QAP Complete Program Description-indexed - NMEDA

QAP Complete Program Description & Rules

01. QAP LOGO PNG

Quality Assurance Program (QAP) Rules

QAP-101 (2021) — Updated January 2021

Below are the Quality Assurance Program Rules, essentially the “instruction manual” for our members. In conjunction with the QAP Guidelines, these documents are the foundation for the program.

To search the QAP Rules for a specific topic or term, press Ctrl + F to open your browser’s “find” feature.

You can download a PDF version of the QAP Rules here.

I. Purpose and Scope

The Quality Assurance Program (QAP) is the only nationally recognized accreditation program for the adaptive mobility equipment industry. The purpose of the program is to ensure the products and services provided by Quality Assurance Program (QAP) accredited locations meet or exceed customer needs and current government safety requirements. It is based on the principle that in order to satisfy customers consistently, companies must have a systematic and documented approach to quality. The program was developed to elevate the level of performance to reliably meet consumers’ personal transportation needs in the safest manner possible.

The QAP designation is indicative of enhanced vehicle modification and adaptive equipment installation consistent with the highest standards available in the industry. Accredited locations that install, sell, and service adaptive mobility equipment for private use, non-commercial vehicles, are required to follow guidelines written in accordance with motor vehicle safety standards, a professionally managed dynamic and static testing program and proven quality control practices that advocate the highest level of performance and safety.

QAP Requirements:

All accredited locations in the QAP are held to extremely high standards for consumer safety and product quality. They are required to:

  • Maintain a NMEDA approved Quality Control Manual that defines processes affecting quality and focuses on customer satisfaction and compliance to applicable industry and regulatory standards while fostering continuous improvement opportunities on product and services offered.
  • Maintain Product, and Completed Operations, and Garage Keepers insurance for liability purposes and to protect the consumer and accredited location.
  • Have certified welders for all welding to assure modifications meet or exceed industry standards.
  • Have technicians who are certified for the equipment they sell, install and service.
  • Maintain detailed records of all adaptive work for at least seven years that are specific to a customer/vehicle for traceability and future reference.
  • Undergo an audit at least annually by an independent Audit Firm to ensure compliance to the QAP Rules, NMEDA Guidelines, certain aspects of the Americans with Disabilities Act (ADA), the National Highway Traffic Safety Administration’s (NHTSA) Federal Motor Vehicle Safety Standards (FMVSS) and “Make Inoperative” mandates as required. In Canada, accredited locations are required to meet applicable building code, and Canada Motor Vehicle Safety Standards (CMVSS).
  • Abide by the Mediation Committee’s decisions whenever a complaint is lodged.
  • Have a dedicated phone number manned by qualified service personnel and provide 24/7 emergency service or support assistance to their customers at home or on the road.
  • Meet NMEDA shop facility and equipment requirements to assure ADA guidelines (or Canadian equivalent) are met or exceeded and customers are comfortable during fittings and on-site inspections.
  • Perform weight analysis using calibrated four-corner scales to assure customer safety, that completed product complies with all applicable motor vehicle safety standards, and load carrying capacity requirements are maintained.
  • Maintain calibration on measurement equipment to assure data accuracy and manufacturer installation instructions are followed.
  • Use the NMEDA Servicing Agreement when offering products outside of the standard service area to assure the product or service will be performed by another accredited QAP location where possible.

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II. Program Participation

All NMEDA member entities and individuals, regardless of member type, are required to abide by all QAP/MQAP Rules and Guidelines for any relevant activity in which the member engages.

All NMEDA members who engage in the retail sale of adapted vehicles and/or the installation of adaptive equipment for consumers are required to achieve and maintain the QAP Accreditation.

QAP Accreditation is available to vehicle retailers and adaptive equipment installers, regardless of NMEDA membership status. This Accreditation requires adherence to all applicable QAP rules and an annual third-party audit.

NMEDA member QAP accreditation fees are included in the annual membership dues. Non-member QAP accreditation fees are established by the NMEDA board of directors and are currently $1,595 USD annually. Annual audit fees are in addition to accreditation fees.

Member and Non-Member Entities with Multiple Locations:

NMEDA member and non-member entities with multiple locations must have all locations QAP accredited for the type(s) of work performed at the location.

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III. Categories of QAP Accreditation

The QAP accreditation categories are established by the type(s) of modifications that are performed with respect to the adaptive equipment industry.

