC, SC, SCT, etc. along with all partner
staff will be involved in the review. The ASTC-M&S (or staff) will participate in the review by accompanying the ASTC-FO
and Review Team. QAR documents will be maintained at the field office until the next QAR is completed. The Review Team will evaluate the efficiency and effectiveness of the field level
technical and financial assistance delivery both in the office and in the field. The Review Team may meet with customers and conservation partners to discuss field
level service and programs. Members of the Review Team are responsible for completing the questions in the QAR
Tool and any other narrative associated with the review as assigned by the ASTC-FO. A draft report will be provided to the ASTC-M&S as part of the review closeout with the final report made available within 10 business days. All members of the LT will receive the final report to highlight innovative methods being utilized in the field and to initiate improvements throughout the state, if needed.
All items needing corrective action will be documented in the final report, following agreement by the Review Team and the ASTC-FO for the actions required and due dates. All items needing corrective action will be completed by the identified person with responsibility for follow-up assigned to the appropriate ASTC-FO.
Within 30 days of receiving the final review report, the ASTC-FO will develop and submit to the STC, with a copy to the ASTC-M&S, a report with the status of all corrective actions. Quarterly reports will be submitted until all actions are completed with the expectation of closing the review within 6 to 9 months. Upon receipt and review of the final report, the STC will provide a written letter indicating that all agreed-to-items are completed, and the review is closed.
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Figure 2- Example Area Office QAR Schedule
AREA OFFICE QUALITY ASSURANCE REVIEWS (TO BE COMPLETED BY IOWA
LT REVIEW TEAM) All members of the area staff including the ASTC-FO, ARC, AE, Program Specialists,
and Specialists etc. will be involved in the review. Area offices will have a follow-up visit by the ASTC-M&S within the fiscal year
following the QAR to ensure agreed-to-items have been addressed. QAR documents will be maintained at the area office until the next QAR is completed. The Review Team will evaluate the efficiency and effectiveness of the Area level
technical and financial assistance delivery both in the office and in the field. The Review Team will meet with appropriate field staff and conservation partners to
discuss Area level service and programs. Members of the Review Team are responsible for completing the questions in the QAR
Tool and any other narrative associated with the review as assigned by the ASTC-M&S. A draft report will be provided to the ASTC-M&S as part of the review closeout with the final report made available within 10 business days. All members of the LT will receive the final report to highlight innovative methods being utilized in the field and also to initiate improvements throughout the state, if needed.
Day 1
o 7:30‐8:30 AM Travel to Office.
o 8:30‐9:00 AM Opening discussions and expectations. STC and ASTC‐M&S will
explain purpose of QAR and set the direction for the week.
o 9:00‐9:30 AM Presentation by ASTC‐FO.
o 9:30‐4:00 PM LT (Review Team) meets with staff, documents responses
to questions.
Day 2
o 8:30‐4:00 PM LT (Review Team) meets with staff, documents responses to
questions.
Day 3
o 8:00‐12:00 PM QAR Closeout.
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All items needing corrective action will be documented in the final report, following agreement by the Review Team and the ASTC-M&S for the actions required and due dates. All items needing corrective action will be completed by the identified person with responsibility for follow-up assigned to the ASTC-M&S.
Within 30 days of receiving the final review report, the ASTC-FO will develop and submit to the STC, with a copy to the ASTC-M&S, a report with the status of all corrective actions. Quarterly reports will be submitted until all actions are completed with the expectation of closing the review within 6 to 9 months. Upon receipt and review of the final report, the STC will provide a written letter indicating that all agreed-to items are completed, and the review is closed.
6 SPOT CHECKS
INTRODUCTION Each office that certifies conservation practices must be spot checked based on the state
quality assurance plan and should be checked at least every 3 years. Spot checks (technical evaluations) of installed practices will be performed in compliance
with national policy Title 450, General Manual, Part 407, Subpart C. Spot Checks are completed outside of the QAR process, but are used for discussion
during QARs. Spot checks may be used as an opportunity for employees to request and obtain JAA. Spot checks of completed practices or practice components must be completed by NRCS
employees with applicable approval authority for the practices. The must be performed in compliance with Title 450, General Manual, Part 407, Subpart C, Section 407.20D.
