V. Program Requirements

A. Insurance:

• • Garage Keeper’s Liability
  • Product and Completed Operations policy.  This must be specifically named and listed as a separate coverage.  It may be contained in the general liability policy or in the Garage Keepers’ policy but must be identified specifically.  Product and Completed Operations must have limits of $1,000,000 per occurrence.  Minimum limits on these policies must be $1,000,000 aggregate and be listed on the certificate.
  • NMEDA will be named as a Certificate Holder and a copy of the certificate and all renewals must be provided to NMEDA.

BACK TO TOP

B. QAP Labeling Program:

The purpose of the QAP labeling program is to show certification from the accredited location that the modification performed was completed in accordance with the QAP and Guidelines and to track all personal use mobility vehicles modified and/or sold by QAP accredited locations. The NMEDA QAP label is to be placed on ALL personal use vehicles modified and/or sold with new and/or used mobility equipment (including pass-through vehicles). NMEDA or their representative will track the sale and use of these labels.

• 1. Ordering and Issuance of QAP Labels – The accredited location must purchase labels directly from NMEDA at a cost of $2.00 USD per label. Additional information and FAQs for the labeling policy, including the “QAP Label Decision Tree” can be found on the NMEDA website in the member document center.
     If the accredited location has any outstanding, overdue, or unpaid audit fees, invoices, or membership dues the labels will not be issued or shipped until all of these fees/invoices/dues are paid. The QAP label fee is subject to change periodically.

BACK TO TOP

C. QAP Online Administration

All accredited QAP locations are required to utilize one of the NMEDA approved QAP online applications for administering QAP. This includes Customer File, Training, Calibration, and Insurance requirements as provided herein.

BACK TO TOP

D. Customer File

The collection of specific job information, forms, and documents is called the ‘customer file’. Each job shall have a QAP Label number assigned that is correlated to the customer file for traceability. Throughout the process, an accredited location must maintain the following records in conjunction with the QAP Program. All records shall be retained for a minimum of seven years (electronic storage is acceptable) and be provided to NMEDA or the audit firm representative upon request.

 The customer file information must contain:

a. The QAP Label number assigned to the job.
b. Customer information including full name and address.
c. Vehicle information including make, model, model year, mileage, VIN, and modification information including conversion details.
d. Job details describing the work performed and all adaptive equipment installed including manufacturer name, model number, and mobility equipment category.
e. The names of the technicians who performed, and in the case of an uncertified technician, the name of the person who supervised the work.
f. Completed final inspection checklist for the activities carried out
g. Evidence that the customer was provided instruction on the use and maintenance of the adaptive equipment installed.
h. Completed Vehicle Delivery Confirmation form.
i. Additionally, if applicable and/or required by the Guidelines:

1. 1. 1. NHTSA Make Inoperative form
      2. A copy of the customer’s driver’s license*
      3. Driver (C/DRS) assessment report (prescription)*
      4. Customer Statement of Current Experience form
      5. Weight analysis
      6. Wiring diagram
      7. Out of Area Service Agreement form
      8. Evidence of test drive
      9. Evidence of final fitting

* Documents that may include sensitive information such as a driver’s license and Driver assessment reports are NOT uploaded into the QAP online application; however, these documents must be retained on file with the dealer for at least seven years and be provided to NMEDA or the audit firm representative upon request.

BACK TO TOP

E.  Evidence of Training

Manufacturer training certificates must be maintained for all individuals who perform (and/or supervise) the work defined in the job details as well as the required NMEDA Certified Technician (NCT) online trainings.

BACK TO TOP

F.  Evidence of Calibration

The accredited location must have a process in place, which ensures that only calibrated equipment/tools (such as torque wrenches, multi-meters, and four-corner scales) are accessible to the technician and that these devices are subject to calibration on a prescribed schedule. All calibrations shall be made by a company or lab certified to ISO 17025 or ANSI/NCSL Z540 and be traceable to NIST (US) or Measurements Canada.

a. Four-Corner Scales: NHTSA requires that load carrying capacity measurements are made using a scale that has an accuracy of one percent (1%) of the scale reading and that the calibration is traceable to NIST (US Scales). For Canada, scales must be traceable to Measurements Canada. The calibration interval shall be one-year (1 yr) maximum. The accredited location shall be able to provide a calibration record that shows the calibration is current and the weight used traceable to NIST or MC.

