Pamela Beck Danner, Administrator Jason McJury, PE Civil ... Government...5 •the hud standards...
Transcript of Pamela Beck Danner, Administrator Jason McJury, PE Civil ... Government...5 •the hud standards...
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MANUFACTURED HOUSING MONITORING SERVICES
INDUSTRY DAY
Pamela Beck Danner, AdministratorJason McJury, PE Civil EngineerEric Bers, PE General Engineer
Office of Manufactured Housing Programs
November 16, 2017
• The Manufactured Housing Program, established by the National Manufactured Housing Construction and Safety Standards Act.
• Nationwide program established to protect the quality, safety, and affordability of manufactured homes through the enforcement of the Federal Manufactured Home Construction and Safety Standards established by HUD.
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Program Purpose
•The National Manufactured Housing Construction and Safety Standards Act gives HUD authority to:
–Establish preemptive manufactured home construction and safety standards
–Determine whether manufactured homes comply with the standards
–Conduct inspections and investigations necessary to enforce the standards
–Contract with separate and independent organizations to carry out monitoring and inspection work
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The Act
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• The Federal Manufactured Housing Program is administered exclusively from HUD Headquarters in DC (no support provided by HUD’s field offices).
• Program support is provided by private and state agency partners accepted by HUD.
• Contracted services are used to assist HUD in monitoring and assessment of performance of agency partners.
General Program Facts
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•The HUD Program is funded by label fees collected from manufacturers. A label is affixed to each transportable section of a manufactured home.
General Program Facts
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•The HUD standards define a manufactured home as:
“A STRUCTURE, TRANSPORTABLE IN ONE OR MORE SECTIONS, WHICH IN THE
TRAVELING MODE IS EIGHT BODY FEET OR MORE IN WIDTH OR FORTY BODY OR
MORE IN LENGTH OR WHEN ERECTED ON SITE IS 320 OR MORE SQUARE FEET,
WHICH IS BUILT ON A PERMANENT CHASSIS AND DESIGNED TO BE USED AS A
DWELLING WITH OR WITHOUT A PERMANENT FOUNDATION WHEN CONNECTED
TO THE REQUIRED UTILITIES, AND INCLUDES THE PLUMBING, HEATING, AIR
CONDITIONING, AND ELECTRICAL SYSTEMS CONTAINED IN THE STRUCTURE…”
•The HUD standards and regulations do not apply to modular or factory-built housing or self propelled recreational vehicles.
What Is A Manufactured Home?
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Example Of A Single Wide Home
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Example Of A Double Wide Home
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•Approximately Eight (8) million Manufactured Homes have been built since the Program’s inception in 1976.
•In Calendar Year 2017, we estimate there will be 90,000 HUD Code homes produced, comprised of more than 135,000 transportable sections.
General Program Data
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•24 CFR 3280Nationally Preemptive Manufactured Home Construction and Safety Standards
•24 CFR 3282Manufactured Home Procedural and Enforcement Regulations (sets forth requirements for industry participants)
Program Standards & Regulations
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•24 CFR 3285Model Manufactured Home Installation Standards
•24 CFR 3286Manufactured Home Installation Program
•24 CFR 3288Manufactured Home Dispute Resolution Program
Program Standards & Regulations
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•Current Contract includes IPIA, DAPIA, and SAA Monitoring and Inspection Services
•Anticipated procurement to be two acquisitions
➢IPIA/SAA Monitoring and Inspection Services
➢DAPIA Monitoring Services
Monitoring Contract History
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IPIA and SAA Monitoring and Inspection Services
• 14 IPIAs provide services to about 130 manufacturing plants (nationally, and internationally)
• 35 States have partnered with HUD to assist in portions of the enforcement and regulation of the construction program
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Background Information
Constraints and Variables
• Number of production plants and locations
• Number, type and complexity of issues observed in the field
• Frequency and extent of natural disasters
• Number and location of monitored agencies
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Background Information
Special Qualifications
• Lead/Primary Auditors - Certified Quality Auditor (CQA) certification from the American Society for Quality
• Other personnel performing systems analysis or compliance assurance services - ASTM Standard E-541 (Standard Specification for Agencies Engaged in System Analysis and Compliance Assurance for Manufactured Buildings)
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Background Information
Production Inspection Primary Inspection Agency (IPIA)
• 5 Private Companies
• 9 Units of State Government
State Administrative Agency (SAA)
• All Units of State Government (35) (manufacturing and location)