PERSONNEL
KEY ROLES AND RESPONSIBILITIES
o ASTC-M&S Member of the Spot Check Cadre. Provides close-out letters for completed spot check corrective action plans as
appropriate. Maintains overall spot check documentation for the state.
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o SRC
Member of the Spot Check Cadre. Provides EcoSci staff to participate on Spot Check Teams. Leads supplemental state office Spot Check Team when warranted. Develops spot check practice list with SCE. Issues the final spot check report(s). Summarizes and recommends policy changes to LT based on results of spot
checking. Maintains records to track practices and employees spot checked in the
current and past two fiscal years.
o SCE Member of the Spot Check Cadre. Provides engineering staff to participate on Spot Check Teams. Leads supplemental state office Spot Check Team when warranted. Develops spot check practice list with SRC. Reviews and edits final spot check report(s). Summarizes and recommends policy changes to LT based on results of spot
checking.
o ASTC-FO Selects area and field office staff to participate on the area Spot Check Team. Responds to identified follow-up actions after a spot check. Meets with visiting Spot Check Team at conclusion of spot checks. Maintains spot check documentation for their area.
o State Office Staff
Potential members of a Spot Check Team.
o ARC Co-leads (with AE) Area Spot Check Team. Reviews spot check practice list. Suggests modification to spot check practice list to SRC if warranted. Ensures the work of TSPs and contractors is adequately represented on the
spot check practice list. Conducts annual spot check of high-frequency, low-risk practices in their area
(internal spot checks).
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o AE Co-leads (with ARC) Area Spot Check Team. Conducts annual spot check of high-frequency, low-risk practices in their area
(internal spot checks).
o DC and Field Office Planners Potential members of a spot check team. Assists Spot Check Team to locate files and to provide sufficient office work
space. Arranges site visits as requested by Spot Check Team. Meets with the Spot Check Team at the conclusion of spot checks in their
county. Maintains spot check documentation specific to their field office.
SPOT CHECK CADRE AND SPOT CHECK TEAMS
o The Iowa Spot Check Cadre is composed of the ASTC-M&S, SRC, and SCE. The Cadre provides overall leadership in completing spot checks.
o Spot Check Teams are created annually by each ASTC-FO to represent their Area in conducting external spot checks of another basin. Spot Check Teams include: ARC and AE, who serve as co-leaders of the team Field office planner Field engineer State office staff Additional planners or engineers if warranted Supplemental assistance from the SRC and/or SCE via a state office Spot
Check Team if warranted
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SPOT CHECK PRACTICE LISTS
PRACTICE RISK
o Low risk practices: Meet none of the criteria for high risk practices shown below. Are typically applied at a high frequency within an area.
o High risk practices meet one or more of the following criteria: Pose a greater risk to life, property or the environment compared to other
practices. Have a high level of design complexity. Have high installation costs compared to other practices. Require peer review or fall within Job Class IV or V. JAA has been granted to only a few employees within the state.
o High risk practices include but are not limited to: - 309 – Agrichemical Handling Facility - 313 – Waste Storage Facility - 316 – Animal Mortality Facility - 317 – Composting Facility - 356 – Dike (Hazard Class III) - 367 – Roof and Covers - 378 – Pond - 396 – Fish Passage - 436 – Irrigation Reservoir - 521 – Pond Sealing - 578 – Stream Crossing (Bridges) - 580 – Streambank and Shoreline Protection - 338 – Prescribed Burning - 654 – Road/Trail/Landing Closure Treatment - 395 – Stream Habitat Improvement and Management - 396 – Aquatic Organism Passage - 657 – Wetland Restoration - 658 – Wetland Creation - 659 – Wetland Enhancement
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PRACTICES TO CHECK (STATE-WIDE CRITERIA)
o Practices, installations and enhancements: A “practice” is a specific treatment for which standards and specifications
have been developed and listed in the Field Office Technical Guide. For example, Cover Crop is a practice.