QAP locations can earn accreditation in any or all of the following four categories.

NOTE:  A location must be accredited for all of the types of work that it performs.

Type 1 – Mobility Equipment Installer:

This is an accreditation to install low technology mobility equipment including, but not limited to:

    • Trunk lifts for wheelchairs and scooters
    • Portable ramps
    • Power and manual wheelchair tie-downs
    • Simple non-driver devices
    • Manual hand controls
    • Steering devices
    • Left foot accelerator
    • Pedal extensions
    • Roof-top carriers
    • Driver and passenger power and manual transfer seats
    • Wheelchair lifts
    • Secondary driving aids (non-electrical)
    • Driver trainer brakes
    • Power seat bases

Type 2 – Structural Vehicle Modifier:

This is an accreditation to perform structural modifications to certain vehicles based on designs accepted by CRP including, but not limited to:

    • Conversion kits
    • Lowered floors
    • Power pans
    • Raised roofs
    • Raised doors
    • Support cages

NOTES:

    1. A company that subcontracts structural modifications in their entirety will not be considered a Structural Modifier and cannot be accredited as such. All structural subcontracting must be made to currently accredited QAP Structural Modifiers.
    2. A company performing structural modifications that subcontracts only their welding to certified welders will be considered a Structural Modifier.  The Structural Modifier must have a copy of the subcontractor’s welding certificates on file.
    3. A company that subcontracts structural modifications cannot be advertised as if such modifications are performed there, nor can this be implied.

Type 3 – High-Tech Driving System Installer:

This is an accreditation to install high-tech primary driving systems including, but not limited to:

    • Low and zero effort steering systems with backup
    • Low and zero effort braking systems with backup
    • Electronic and pneumatic gas/brake
    • Horizontal, joystick, hydraulic, and electronic steering systems
    • Touch pads/secondary controls (requiring electrical)

Type 4 – Off-Site Installer:

This is an accreditation to perform installations and servicing off-site. An Off-Site Installer must still have a permanent shop location and a dedicated vehicle for this purpose. Off-Site installations are limited to specific (low tech) equipment such as hitch mounted equipment and other equipment that can be performed at a client’s home where ambient environmental and working conditions allow for safe and proper installations. All of the requirements for Off-Site installation and servicing are found in the NMEDA Guidelines.

Note: Additional insurance may be required to cover work performed off-site. Consult your insurance carrier for more information.

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IV. NMEDA QAP Accreditation and On-going Membership Process

The QAP accreditation process is detailed in this section. There is additional information and links to electronic forms provided on the NMEDA website at www.nmeda.org/documentcenter.

A.  Complete a NMEDA Member or QAP Non-Member Application

Request the member (or QAP Non-member) application directly from NMEDA or visit the NMEDA website.

B.  Submit required documentation to NMEDA

  1. Certificates of Training: Furnish copies of certificates of training from all manufacturers listed on your application form. Some manufacturers may not offer factory training and/or certificates. A letter stating authorization to sell and/or install their product must be furnished in lieu of a certificate.
  1. Welding: US applicants must submit a welders’ certification to AWS D1.1 or AWS D1.3 if structural modifications are made. If welding is contracted out, a copy of that welder’s certificate must be included with the application. Test welds for certification must be done in accordance with AWS D1.3 sheet metal welding code or AWS D1.1 structural welding code.

Canadian applicants must submit a welders’ certification to Advanced Welding Techniques standards in accordance with sheet metal or structural welding code.

Note: All welding for any accreditation type shall be performed by certified welders in accordance with Guidelines Section 3. While only applicants seeking accreditation as Structural Modifiers need to submit their welding certifications during the application process, all welders for other accreditation types (when necessary) are expected to have certification on file and make this certification available upon request.

  1. NHTSA Modifier Registration: Applicants are required to register as a modifier on the NHTSA website. Registration will be verified at the initial and annual audits.

Canadian applicants must submit a copy of the National Safety Mark from Transport Canada if they do structural modifications.

  1. Insurance Certificate: An insurance certificate that meets the requirements of Section V “Program Requirements.”
  2. Quality Control Manual: The applicant shall submit their existing QC manual for approval. If the applicant does not have an existing QC Manual, they can create one using the NMEDA provided template (QAP-F08) or by any other method. The minimum requirements for an acceptable QC Manual are defined in Quality Control Manual Requirements found on the NMEDA website. Once received, NMEDA will approve and sign the QC Manual and send the signed copy back to the applicant and place a copy in the QAP file.

