United States Department of the Interior NATIONAL PARK SERVICE

1849 C Street, N.W. Washington, D.C. 20240

IN REPLY REFER TO:

Memorandum

To: Regional Chiefs of Concessions

From: Chief, Commercial Services Progra~ ~ Subject: Implementation of Updated Program Standards and New Annual Overall Rating (AOR)

The W ASO Commercial Services Program is launching a major upgrade to the Concession Review Program as part of the Standards Evaluation and Rate Administration (SERA) Project.

With this memorandum, the Service is issuing: • revised standards for concession risk management; • new standards for concession environmental management; • revised methods and forms for concession administrative compliance, environmental

management and risk management evaluations; • a new concession asset management evaluation and form; and • an updated concession Annual Overall Rating (AOR) procedure and form for 1998 Law

contracts

Updated risk and environmental management standards and updated guidance on administrative compliance, asset management and public health evaluations for can be found on the Commercial Services SharePoint site in the Program Policy Library under the Principle Topic Standards and Evaluations. The updated annual evaluation forms have been compiled into a single AOR Excel workbook which can be found in the Contract Management Toolbox under Concession Review Program under Category: Annual Overall Rating.

BACKGROUND

The Concession Review Program performance standards and evaluation processes were established over 30 years ago and are documented in NPS 48. Over the years, minor adjustments were made to these processes but there was no comprehensive effort to upgrade them. The NPS is executing the SERA Project to review these processes and make improvements. Key improvement goals are to:

• increase consistency with industry practices; • update to reflect current NPS requirements; • reduce subjectivity and increase consistency in evaluation results; • provide a broader range of ratings for concessioner performance including a superior; and • streamline and use current technologies.

The NPS contracted with hospitality consultants, worked with NPS concession management field staff, and interacted with concessioners through meetings and field pilots to improve the Concession Review Program.

IMPLEMENTATION

Implementation under this memorandum consists of three key components: 1) implementing updated "program" standards and evaluation processes; 2) implementing an updated operational performance evaluation process; and; and 3) implementing the updated AOR. Implementation of these Concession Review Program changes will begin in 2016. Proactive parks and concessioners are authorized to pilot the updated materials for the AOR due on April 1, 2016 if the park and concessioner mutually agree. Details on all Concession Review Program updates and how to implement the updates in each area are provided in Attachment A.

A fourth component of the Concessioner Review Program is the updating individual visitor service standards and evaluations (i.e., periodic evaluations for services such as lodging, food and beverage, etc.). Promulgation and implementation of these updates will be addressed under separate memorandum to be issued later this year.

SUPERCESSIONS

Concession Review Program changes being implemented through this memorandum that consist of changes to specific program standards (i.e., risk management), evaluation procedures, and evaluation forms replace those in NPS-48 Chapter 19, Concessioner Review Program, Ch_apter 20, Concessioner Review Program - Operational Performance, Chapter 22 - Contract Permit Compliance, NPS-48, and Chapter 34 - Risk Management Program (Revised).

General policies on the Concession Review Program such as authorities, policy, responsibilities, distribution of reports, and appeal processes contained in NPS 48 are not superseded. NPS 48 will be replaced by Reference Manual (RM) 48. All Concessioner Review Program changes will be integrated into RM 48.

1965 ACT CONTRACTS

The updated AOR workbook in its current format should be used for evaluating 1998 Law Contracts. An updated workbook that addresses 1965 Act Law contracts will be issued in December 2015.

NEXT STEPS

As parks implement these changes, W ASO Commercial Services will continue to provide ongoing training and awareness to NPS Commercial Services employees and concessioners. This will include a number of Commercial Services Chats for NPS concession managers and webinars for concessioners in the Fall 2015 and early 2016. Assistance will also be available to parks through the WASO Technical Assistance Program.

It is anticipated that there will be minor adjustments needed as the updated standards and evaluation rating systems and tools are implemented in the field. Throughout the first two years of implementation(i.e., 2016 and 2017), WASO Commercial Services will collect comments from park and region personnel and concessioners and will make adjustments where appropriate to Concession Review Program components to ensure the program works as effectively as possible.

DISTRIBUTION

Please distribute this memorandum to all parks with concession operations. Managers are also encouraged to share the memorandum and updated materials with their concessioners.

FOR FURTHER INFORMATION

For further information on these SERA updates, please contact Kat Berry at 202.513.7153 or Kurt Rausch at 202.513. 7202 in the WASO Commercial Services Program.

ATTACHEMENT A

SUMMARY OF CONCESSION REVIEW PROGRAM CHANGES AND STEPS FOR IMPLEMENTATION

Changes to the Concession Review Program components are outlined in Table 1 below. Details are provided in the Concession Review Program forms instructions.