A “practice installation” is one NRCS-approved practice installed in one field. For example, a farm that installs Cover Crop on five fields will be calculated as having five Cover Crop practice installations.
All cost-share and non-cost-share practices (structural, vegetative, or management) for all programs are subject to spot checking.
Conservation Stewardship Program (CStP) practices and enhancements will not be spot checked via the process described in section 6.4.
o Spot checks of completed conservation practices or practice components must be completed by NRCS employees with applicable approval authority for the practices Spot check 5 percent of the total practices installed or reported in the State. In
States where a practice exceeds 400 occurrences, only 20 installations of that practice need to be checked. It should not be necessary to check more than three to five low risk practice installations in an office, field office or county.
o For practices with over 400 installations in the state, only 20 installations need to be checked.
GENERATING AREA PRACTICE LISTS
o The SRC and SCE will generate five spot check practice lists, one for each area, based on PRS data for the current fiscal year.
o Criteria for generating area lists: Each field office is checked every year. Each planner is checked at least every 3 years and preferably every year. Each low risk practice in an area is spot checked at least every 3 years and
preferably every year. At least 5 percent of the installations of each high-risk practice in each area
are checked every year. No more than five installations of any one practice will be checked per client.
o The SRC and SCE may expand the practice list as necessary based on previously noted deficiencies. The expanded list may be extended to include practice installations completed in previous years.
o Although policy allows some flexibility in generating practice lists the goal is to keep spot checking simple and equitable. Unless warranted by situations demanding special attention (for example: previously noted deficiencies), the SRC will generate each area list to include 5 percent of the total practice installations in that basin.
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o Example: An area installs both high risk and low risk practices. Each practice has 100 installations. The SRC will attempt to generate the area’s spot check list to include: Five installations of each low risk practice (100 x 5 percent). Five installations of each high-risk practice (100 x 5 percent). In no cases, however, will less than 5 percent of an area’s high-risk practice
installations be checked. In this example, each of the high-risk practices will have at least five installations checked.
PRACTICE LIST REVIEW AND MODIFICATION
o The ARC in each area shall review the list of practices to be checked in their area. o The ARC may request that the SRC modify the list to ensure:
All cost-shared practice installations on farms NRCS employees own or have an interest in are spot checked in the year the practice installation is certified.
Previously noted deficiencies are addressed by an appropriate number of spot checks. This may include expanding the practice list to include practice installations completed in previous years.
Selected practice installations are actual practices (not data errors) and are reasonably accessible for checking.
Technical Service Providers and contractors acting in an authorized contractor-certification process are included in the practice list as per the policy in Section 6.3.5.
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TECHNICAL SERVICE PROVIDERS AND CONTRACTORS
o Technical Service Providers (TSP): Conservation Activity Plans (CAP) written by TSP and practices designed,
installed or certified by TSP acting in the official capacity of a TSP shall be spot checked as per Title 450, General Manual, Part 407.
No fewer than the first two plans or practices completed by a TSP will be spot checked.
Individuals or entities certified as TSP often provide consulting services that are not official TSP projects. A TSP is not subject to spot checking for these consultations. Example:
- A TSP is certified to write CNMP CAPs (practice code 102). This TSP also provides consultation to farmers on Nutrient Management (practice code 590) via contracts that do not include TSP funding for the design, implementation and certification of practice code 590.
- The TSP is subject to spot checks on practice code 102 but is not subject to spot checks on practice code 590 unless the contract includes contract line items with funding to hire a TSP to design, install and/or certify the Nutrient Management practice.
- Planning, designing and certifying practice code 590 in this example is the responsibility of NRCS or partner staff with appropriate Job Approval Authority. The TSP may help the client implement practice code 590 and may provide information about the installation to NRCS, but the NRCS or partner staff who plan, design and certify this practice shall be spot-checked rather than the TSP.