C.  Payment / Annual Audit Fee

Payment for membership dues or non-member accreditation fees and the initial audit fees must be included with the application.

D.  Missing Documentation

If the application does not contain all the required information/documents the applicant will be sent written notice within 10 working days of receipt of the application that documentation is missing. The applicant must supply missing documentation to NMEDA within 30 days. If the missing documentation is not received within the 30 days allowed the application process will be terminated. QAP accreditation fees are non-refundable.

E.  Auditing Firm Notification of Application Approval

Once the application and QC Manual are approved, NMEDA will forward all relevant documents and applicant information to the audit firm. The audit firm will contact the applicant within fourteen (14) days to schedule the initial audit. The initial audit must be completed within six (6) weeks of application approval.

F.  Initial QAP Accreditation

After successful completion of the initial audit, NMEDA will issue the QAP certificate of accreditation. The accredited location may then make use or reference to NMEDA and/or QAP in advertising, electronic media, labels on vehicles, or printed materials.

G.  Subsequent Audits and Billing

Subsequent audits by the audit firm will take place annually, generally within one year from the initial accreditation date or the prior year’s audit; however, more or less time, at the discretion of NMEDA and the audit firm, is acceptable to allow for efficient audit groupings (travel logistics).

The invoicing is made from, and payable directly to NMEDA. Audit fees are not included with membership dues, or with non-member QAP accreditation fees and are billed separately.

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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.

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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.
    2. Label Log -The QAP requires accredited locations to maintain a label log (QAP-F26). The label log is a listing of all QAP labels applied in a given month. The label log is typically arranged in a binder that also includes the associated Label Reporting Forms (QAP-F25), and the Monthly Label Use Summary Form (QAP-F27) for each month. Additionally, the QAP label number is to be applied to any inspection or vehicle acceptance forms that are contained in the customer’s file for cross-referencing. A chronologically sorted label log is considered a valuable resource that can aid the accredited location in monitoring monthly activity and would be useful in the event they were called upon to carry out a recall.
    3. Label Reporting Requirements – Each accredited location is required to submit monthly label use to the audit firm. The report shall include the Monthly Label Use Summary Form (QAP-F27) along with all associated QAP Label Reporting Forms (QAP-F25). The report is due to the audit firm every month including months where no labels have been applied. In the event no labels have been applied only the Monthly Label Use Summary Form is required to be submitted with zero “0” labels applied. This will provide data on activity including how many labels were used and what types of equipment were installed.  The report forms must be submitted electronically to the audit firm at the beginning of each month at the following e-mail address: info@radcoinc.com. Alternate arrangements for delivery shall be agreed to with the audit firm and NMEDA.

Penalties for Infraction – If a monthly label use report is not delivered to the audit firm after sixty (60) days from the first day of the month, the location’s QAP status will be temporarily suspended from the program. To be reinstated, NMEDA must verify that the delinquent reports have been received.

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C. Maintaining Books, Records, Standards of Knowledge, and Tool Verification:

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.

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).

1. Customer File:  This file must contain:

a.    A completed Label Reporting Form

b.    A work order describing the work performed,

c.    Completed inspection checklists for the activities carried out,

d.    The names of the technicians who performed, and in the case of an uncertified technician, supervised the work,

e.    Evidence that the customer was provided instruction on the use or maintenance of the devices installed.

f.     Additionally, if applicable and/or required by the Guidelines:

          • NHTSA Make Inoperative form,
          • A copy of the customer’s driver’s license,
          • DRS assessment or current experience statement.
          • Weight analysis
          • Wiring diagram
          • Out of Area Service Agreement
          • Evidence of test drive
          • Evidence of final fitting

2. Evidence of Training: Training certificates must be maintained (hardcopy or electronic) for all individuals who perform (and/or supervise) the work defined in the customer file as well as the required NMEDA Certified Technician (NCT) online trainings.

3. Standards of Knowledge: The accredited location must have access to the following documents and be readily available to the person(s) performing the work. These documents are available on the NMEDA website.

a.    NMEDA QAP Rules

b.    NMEDA Guidelines

4.    Evidence of Tool 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.

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 calibration, but if using this method, there shall be a documented process that is approved by NMEDA.

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 current calibration.

5.    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.