b. Torque Wrench(s): QAP requires that technicians use calibrated torque wrenches for any installation requiring a specific torque value per the guidelines or the manufacturer/OEM instructions. The calibration interval shall be as-per the manufacturer recommendation or, if not specified by the manufacturer, one-year (1 yr). The accredited location can employ a ‘per-use’ method of counting the number of cycles used, but if using this method, there shall be a documented process that is pre-approved by NMEDA. Evidence of calibration certification is required.

c. Multi-Meter: Multi-meters are not required to be calibrated for purposes of checking grounds or troubleshooting. However, if the installation instructions from the manufacturer or guidelines require the accredited location to document quantitative data for acceptance, any such measurement shall be made with a calibrated multi-meter and the accredited location shall be able to provide evidence of calibration certification.

BACK TO TOP

G.  Access to Employee and Customer Files

The accredited location agrees to permit NMEDA, or its designated agent, to inspect records pertinent to this program, including customer and employee files during normal business hours in order to verify that technicians have valid certification, and that the labeling policy is being followed.

BACK TO TOP

H.  Business Changes Requiring Notification

Any changes to the business location must be submitted to NMEDA. Changes to Calibrated Tools or Product Listing are uploaded directly to the QAP Administration Software.

BACK TO TOP

      I.  Dealer QAP Process Flow

Each accredited location follows a documented process and sequence of events that are necessary to satisfy the needs of the customer. A sample of the process flow is shown in figure 1. Note that the specifics of the docs/form names may differ in the QAP online application.

[figure 1 – process flow]

BACK TO TOP

J. Structural Vehicle Modifications:

All structural modifications shall comply with any/all applicable Guidelines and be performed using documented work instructions. The accredited location shall be able to provide (upon request) evidence of successful testing and/or engineering analysis certifying compliance to all applicable F/CMVSS.

BACK TO TOP

K. Mandatory Audits:

All QAP accredited locations are audited annually by the audit firm. The audit process and method are determined in a manner that will sufficiently assess adherence to the QAP program Rules and Guidelines.

At the completion of the audit, the audit results are sent to NMEDA headquarters for final review and disposition. A copy of the audit report is put into the accredited location’s QAP file.  The location’s QAP Contact will be advised by NMEDA of any discrepancies or findings in their audit report and notified of any corrective actions that are required to be completed to maintain QAP accreditation when necessary.

BACK TO TOP

L. Facility Specifications and Compliance Policy:

NMEDA QAP accredited locations are required to have shop facilities with the following minimum specifications:

1. 1. An indoor permanent shop service area, separate from a showroom, which has a minimum of five (5) feet (1.524 meters) of clear floor space around the perimeter of the vehicle (including any fully deployed ramp or lift) to allow the client to safely maneuver around, into, and out of the vehicle;
   2. Have a vehicle entry door of sufficient size to allow safe entry/egress of all vehicles sold and serviced.
   3. To be in compliance with the Americans with Disabilities Act (ADA).

A QAP accredited location, whose facility does not comply with the Shop Facility Specifications will be given time to comply according to the following timetable.

• • Within six months of notification that the location is out of compliance, the location will provide NMEDA with a documented plan to correct the facility according to the standard.
  • The location will then have up to twelve (12) additional months to complete the planned action(s) that will bring the facility into compliance with the standard.
  • Failure to comply with this policy will result in an immediate suspension from QAP until the policy is adhered to by submitting a facility compliance plan to NMEDA and/or correcting the physical building structure.