TABLE 1 SUMMARY OF CONCESSION REVIEW PROGRAM CHANGES

Program Standards and Evaluations

Administrative Compliance Review

Risk Management Program (RMP) Review

Environmental Management Program (EMP) Review

A-2

This review (formerly titled "10-630 Contract Compliance") assesses items such as timely and accurate payment of franchise fees, maintaining required insurance, and other contract requirements.

Through the SERA Project, existing review criteria were assessed and minor revisions were made to enhance clarity in the evaluation criteria (i.e., questions). In addition, several elements were added to account for recent program requirements (e.g., contract transition, social media). Scoring was converted from a more subjective determination to a simplified Oto 100 formula based on the percent of standards achieved. A "superior" rating range was established. Form 10-630 was converted to an electronic form in a new Excel-based AOR Workbook, and was retitled 10-ADM. Concessioners are required to develop and implement an RMP to provide a safe environment for employees, visitors and NPS personnel. Risk management standards and evaluation methods to assess concessioner performance were developed in the mid-80s and included in NPS-48 under the title Loss Control Program. They were updated and retitled risk management in 1998.

The requirement for superintendents to define mandatory A, and optional Band C elements for concessioner RMPs in the Operating Plan was removed as it was found to be difficult to understand for both parks and concessioners and was inconsistently applied. Under the revised system, a core set of fundamental RMP standards are now required for all contracts without any 'optional' components. The scope of these requirements can be further defined by the park to address the size and complexity of the concession operation and park-specific procedures through additions to the contract operating plan. The risk management evaluation form, Form 10-628, was revised to reflect the updated standards. Ratings were converted from a number of As, Bs and Cs approach to a simplified Oto 100 scoring formula. A "superior" rating range was established, as well as "special attention items". Form 10-628 was converted to an electronic form in the AOR Workbook and retitled 10-RMP. Under the 1998 Law, Category I and Category II contracts require concessioners to develop and implement a documented EMP. All categories of concession contracts also contain other requirements related to compliance with environmental criteria and the protection, preservation and conservation of park resources. An EMP performance review process was piloted in 2007. No formal environmental standards were developed at that time and assessment criteria focused on the documented EMP.

As part of the SERA Project effort, environmental management standards were formally developed from contract EMP requirements.. The environmental management evaluation form, Form 10-ENV, was revised to reflect these new standards. As with the RMP, ratings were converted to the simplified 0 to 100 scoring formula, and a superior rating range was established, as well as "special attention items". Form 10-ENV was converted to an electronic form in the AOR Workbook and retitled 10-EMP.

Public Health Program (PHP) Review

Asset Management Program (AMP)

Review

TABLE 1 SUMMARY OF CONCESSION REVIEW PROGRAM CHANGES (Cont.)

PHP reviews are conducted by NPS Public Health Service consultants to assess food safety and several other public-health related areas such as pools and bathhouses.

There are no substantive changes to this process. NPS PHS-developed criteria, forms, reporting, scoring and rating methods are used. The only notable change is that Form 10-622 was converted to an electronic form in the AOR Workbook and retitled 10-PHP. Asset management performance was historically recorded as a single "maintenance" element in the former Contract Compliance form. This was inadequate to reflect the actual scope, importance and level of effort of this program to both parks and concessioners.

As part of the SERA Project, a stand-alone AMP review was established. No stand-alone asset management standards were developed. Instead, evaluation criteria are defined in a new 10-AMP form that refers back to key requirements in the Contract and Maintenance Plan. Consistent with other programs, ratings are determined using a Oto 100 scoring formula with the potential to obtain a superior rating. Form 10-AMP is an electronic form in the AOR Workbook.

Visitor Service Standards and Evaluation

Visitor service standards and the periodic evaluation process, which were last revised in the mid-1980s, tend to be generalized and subjective, missing key components, and criteria were not always consistent with current industry standards.

Standards are being revised to be more current, complete, and objective. Where appropriate, the standards are being defined by service classification levels to enhance applicability. For example, lodging standards will be defined for upscale, midscale, basic and rustic property classifications. Evaluation forms are being converted to Excel-based workbooks for streamlined data entry and report generation.

Launch of these new standards and evaluation tools will be occurring in 2016. In the meantime, parks should continue to use the current service-specific periodic evaluation forms from NPS-48.

Operational Performance Review (OPR)

The operational performance rating combined program review results for the RMP and PHP with periodic evaluations results. It did not allow for the integration of the new EMP and AMP program reviews.

The operational performance review was revised so that it collates the results of visitor service-specific periodic evaluations without including any program review results (which are now addressed individually). The process was revised so that individual service ratings could be weighted based on their overall importance to the contract, providing a more accurate summary rating. The Concession Operational Performance Report, Form 10-629 was converted to an electronic form in the AOR Workbook, retitled 10-0PR, and includes a superior rating.

Annual Overall Rating (AOR)

The AOR process provided a combined summary rating based on the results of the roll-up operational performance rating and the contract compliance rating and provided a narrative report.