6.    Business Changes Requiring Notification:

Any changes to the approved QCM must be submitted to NMEDA, including: Employees (Appendix A), Facility (Appendix B), Tools (Appendix C), and Products (Appendix D).

7.    NHTSA “Make Inoperative” Form (US locations only):

The accredited location is responsible for completing the “Make Inoperative” form for each vehicle to which it applies.

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D. 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.

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E. 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.

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F. Facility Specifications and Compliance Policy:

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

    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.

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G. 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 Section V.C.4 for Calibration Requirements
1 – if the multi-meter is used for any quantitative acceptance data, it must be calibrated

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H. 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. 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. 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).

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I.  Out of Area Sales and Service Requirements:

After-Sale Service Agreements:

All vehicles outfitted with new warrantied mobility products for use by individuals with disabilities must be sold and delivered only in the seller’s service area, or in mutual agreement with another QAP accredited location (without crossing international borders) who will serve the client. This mutual agreement should be evidenced by a completed “QAP Servicing Agreement Form” (See Appendix B), which is to be signed by the selling QAP accredited location, the servicing QAP accredited location, and the customer prior to finalizing the sale.

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. 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, a QAP Servicing Agreement Form signed by the customer will be placed in the customer file.
    2. 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 has found no one willing/able to service the products sold, a QAP Servicing Agreement Form listing the service locations contacted and signed by the customer will be placed in the customer’s file.
    3. Alternatively, a customer may elect to utilize the selling location for service, regardless of the customer’s proximity to the selling location. This must be acknowledged by the customer on part A of the QAP Servicing Agreement Form.

Misrepresentation of After-Sale 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.

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J. 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.

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K. 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 on the QAP Label Reporting Form. The inspector, as a minimum, shall have: (a) current certification from the mobility equipment manufacturer(s), or (b) current NMEDA QAP-1-2-3 training.

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L. 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 1-2-3 and QAP 4 trainings. Recertification is required every two years.

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

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M. 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.F and comply with the Off-Site Installation and Servicing policy defined in the NMEDA Guidelines.

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N. Regulatory Compliance:

New Vehicle Conversions –The participant shall be in possession of, and able to produce sufficient, as solely determined by NMEDA, evidence of regulatory compliance for all newly converted vehicles they sell. All newly converted vehicles procured from MQAP accredited manufacturers are considered compliant (compliance can be verified on NMEDA’s website) and no further documentation is necessary. However, for newly converted vehicles procured from a source that is not listed on NMEDA’s website, the accredited location shall be in possession of, and able to produce, evidence of regulatory compliance; typically F/CMVSS. NMEDA will make available a listing on its website showing what standards apply and how accredited locations can comply. Acceptable forms of evidence may include: a test report summary from a NMEDA authorized third-party test lab or engineering firm stating compliance to all applicable regulatory standards, or an acceptance statement from NMEDA CRP, based on all established, objective criteria.  In the absence of either form of compliance evidence, delivery of the converted vehicle to the customer is a rule violation that can impact a location’s QAP status. The accredited location should contact NMEDA, for referral to the Compliance Review Program if there are any questions regarding either form of compliance.

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O. 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 on the Label Reporting form (QAP-F25). 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.

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P. 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.

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VI. Status of NMEDA QAP Accreditation

A. Application Pending:

Once the application, all required materials, and payment for the initial audit and dues (if applicable) is received by NMEDA, the applicant will be put in pending status.

B. Accredited / Good Standing

The participant will be placed in accredited / good standing status upon successful completion of the initial audit.

C. Suspended

See Section VII.

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VII. Suspension, Termination, and Reinstatement

QAP accreditation may be suspended for noncompliance with: program requirements as defined herein; the NMEDA Bylaws (for NMEDA members); or the Dealer Participation Agreement.

QAP accreditation may also be suspended for providing false information to NMEDA or the audit firm.

Non-Compliance – Audit Findings:

1. Major findings – Corrective action on a major finding must be completed within 14 days of the location’s receipt of notification or the location will be suspended.

2. Minor findings – Corrective action on a minor finding must be completed within 28 days of the location’s receipt of notification or the location will be suspended.

A suspended location that complies with all corrective actions or Mediation’s directive within 120 days of suspension notification will be reinstated.

Failure to comply with all corrective actions or Mediation’s directive within 120 days of suspension notification will result in termination of accreditation. Upon presenting evidence of compliance, the location may reapply for QAP accreditation subject to the fees appropriate for any first-time applicant.