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Background Information
IPIA Monitoring – 24 CFR 3282
• Subpart E – Manufacturer and Inspection Certification Requirements
• Subpart F – Retailer and Distributor Responsibilities
• Subpart H – Primary Inspection Agencies
• Subpart I – Consumer Complaint Handling and Remedial Actions
• Subpart J – Monitoring of Primary Inspection Agencies
• Subpart M – On-Site Completion of Construction of Manufactured Homes
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Key Regulation References
SAA Assessment – 24 CFR 3282
• Subpart E – Manufacturer and Inspection Certification Requirements
• Subpart F – Retailer and Distributor Responsibilities
• Subpart G – State Administrative Agencies
• Subpart I – Consumer Complaint Handling and Remedial Actions
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Key Regulation References
• Management
• IPIA Monitoring
• SAA Assessment
• Ancillary Services
Four Principal
Tasks:
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Overview of IPIA/SAA M&I Services
• Management
• IPIA Monitoring
• SAA Assessment
• Ancillary Services
Four Principal
Tasks:
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Overview of IPIA/SAA M&I Services
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Management and Administration
Service Activities/Outcomes
Transition Plan (Out) • Transfer of files and materials • Key steps and schedule• 90 day period
Operating Procedures • Documented procedures• Checklists • Contractor forms • All activities within PWS. • (Historical documents may be used initially)
Monthly Reporting • Consolidated report of accomplishments • Identification of activity for contract tasks
Monthly Meetings • In-person meeting • Review of monthly report• Discuss items of interest
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Management and Administration
Service Activities/Outcomes
Data Management and Security Plan
• HUD access to contractor data• Data for monitoring activities maintained in
a fashion that allows for identification of trends and performance of each entity
• Confidentiality and Non Disclosure• COI Avoidance
State Participation (In-Plant Auditing Only)
• Agreements with SAAs to provide personnel to conduct “joint monitoring” –see 3282 Subpart J
• Management
• IPIA Monitoring
• SAA Assessment
• Ancillary Services
Four Principal
Tasks:
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Overview of IPIA/SAA M&I Services
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IPIA Monitoring
Service Activities/Outcomes
Schedule In Plant Audits • Identification and coordination of all parties• Travel estimates and approvals• Notification to all parties
Perform In Plant Audits • Historically 3-day audits• Collect data to assess whether IPIA is
performing effectively (3282.362)• Regular, Follow Up, and Post-Approval
Audits• Preliminary reports provided
Resolve In Plant Audit Reports
• Failures to Conform• Quality Systems Issues• Finalized audit reports provided
Handle Disputes • Forward issues in dispute to HUD
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IPIA Monitoring
Service Activities/Outcomes
Review Plant-Specific Plans of Corrective Action
• Analysis of In Plant Audit data• Data indicates ineffective manufacturer QA• Recommendation for plants with
ineffective IPIA oversight requiring a POCA
Conduct Post Production Audits
• Review of IPIA activities at retail sites Review IPIA activities at home sites
Perform IPIA Performance Assessments
• Annual reviews of IPIA performance• Based on audit data analysis• Documentation review• Headquarters Visits• Written report with recommendations
Review IPIA Plans of Corrective Action
• Written assessment with recommendation for HUD to accept or seek supplement
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IPIA Monitoring
Service Activities/Outcomes
Manage Certification Label Distribution and Reporting
• Administer process for managing certification label sales and tracking
• Coordination with www.pay.gov• Label ordering and reports• Label usage reporting• Label tracking• Label production and distribution• Review of IPIA Label Operations
Coordinate State Fee Accounting and Payments
• Analyze production and shipment information
• Assist HUD in determining payments to SAAs
• Management
• IPIA Monitoring
• SAA Assessment
• Ancillary Services
Four Principal
Tasks:
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Overview of IPIA/SAA M&I Services
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SAA Monitoring
Service Activities/Outcomes
In Person State Monitoring Assessments
• Review of states with manufacturers• Multi-day audit• Review of State Plan• HQ visit and observation of SAA
administered record review in a plant• Written report of performance and
recommendations
Remote State Monitoring Assessments
• Review of states without manufacturers• Review of State Plan• Generally a remote/conference call audit• Written report of performance and
recommendations
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SAA Monitoring
Service Activities/Outcomes
Review of SAA Plans of Corrective Action
• Written assessment with recommendation for HUD to accept or seek supplement
Conduct Post-Production Audits
• Conduct audit at retailer lot locations• Assess retailer compliance with regulations• Conduct audits of homes on retailer lots