Spot checks will be performed for at least five percent of TSP implemented conservation plans and practices annually.
The SRC and SCE share responsibility in identifying TSP practices. The SRC, SCE, and ASTC-FO’s will ensure that the sample of an individual
TSP’s work is a representative cross section by geographic area, size of projects and complexity of projects.
o Contractors: Contractor-certified practices shall be spot checked as per Title 450, General
Manual, Part 407. Spot check will occur on five percent of contractor certifications. Complete construction checks and checks of the documentation furnished by
the contractor, including approved drawings and specifications, should be made on one or more jobs installed by each contractor during the year.
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CONDUCTING SPOT CHECKS
PREPARATION
o Under the guidance of the SRC, SCE, and ASTC-FO the Spot Check Cadre and Spot Check Team leaders (ARC’s and AE’s) meet annually (either in person or via teleconference). Spot Check Team members are encouraged to participate in this meeting. Topics discussed at this meeting include: Current year spot check schedule. (Figure 2) Forms, spreadsheets, databases to use. Guidelines in conducting spot checks to ensure uniformity across basin lines. Questions and answers by team members.
o ARC’s, AE’s and DC’s work with Spot Check Teams to finalize a schedule for which Spot Check Team members will be in which field office on which days.
o DC’s arrange for adequate office/meeting space for Spot Check Teams. o DC’s arrange for site visits to allow Spot Check Teams to view completed practices
in the field and, when possible, to meet clients who applied the practices. o Spot Check Teams will accommodate, as much as possible, requests from DC’s,
ARC’s and AE’s to minimize disruption to ongoing work activities and client schedules.
IMPLEMENTATION
o Spot checks will include site visits when appropriate and feasible. For example, it is appropriate to conduct a site visit for a Waste Storage Facility practice to ensure it was installed according to standards and is functioning properly. It is not necessary to visit a site where Cover Crop was applied the previous fall and no signs of the practice are visible when spot checks occur.
o Spot Check Teams will document results for both internal and external spot checks on the most current version of the Conservation Practice Spot Check Report form.
o If in the course of conducting a spot check, waste, fraud, or abuse is suspected, the spot check for that practice will be suspended immediately and the incident reported Title 440, Conservation Programs Manual (CPM), Part 504, Subpart H, “Technical Assistance Waste, Fraud, and Abuse.” Assistance and additional guidance may be needed from programs staff where projects may have resulted in improper financial assistance payment.
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CLOSEOUT, CORRECTIVE ACTIONS AND RECORDS
o After field office spot checks are completed the Spot Check team will review commendable items, deficiencies, and comments with the DC and ASTC-FO.
o By November 30: The ASTC-FO contacts the Spot Check Cadre regarding any disputed
deficiencies. The Spot Check Cadre decides whether disputed deficiencies stand or are
modified/deleted. The ASTC-FO ensures a corrective action is entered for each deficiency.
o By December 31: The Spot Check Cadre reviews corrective actions for each area. The Cadre
may accept corrective actions or request that the ASTC-FO modifies corrective actions.
SRC and SCE issue final spot check reports for the areas and state. The SRC and SCE have joint responsibility for summarizing reports and
providing recommendations to the LT for policy changes or training needs. o By March 30:
ASTC-FO submits a letter to the Spot Check Cadre indicating the status of corrective actions.
o By June 30: All corrective actions implemented. ASTC-FO submits a letter to the Spot Check Cadre indicating that all action
items are completed. o Records of spot check reports and correspondence are filed under code 450 in
accordance with the records management system (Title 120, General Manual, Part 408): DC maintains documentation specific to their field office. ASTC-FO maintains spot check documentation specific to their Area. The SRC maintains a spreadsheet such as shown in to track practices and
employees reviewed in the current and past two fiscal years in each office. ASTC-M&S maintains overall spot check documentation for NRCS Iowa.