Additionally, a location that applies QAP labels while suspended will be terminated. Twelve months after termination, the location may reapply for QAP accreditation subject to the fees appropriate for any first-time applicant.

Upon receipt of notification of termination from the program the location forfeits all fees and must immediately:

Cease making any reference that indicates QAP and/or NMEDA on modified vehicles, websites, invoices, advertising, publicity, or other releases.

Return all labels to the Administrator. The location also forfeits all funds paid to Administrator for the labels.

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VIII. Complaint Process

All complaints are handled via the documented Mediation Process.

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IX. Privacy Policy

Information provided by the accredited location including the application, insurance policies, training and welding certifications is confidential and will only be shared with the audit firm as necessary; audit reports are confidential.  NMEDA will only provide forms and documentation to third parties as required by a court of law.

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X. NMEDA QAP Buy/Sell Regulations and Procedures

A.  An entity acquiring an existing QAP location(s) must submit a “Change in Ownership” Form (QAP-F35) for each location within 30 days of taking ownership. Failure to comply may result in suspension of accreditation.

B.  If the buyer (purchasing entity) currently operates QAP accredited location(s), and is purchasing a QAP location(s) that is in good standing, then the newly acquired location(s), with NMEDA approval, may continue to operate as QAP in good standing, provided all required documentation has been submitted.

C.  If the buyer (purchasing entity) currently operates QAP accredited location(s), and is purchasing a location(s) that is not in good standing, then the newly acquired location(s), with NMEDA’s approval, may be granted, if requested, a “Conditional” QAP accreditation to carry them over until the time the initial audit is completed, provided all required documentation and payment have been submitted.

D.  A buyer who does not have an existing QAP accredited location is considered a new applicant and the new owner must follow the accreditation process described in section IV.

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XI. QAP Location Change Policies – Other

A.  Facility Relocation – If a store relocates to a different mailing address, that accredited location shall notify the NMEDA office with the new information no later than thirty (30) business days after the move. Notification shall include updated Quality Control Manual.

B.  Name Change – If an accredited location changes its legal business name, that location shall notify the NMEDA office with the new information no later than thirty (30) business days after the name change.

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APPENDIX A – NMEDA SERVICE AGREEMENT

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APPENDIX B – AUDIT FINDINGS AND ACTIONS MATRIX

FINDING / CLASS
NMEDA ACTION
QAP CONTACT ACTION
AUDIT FIRM ACTION
DISPOSITION

Major

CLASS 1

QAP Coordinator will issue a formal Corrective Action Request (CAR) to the primary QAP Contact. The CAR will include a description of the finding, along with a due date for response. Once there is evidence the QAP Contact has been notified their membership status will be changed to “Suspended” until the time the CAR is completed and approved. QAP Contact is required to identify the root cause of the finding and complete the action necessary to prevent the finding from recurring. The QAP Contact completes the CAR through the member portal by the due date or asks for an extension. Verification of the effectiveness of the corrective action will be evaluated during the next scheduled audit. The CAR will be closed when approved by NMEDA and a record of the finding recorded. If the CAR is not approved, NMEDA will reply to the QAP Contact with any further actions. Failure by the QAP Contact to respond to the CAR or perform the steps necessary to close the CAR will result in continued suspension and may lead to termination from the QAP.

Major-OSAR
(out-of -sequence audit required)

CLASS 1

QAP Coordinator will issue a formal Corrective Action Request (CAR) to the primary QAP Contact. The CAR will include a description of the finding, along with a due date for response. Once there is evidence the QAP Contact has been notified their membership status will be changed to “Suspended” until the time the CAR is completed and approved. QAP Contact is required to identify the root cause of the finding and complete the action necessary to prevent the finding from recurring. The QAP Contact completes the CAR through the member portal by the due date or asks for an extension. Once the CAR is closed, NMEDA will notify the Audit Firm to schedule an out of sequence audit. The Audit Firm will complete the audit and provide the results to NMEDA for review. The CAR will be closed when approved by NMEDA and a record of the finding recorded. If the CAR is not approved, NMEDA will reply to the QAP Contact with any further actions. Failure by the QAP Contact to respond to the CAR or perform the steps necessary to close the CAR will result in continued suspension and may lead to termination from the QAP.