Perform In-Plant Record Reviews
• Conduct in-plant record reviews• Assess compliance with Subpart I
Review Manufacturer Plans of Corrective Action
• Written assessment with recommendation for HUD to accept or seek supplement
Review State Plans • Review and report on new or revised plans
• Management
• IPIA Monitoring
• SAA Assessment
• Ancillary Services
Four Principal
Tasks:
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Overview of IPIA/SAA M&I Services
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Ancillary Services
Service Activities/Outcomes
Alternative Construction /On Site Approval
• Monitoring inspections
Special Investigations and Studies
• Research and technical assistance
Regulatory Specialist Services
• Review monitoring data• Recommendations for enforcement action• Testimony/Expert Witness
Freedom of Information Act Assistance
• Estimates of time and cost to produce documentation
• Copies of relevant documentation
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Ancillary Services
Service Activities/Outcomes
New PIA Applications • Review per regulatory requirements• Letter of findings/observations
Technical Meeting Support • Workshop and seminar support• Preparation/presentation of materials
Technical Information Exchange
• In Person or conference call support
Internet Materials and Data
• Propose and provide materials for posting to HUD’s website
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Ancillary Services
Service Activities/Outcomes
Coordinate with Other Contractors
• Data and information exchange• Quarterly Meetings
Ad-Hoc Reports • Special reports on monitoring data
On Site Technical and Administrative Assistance
• Up to 2 days per week• On site work
•Questions?Four
Principal Tasks
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Overview of IPIA/SAA M&I Services
MANUFACTURED HOUSING DAPIA MONITORING SERVICES
INDUSTRY DAY
Eric L. Bers, P.E.Office of Manufactured Housing Programs
Program Manager
November 16, 2017
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DAPIA Monitoring &
Inspection Contract
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–Review and approve building plans and Quality Assurance Manuals
– Manufacturers contract with DAPIAs for design review services provided
–6 Agencies (5 private, 1 unit of state government)
Design Approval Primary Inspection Agencies (DAPIA)
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Background
• 130 production plants
• 90,000 code homes in 2017
• 135,000 transportable sections in 2017
• Roughly 8 million designs in current library
• Approx. 50 DAPIA-approved design packages
• 8 Million HUD code homes since 1976
• Purpose: support design element of MH
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•24 CFR 3280Nationally Preemptive Manufactured Home Construction and Safety Standards
•24 CFR 3282Manufactured Home Procedural and Enforcement RegulationsSubpart H --Primary Inspection AgenciesSubpart J –Monitoring of PIAs
Standards & Regulations
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Overview of Tasks
THREE Principal Tasks:
• Management and Administration
• Design Review/DAPIA Monitoring
• Ancillary Services
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Management & Administration
• Transition Plan
• Annual Management Work Plan
• Operating Procedures
• Monthly Meetings
• Monthly Activity Report
• Data Management & Security Plan
• State Participation (DAPIA)
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Service Activities/Outcomes
Transition Plan • Transfer of files and materials at end• Schedule and key steps• 90 day period at end of contract
Annual Management Work Plan
• Address all activities, including support • Identify resources—staff, equipment, etc.• Timelines, due dates
Operating Procedures • Documented procedures• Checklists and Contractor forms • All activities within PWS • (Historical documents may be used initially
Monthly Contract Meetings
• In-person meeting • Review of monthly report• Discuss items of interest
Management & Administration
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Service Activities/Outcomes
Monthly Activity Reports • Summary of findings• Report on current data collection efforts• Current log of industry findings
Data Management & Security Plan
• Provide HUD with access to all data• Security Plan to safeguard data• Maintain Conflict of Interest (COI)• Non-Disclosure & Confidentiality
State Participation (DAPIA)
• States may participate (see § 3282.308)• Canvas States to determine interests• Perhaps up to 6 States will participate• Joint monitoring
Management & Administration
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• Design Reviews
• Resolution of Design Error Records
• Handling Disputes
• DAPIA Performance Assessment & Written Performance Reports
• Review of DAPIA Plans of Corrective Actions
• Maintain Library of DAPIA-approved Designs
Design Review Monitoring
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Design Review MonitoringService Activities/Outcomes
Design Reviews • Planning and scheduling• Data collection/analysis• Review designs to determine conformances• Report compilation (8k–10k new pages per mo.)• Minimum 10% Sampling of designs required
Resolution of Design Errors