BACK TO TOP

M. Equipment Requirements:

NMEDA QAP accredited locations shall have all the equipment and tools necessary to comply with the manufacturer’s installation instructions. The equipment type/model used shall be capable (appropriate range, precision, and unit of measure) of achieving the specification given in the instructions or standard. At a minimum, each accredited location shall have the following equipment:

• • Four-Corner scales (calibrated**)
  • Multi-meter¹ (used for continuity and electrical measurements, ohms and volts)
  • Floor jack and jack stands, or vehicle hoist
  • Crimping tools of appropriate type for connectors used in the shop
  • Air compressor and air tools or appropriate corded/cordless tools
  • Torque wrench(s) (calibrated**)

**See “Evidence of Calibration” section for specific requirements
¹ – if the multi-meter is used for any quantitative acceptance data, it must be calibrated

BACK TO TOP

N. 24/7 Emergency Service:

NMEDA QAP accredited locations must have a system in place that allows customers easy access to an after-hours answering service, or service telephone number.  Accredited locations must respond to a service call within 30 minutes and provide emergency assistance as warranted.

The service person responding is expected to:

1. 1. Respond within 30 minutes to a service call.
   2. Verify that the situation is not life threatening.
   3. Confirm whether the problem is related to the conversion.
   4. Attempt to talk the customer through a corrective action/emergency backup procedure.
   5. Confirm that the customer has completed the necessary corrective action and can safely get home and advise the customer to call again with any other problems.

NOTE: If the customer cannot complete the corrective action, the accredited location is expected to advise the customer that a service person will be dispatched.

If a service person must be dispatched for a road call, the service person is required to:

1. 1. confirm that the customer is in a safe location, and confirm any directions needed to find the customer.
   2. inform the customer that the emergency service will likely be a temporary repair, intended only to get the customer safely home. Therefore, a subsequent service appointment must be scheduled during normal service hours.
   3. confirm their approximate arrival time.
   4. confirm the approximate cost of the service call (if the service is not covered under warranty).

BACK TO TOP

O.  Out of Area Service Requirements:

All vehicles outfitted with new warrantied mobility products for use by individuals with disabilities that are delivered to a customer whose primary residence is out of the seller’s service area must have a service agreement in place. The Out of Area Service Agreement Form (QAP-F33) is completed in one of the following ways:

• • • The client agrees to have the service provided by the seller, regardless of the distance to the location (complete Out of Area Service Agreement Part A)
    • The seller makes arrangements with another QAP accredited location in the client’s local area who is certified to perform the service (complete Service Agreement Part B)
    • If there are no qualified QAP accredited locations in the client’s local service area, or no QAP accredited locations in the area willing to perform the service, a waiver of the service requirement is necessary. See section “Customer Waiver of Service Area Requirement” and complete Out of Area Service Agreement Part C.

A service area is defined as an area within 100 miles (160 km) or 2 hours drive time (whichever is shorter in the best judgment of the selling accredited location) from which a location can reasonably service customers to the level of service expected of a QAP compliant location.  The servicing QAP accredited location is required to have technicians certified to service the mobility products installed by the selling accredited location.

The definition of this proximity assumes that customers who purchase a vehicle, adaptive equipment, or both, will drive the distance for repairs to a QAP accredited location, and ensures that 24/7 emergency service can be administered on behalf of the customer in a reasonable and timely manner.

Customer Waiver of QAP Service Area Requirement:

1. 1. If there is no QAP accredited service location within 100 miles (160 km) or 2 hours drive time from the customer’s place of residence, and the customer does not want to have the selling dealer service the vehicle, complete section C (1) of the Out of Area Service Agreement Form.
   2. If there is an accredited location in the service area but they do not have technicians qualified to perform the work, complete section C (2) of the Out of Area Service Agreement Form.
   3. If the selling accredited location has called at least four (4), or all of the lesser number available, of the QAP accredited locations within 100 miles (160 km) or 2 hours drive time from the customers place of residence and none of the locations are willing to service the customer, complete section C (3) of the Out of Area Service Agreement Form.

Misrepresentation of Service Availability:

Without first establishing written service agreements, no QAP location shall state or imply to a client or potential customer that following a sale, ANY location can or will provide service to the vehicle or adaptive equipment package.

Final Delivery and Acceptance Requirements:

The accredited location shall provide training, demonstration, and documentation of final delivery as per Guidelines 4.5.3 and 4.5.4.

BACK TO TOP

P. QAP Contact:

A QAP Contact (Primary) shall be assigned for each accredited location. The QAP Contact shall complete and maintain all required QAP training as defined under Required Training. The QAP Contact must be employed at the location and shall be the main point of contact within the organization that all QAP relevant information flows through (from NMEDA, audit firm, etc.). The QAP Contact’s name, phone number, and email address shall be provided to NMEDA and listed in the accredited location’s NMEDA member portal. It is the accredited location’s responsibility to assure the NMEDA member portal information is accurate and up to date.