Minor

CLASS 2

QAP Coordinator will issue a correspondence to the primary QAP contact notifying them of the action that is necessary to close the Minor finding and the due date to avoid further action or suspension. The facility’s membership status remains in good standing. QAP Contact is required to complete all actions necessary including providing objective evidence to satisfy the QAP Coordinator that the action is completed. Verification of the effectiveness of the action will be evaluated during the next scheduled audit. The Minor finding is closed when the QAP Coordinator issues confirmation back to the QAP Contact. In the event the QAP Contact does not respond to the action(s) by the due date(s) assigned by the QAP Coordinator, the facility’s membership status will be changed to “Suspended” and remain suspended until the issue is resolved.

Opportunity For
Improvement (OFI)

CLASS 3

 

No Action, the information is recorded on the audit report but is not counted as a finding. No Action is formally required by the QAP Contact, but they should consider the opportunity and if it can improve the product or process. Additionally, the QAP Contact should consider its potential consequences for future audits. The auditor will review OFIs recorded from previous audits during pre-audit preparation and observe if the condition is acceptable during the next scheduled audit. None

NOTES:

Two consecutive suspensions demonstrate a lack of commitment and should result in the removal of NMEDA QAP accreditation for a period of not less than six (6) months.

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APPENDIX C – QUALITY CONTROL MANUAL (QCM) REQUIREMENTS

 A. Instructions for completing the Quality Control Manual:

The accredited location’s quality control manual, also known as the “QCM” is the primary document used that shows NMEDA the benefits and value that is being provided to customers. NMEDA provides the accredited location with the flexibility to use an existing company quality manual, create a new one from scratch, or create one using the sample template that NMEDA provides. As well, it provides a valuable link to each of the QAP Rules and an understanding of how the Guidelines are being followed. To the NMEDA third party auditors, it is an extremely valuable resource that assures the audit process goes smoothly. The use of the QCM Template is not mandatory as long as all the minimum elements listed in this appendix are included in the completed manual.

Below are the established minimum required elements (or components) for a QAP compliant QCM. It is noted that while there is an order to the list of elements, it is not mandatory that the QCM follow this order as shown. The important aspect is that each of these elements are covered somewhere in the QCM, whether they stand alone, or are combined.

As a minimum the QCM shall contain the following elements unless otherwise stated as “(optional)”:

  1. Quality Policy: A stated quality policy that is specific to the accredited location. The quality policy should include an element of how they are satisfying the customer.
  2. Scope: Describes the scope of work performed accredited location including the accreditation type. Makes reference to the use of the approved Guidelines.
  3. Definitions and Acronyms: A list clarifying any acronyms or verbiage used in the QCM document that a reader may need for assistance.
  4. QAP Program Requirements: A statement describing how the accredited location complies with each of the QAP Program Requirements found in section V of the QAP Rules, and if any are not applicable, that should be indicated. This section shall also describe how the accredited location generates, controls, approves, releases, stores, and destroys QAP required documents such as customer/vehicle files.
  5. General Requirements: Describes the purpose of the quality control system implemented at the accredited location. Includes the accredited location’s commitment to the QAP Rules and established Guidelines as well as any applicable motor vehicle safety standards and other applicable industry standards employed.
  6. Organizational Chart: This is recommended to be an Appendix to the QCM. That way the appendix can be updated without revising the manual. The organizational chart can be graphical or can be text based and again, depends on the size and complexity of the organization. It may be that there is one person responsible for everything, or that there are multiple people. As a minimum the section shall describe the name and title of the person that is designated as the QAP contact. This name shall also be listed in the member information portal on the NMEDA website.
  7. Responsibilities and Authority: Describes (by title, not name) who is responsible for what major activities at the accredited location, who is authorized to make changes to processes, or allow shipment of product. Shall include that there is a primary QAP contact that is responsible to maintain current information on the NMEDA website member portal and receive and disseminate QAP related information as it is distributed by NMEDA via Short Circuits, Circuit Breaker, or other targeted emails, notifications and/or letters. If the accredited location opted to assign a secondary QAP contact it should be mentioned here.
  8. Process Control: This section of the QCM should describe the methods used for controlling the accredited location’s internal processes and will vary depending on the size and complexity of the location. Describe how the accredited location assures their processes remain in control. If the accredited location has a document control system, it should be mentioned here. State how the accredited location inspects work in-process and if there are records as a result of the inspections.
  9. Receiving Inspection: Describe how the accredited location receives material to assure it is compliant with the manufacturer, NMEDA, regulatory agency, or industry specifications. This is a simple description, not a complex process work instruction. If there is an internal work instruction, that can be referenced here.
  10. Process Flow (optional): It is optional that the accredited location provides a process flow. This is best depicted visually with a flow chart, however, can be accomplished by other means. The purpose of the process flow chart is not only to aid the employees performing work, but also for the auditor to understand how the accredited location processes work through the shop location. There is no right or wrong to process flow, it should accurately reflect how work is processed in a serial or parallel manner.
  11. Non-conforming Material: Describe how the accredited location handles nonconforming material either in-process, or at incoming, or anywhere in the process. How the non-conforming material is segregated and identified so it is not installed or accepted as conforming material.
  12. NMEDA Guidelines: Describe how the accredited location interprets and understands the NMEDA guidelines, could also include what parts of the guidelines apply and what do not apply. This is not a rewriting of the guidelines but can be as simple as a short sentence that states the Guidelines are used as a reference when there are no manufacturer instructions.
  13. Customer Satisfaction: Describes what processes the accredited location employs to satisfy its customers. This should include a minimum description of the following:
    • A high-level overview of the customer satisfaction process.
    • The follow-up process if there is a returned item or the customer is not satisfied with the product or service.
    • How customer complaints or returns are handled/processed.
  14. Labeling: Labeling is a large part of the QAP. In addition to the QAP label, there can be other labels such as Make Inoperative, Load Carrying Capacity, Tire Placards and more. This section shall describe the process the participant performs for labeling, including the label log, and goes through each of the label types used at the location.
  15. Measuring and Test Equipment: This section describes how the accredited location maintains and calibrates measuring and test equipment (MT&E) such as the four-corner scales, multi-meter (if applicable), and torque wrenches. For example, if the accredited location calibrates in-house or uses a third-party service. It is recommended that this section is a higher-level description and reference an appendix that can be used to list each piece of MT&E, its calibration interval, and serial numbers.
  16. Corrective and Preventive Action: Describe the process the accredited location performs to correct and/or prevent anomalies or nonconformance’s found by in-process and final inspections, NMEDA, or the audit firm. It should be noted that audits may result in nonconformance’s and this section should state how those deficiencies are handled and if not already described in the Responsibilities section, who (by title) is responsible to handle these situations.
  17. Training Requirements: A review of what types of training is required, this includes NCT and technician training for each manufacturer product, as well as optional certification training and welding if the accredited location is structural modifications or welding as part of any mobility equipment installation or modification. Note: if the installation is supervised then there shall be a record for the person supervising, and a training certificate for that person is on file.
  18. Revision Log: There shall be a revision log that is part of the QCM that shows the revision history of any changes made to the manual after NMEDA approval.
  19. Manual Review: The accredited location is required to review the QCM at least annually and provide evidence the review was completed. This section should indicate that the accredited location reviews the manual for fitness for use and to assure any changes to policies, processes or other regulatory changes have been considered and incorporated as necessary. It is suggested to use a manual review checklist as the basis for the review and to use a log sheet that shows the date and person(s) responsible for completing the review. The auditor will review this log at each annual audit. The QC Manual Annual Review Checklist QAP-F15] can be downloaded or requested from the NMEDA.
  20. Equipment Manufacturer and Product Listing: The QC Manual shall contain a product listing, or a reference to the product listing (if electronically stored and controlled). It is suggested the listing be an appendix to the manual. The list should include as a minimum, the manufacturer name and product type for every piece of adaptive mobility equipment the accredited location sells, installs, or services. When there are changes to the product listing, the QAP Contact shall provide NMEDA with the updated listing.

Additional notes about the QC Manual:

  • There are required (minimum) elements as described, however it is understood that some elements may be combined. So long as each minimum element is covered, the manual will be acceptable.
  • The accredited location may have an existing quality control or quality assurance manual. If that manual includes all of the minimum elements, there is no need to create an additional manual for QAP accreditation.
  • The manual is intended to be flexible to accommodate locations of all sizes. The primary purpose is to document the processes as they apply to complying with the QAP rules. Manual size is not important and is dependent on the scope and complexity of the location.
  • A sample QC Manual Template can be provided by NMEDA for more assistance with the creation of the manual. Contact NMEDA for further assistance if necessary. The QC Manual Template can be supplied by request or found on the NMEDA website document section.

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