• Characterize non-conformances • Issue findings for DAPIA review• Maintain/track sequence of comments • Coordinate with DAPIA to resolve
Handling Disputes • Prepare documentation on the “issue”• Present differing sides • Transmit to HUD for a determination• Maintain log of disputes• Follow up after HUD determination
DAPIA Performance Assessment
• Compile design reviews for each DAPIA• Assess respective DAPIA performance• Provide recommendations to improve
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Design Review Monitoring
Service Activities/Outcomes
Review of DAPIA Plans of Corrective Action (POCA)
• Review of DAPIA proposed POCA materials • Assess adequacy of DAPIA response• Provide recommendations for further
action
Maintain Library of DAPIA-approved Designs
• Index incoming designs • Manage design library• Data collection and analysis • Provide current inventory totals and other
data on regular basis
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• Coordinate & Assist in Review of Special Construction/Alternative Construction Approvals
• Perform Special Studies & Investigations
• Provide Regulatory Specialist Services
• Provide Freedom of Information Act (FOIA) Assistance
• Evaluate New Manufactured Housing Partners
• Provide Technical Meeting Support
• Provide Technical Information Exchange and on-Site Assistance
• Provide Internet Materials and Data Access
• Coordinate with Other HUD Manufactured Housing Contractors
• Ad-Hoc Reports
• On-Site Technical Administrative Assistance
Ancillary Services
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Ancillary Services
Service Activities/Outcomes
Coordinate & Assist in Review of Special Construction/Alternative Construction Approvals
• Monitoring inspections &/or engineering• Prepare reports, draft letters, etc.• Make recommendations
Special Investigations and Studies
• Provide research and technical assistance• Data analysis, evaluation, recommendation
Regulatory Specialist Services • Review monitoring data• Prepare documentation for enforcement action• Provide Testimony and/or Expert Witness
Freedom of Information Act Assistance
• Estimates of time and cost to produce documentation
• Data collection/analysis• Prepare documentation• Compile reports
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Ancillary Services
Service Activities/Outcomes
New PIA Applications • Review per regulatory requirements• Data analysis• Review at least one approved design• Letter of findings/observations
Technical Meeting Support • Workshop and seminar support• Preparation & presentation of materials• Note taking and follow up action
Technical Information Exchange
• In Person or conference call support• Provide presentations on technical issues• Report compilation and recommendations• Information dissemination
Internet Materials and Data
• Propose and provide materials for posting to HUD’s website
• Update HUD reports
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Ancillary Services
Service Activities/Outcomes
Coordinate with Other Contractors
• Attend meetings• Provide reports, data & other info• Data and information exchange• Coordinate with other HUD contractors• Maintain log of action items
Ad-Hoc Reports • Special reports on monitoring data• Lists of repeat non-conformances • Listing top ten industry deficiencies• Updated lists of DAPIAs clients and
contacts
On Site Technical and Administrative Assistance
• Up to 1 day per week• On site work• Drafting/editing documents• Coordinating staff on projects and issues
QUESTIONS??
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Manufactured Housing Monitoring Services
Acquisition Information
November 16, 2017Jerl Traylor, Contracting Officer
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Current Requirement
• Contract Number: DU100H-13-C-03
• Incumbent Contractor: •Institute for Building Technology & Safety (IBTS), Inc.
• Contract Type: Firm Fixed Price
• Value: $25,006,546.00 (approx. $5M annually)
• Period of Performance: August 16, 2013 –August 15, 2018
• Set Aside: None, Unrestricted
• Transition Out: 60 days
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Anticipated Solicitation Details
Two Separate RFPs • IPIA and SAA Monitoring Services• DAPIA Monitoring Services
Level of Competition • Full and Open, Unrestricted
Set Aside • None
Contract Type • Firm Fixed Price
Solicitation Release Date • December 29, 2017
Solicitation Response Date • January 19, 2018
Award Date • May 15, 2018
Future Requirement
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Future Requirement
Anticipated Solicitation Details
Evaluation Criteria • Technical Approach• Quality Control Plan• Management Plan• Past Performance• Key Personnel• Socio-Economic Participation✓ Small Business 55%✓ SDB 5%✓ WOSB 5%✓ SDVOSB 3%✓ HUBZone 3%
• Price
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Anticipated Solicitation Details
Transition In • 60 Days
Transition Out • 90 Days
Period of Performance • One Base Year (12 month) and Four Option Years (12 month each)
Future Requirement
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Who Can Bid?
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Capability Statements
Send Us Your Capability Statement
• Send Statements To: [email protected]
• Due Date: November 27, 2017 by 4:00PM EST
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Questions ??