The QAP Contact has the responsibility to receive inbound information and disseminate the information, as appropriate, to the accredited location’s internal workforce. The QAP Contact will be the main point of contact for audit scheduling, corrective actions, email notifications, and any other pertinent information. The QAP Contact shall host or be available during all audits. NMEDA shall be notified immediately if there is any change to the QAP Contact.

The accredited location may opt to assign a Secondary QAP Contact in the NMEDA database. The Secondary is a backup to the Primary and is copied on, but not responsible for, all correspondence and actions.

BACK TO TOP

Q. Final Inspection:

All final inspections performed by the accredited location shall be accomplished by an employee (herein known as the ‘inspector’). The inspector shall be a person other than the technician who installed, serviced, or modified the mobility equipment shown in the job details. The inspector, as a minimum, shall have: (a) current certification from the mobility equipment manufacturer(s), or (b) current NMEDA QAP training.

BACK TO TOP

R. Required Training:

1.  NMEDA Certified Technician (NCT): All accredited locations shall have at least one NMEDA Certified Technician on staff. Recertification is required every two years. Details of the program, its requirements, and how to become certified can be found in the dealer education section of the NMEDA website. In the event that an accredited location’s NCT is no longer employed with the company, the location will be given up to six (6) months from the date of employment termination to certify a new NCT on staff. The NCT requirement does not exempt any Manufacturer or NMEDA required training.

2. QAP Primary Contact Training: The QAP Primary Contact is required to complete QAP training. Recertification is required every two years.

3. Technician Training: Technicians are required to be certified for all mobility equipment they install and service.

BACK TO TOP

S. Off-Site Installation and Servicing

The Off-Site Installation and Servicing policy applies to all locations in good standing that are accredited as (Type 4) “Off-Site Installer”. Off-Site installations are limited to low-tech category. Off-Site installations exclude primary and secondary driving controls, high-tech, and structural modifications.

Locations accredited as an Off-Site Installer are required to have a permanent shop facility in accordance with Rules Section V.L and comply with the Off-Site Installation and Servicing policy defined in the NMEDA Guidelines.

BACK TO TOP

T. Regulatory Compliance:

New Conversions* – The participant shall be in possession of, and be able to produce evidence that NMEDA determines, in its sole discretion, establishes compliance with identified regulatory requirements for all personal-use, new conversions the participant advertises, offers for retail sale or sells at retail.

Conversions that have been reviewed and accepted by NMEDA’s Compliance Review Program (CRP), and posted to the NMEDA website, meet the requirement above.

For those conversions not posted to the NMEDA website, acceptable forms of evidence include:

1. • a NMEDA-specific test report summary from a NMEDA-authorized third-party test lab or NMEDA-authorized engineering firm stating compliance to all applicable regulatory standards; or
   • an acceptance statement from NMEDA CRP, based on CRP’s established, objective criteria.

Absent the ability to meet, or to objectively prove satisfying, the compliance evidence threshold, offering for retail sale or selling at retail a personal-use, new conversion a is a rule violation that may result in the suspension of the participant’s QAP status.

* = for purposes of this subsection, “new conversion” is defined as: a converted vehicle which has not been the subject of a retail sale since the conversion; or, a customer-owned vehicle which the participant offers to convert, or causes to be converted.

BACK TO TOP

U. Subcontracted Work

If there is any work within the scope of the QAP subcontracted out, the subcontractor must be an accredited QAP location and listed in the job details. This section does not apply to work subcontracted out directly to a manufacturer exclusively for the installation of the manufacturer’s own product(s). A manufacturer doing subcontracted work for a dealer is required to provide the dealer with evidence of insurance adequately protecting the customer’s vehicle while in transit and while in the manufacturer’s possession. The dealer shall retain such evidence of insurance.

BACK TO TOP

V. Mediation Process

All QAP accredited locations, regardless of membership status, are subject to the provisions of the NMEDA mediation process and shall abide by the decisions thereof.

BACK TO TOP