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SPOT CHECK TIMELINE
Table 2- Spot check timeline (summary)
Deadlines Tasks May 15 ASTC-FO selects Spot Check Teams and notifies Spot Check Cadre.
May 15 SRC and SCE identify state office staff to serve on Spot Check Teams.
June 30 Spot Check Cadre, ARC’s, AE’s meet. Spot Check Team members participate with supervisor approval.
Sept. 1 SRC or SCE downloads PRS data for spot check practice list development.
Sept. 7 SRC sends spot check practice lists to ARCs.
Sept. 15 ARC and AE suggest practice list modifications to SRC. Practice list finalized.
Sept.-Oct. Spot Checks are completed.
Nov. 30 ASTC-FO ensures each deficiency has a corrective action approved by Cadre.
Dec. 31 SRC and SCE issue final spot check reports.
March 30 ASTC-FO informs Cadre of progress on implementing corrective actions.
June 30 All corrective actions implemented. ASTC-FO informs Cadre of status.
7 ONGOING QUALITY ASSURANCE EFFORTS
PRE-OBLIGATION REVIEW Planners will use an approved program-specific checklist to review each Environmental Quality
Incentives Program (EQIP) contract prior to submitting to the APS. The APS will then use the same checklist to review each EQIP contract prior to submitting to the ASTC-FO for obligation. All EQIP contracts must undergo a pre-obligation review.
The ARC will complete a technical review of at least three contracts or five percent of approved contracts, whichever is greater, per field office using the approved program-specific checklist for the Environmental Quality Incentives Program (EQIP). This second-level review is in addition to the planner and APS reviews described above.
ANNUAL CSP QUALITY ASSURANCE REVIEW NHQ will identify 10 percent of randomly selected CStP contracts to be reviewed annually.
7.3 QUARTERLY CERTIFICATIONS NHQ will provide quarterly guidance related to ProTracts and zRoles certifications. Open obligation reviews will be conducted via ROOT as directed by NHQ with coordination
from the ASTC-M&S and ASTC-P.
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8 CIVIL RIGHTS REVIEWS
Field Office Civil Rights Compliance Reviews and the Service Center/Field Office American with Disabilities Act (ADA) Reviews will be conducted by Area Office staff.
A member(s) of the Iowa Civil Rights Committee or Advisor will accompany the Review Team to complete the Civil Rights and ADA reviews.
9 CONSERVATION COMPLIANCE
INTRODUCTION The State Quality Assurance Plan for Food Security Act Compliance is based upon requirements in Parts 518 through 520 of the 1985 National Food Security Act Manual, as amended. Wetland Conservation Compliance is specifically based on Part 510, Subpart C, Section 510.21 B and D, Part 514, Subpart A, Section 514.1 E, and Part 519, Subpart A, Section 519.0 D which describe agency responsibilities for quality control procedures. Detailed QAR guidance will be provided by the ASTC-C.
QAR processes for conservation compliance will answer two distinct questions:
Are field staff correctly and consistently completing Food Security Act Compliance Status Reviews?
Are field staff correctly and consistently completing HELWC determinations?
FOOD SECURITY ACT COMPLIANCE STATUS REVIEWS National Headquarters directs states to complete annual Food Security Act Compliance Status Reviews to ensure that clients receiving commodity payments are implementing and maintaining conservation practices. The ASTC-Compliance coordinates the Area level staff who conduct the reviews. To ensure that field staff are correctly and consistently completing these Status Reviews, second level quality assurance is completed annually as follows:
ARCs are responsible for conducting second level quality assurance of Food Security Act Compliance Status Reviews each year.
Each ARC will review a minimum of five percent of the Food Security Act Compliance Status Reviews randomly checked by the field level staff.
When second level quality assurance is completed on a tract the ARC will select “Yes” to the question “Review part of Quality Assurance Plan?” in Part G of the reporting page in the FSA Compliance Reviews portion of the online Integrated Accounting System.
Second level quality assurance will be completed by December 1st.