The organization, scoring process and AOR form are revised. Now Operational Performance, Administrative Compliance, RMP, EMP, PHP and AMP are all averaged in the AOR. Final scoring includes a superior rating range. The format for the AOR report is now an Excel Workbook. Other new AOR features include ways to track and rate performance when no services were evaluated that year and when a final rating has been changed by the Superintendent. The revised organization for the AOR is presented in Figure 1 on the following page.

Form 10-631 was converted to an electronic form in the AOR Workbook and retitled 10-AOR.

A-3

Old Periodic Evaluations

' I

Operational Performance

I Visitor Satisfaction

New

Figure 1 AOR Reorganization

Risk Management Public Health

I

i ----------------~ AO R

I Contract Compliance

I Environmental

~---------------------- Management

Risk Environmental Public Asset

Periodic Evaluations Management Management Health Management

~ Operational Performanc

I

A-4

Administrative Compliance

I +

Other Factors -------------3> AO R ~------------ Visitor Satisfaction

Table 2

STEPS FOR CONCESSION REVIEW PROGRAM IMPLEMENTATION

Updated Program Standards and Evaluation Processes and Updated AOR

Revisions to these portions of the Concession Review Program are essentially changes in evaluation methodology and do not substantially change the scope of program requirements under the concession contract. As such, these changes have been found appropriate for implementation during the term of an existing contract.

There are some minor adjustments that may be required to park documentation and concessioner operations to maximize alignment with the updated standards. One such example is the removal of the required A and optional Band C elements approach for parks to define RMP requirements. Concessioners must be given an adequate opportunity to understand any such revisions and update programs, associated documentation, and operations as necessary to reflect these changes. In addition, parks must ensure that contract documentation (e.g., Operating Plans) and their evaluation practices are updated to reflect applicable program revisions.

To provide time for this realignment, implementation of the updated program standards and new AOR process will occur in 2016. With this timeline, parks and concessioners will have time to review updates and revise programs and documentation in the Fall of 2015 and Winter of 2016, implement any program revisions during the 2016 season, conduct the first revised program reviews at the close of the 2016 season and implement the updated AOR for AORs due in April 2017.

If parks and their concessioners would like to be leaders in this AOR effort, they may proactively begin using the new Program evaluations and AOR for the 2015 operating year.

In the event that there are extenuating circumstances that will prevent a park from implementing the updates in 2016, park superintendents may request an extension until 2017 from their Regional Chief of Concessions.

Steps to execute are outlined below: Step 1 Parks download and review the updated standards and evaluation materials.

Step 2 Parks share the materials with their concessioners.

Step 3 Park concession specialists participate in Commercial Services Summer 2015 Chats on the new processes. Recordings of these past chats are available in the Chat Libra[Y.

Step 4 Concessioners voluntarily participate in informational webinars for concessioners that will be conducted by WASO Commercial Services in the Fall of 2015. Specific dates will be announced.

Step 5 Park concession specialists and concessioners meet to jointly review and discuss the updates and identify any program adjustments that are needed. Topics to discuss include Operating Plan revisions, decisions on the new weighting of services for the Operational Performance rating, and other topics that arise.

Step 6 Park concession specialists revise concessioner Operating Plans to appropriately reference the new standards and evaluation processes. Template language will be available from WASO Commercial Services. (Note that for 65 Act Contracts, Operating Plan revisions must be by mutual agreement.)

Step 7 Concessioners revise programs (e.g., EMP and RMP) as necessary to align with updated standards and evaluation criteria and submit revised programs for review and acceptance in accordance with Operating Plan reporting schedules.

Step 8 Park concession specialists review any revised documented programs (EMP and RMP) that concessioners may have updated and submitted to ensure conformance to new program standards.

Step 9 Concessioners execute the updated programs beginning in the 2016 season. Park concession specialists check in periodically with the concessioner during operations to ensure programs are on track.

Step 10 Park concession specialists complete the ADM, EMP, RMP, and AMP program reviews at the conclusion of the 2016 season and then use the new AOR workbook to complete the year-end review.

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Table 2 STEPS FOR CONCESSION REVIEW PROGRAM IMPLEMENTATION (cont.)

Visitor Service Standards and Periodic Evaluations

Updates to service standards and associated periodic evaluation forms represent a more substantial change to operating requirements for concessioners than those associated with changes to administrative compliance, program standards or the AOR.

As a result, use of the new service standards and periodic evaluation procedures will only apply for new contracts in which the updated standards have already been applied or if the contract indicates the new standards and forms are to be used once issued. Use of the updated standards and processes for these contracts can begin in 2016 and as updated standards and evaluation forms are finalized and made available by WAS Commercial Services.

For existing contracts, parks and concessioners are encouraged, but not required, to adopt the new visitor service standards and associated evaluation tools. However, because these may represent a more substantial change to contract operating requirements, any changes must be mutually agreed by both the park and the concessioner.

Additional details on the roll-out of the Service Standards and Evaluation Tools and steps for implementation will be provided in a separate memorandum later this year.

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