2.2.1 Attachment 1 - SOO - TTHU TSS IDIQ 3.5.2024.pdf
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- Technical Support Services - Transportable Temporary Housing Quality Assurance and Forensic Analysis Federal contract opportunity
- Solicitation number
- 70FB8024R00000021
About this file
This document is a Statement of Objectives (SOO) for a Technical Support Services contract to provide quality monitoring and investigations of Transportable Temporary Housing Units (TTHUs) for the Federal Emergency Management Agency (FEMA).
The SOO outlines the objectives for the contractor to provide services throughout the TTHU lifecycle, including design review, in-plant inspections and monitoring of manufacturing, forensic analysis and root cause investigations, and safety/health/environmental reviews. The contractor will also be tasked with reviewing and enhancing FEMA's TTHU requirements. Key objectives include improving TTHU quality, reducing lifecycle costs, and providing training to FEMA and supporting personnel. The contractor must have expertise in manufactured homes, travel trailers, and other TTHU types, and perform work at various locations including manufacturing facilities, FEMA sites, and the contractor's own facilities. The period of performance is a 1-year base period with 4 option years.
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Technical Support Services Draft SOO- 1
Technical Support Services Transportable Temporary Housing Quality Assurance and Forensic Analysis
Statement of Objectives 3
BACKGROUND: The Federal Emergency Management Agency (FEMA) is seeking the 5 Technical Support Services of a contractor(s) to support its Transportable Temporary Housing 6 Unit (TTHU) Program through quality monitoring and investigations of Transportable 7 Temporary Housing Units (TTHUs). FEMA’s TTHU inventory is comprised of Manufactured 8 Housing Units (MHUs) and Travel Trailers (TT). The FEMA TTHU program oversees the entire 9 TTHU lifecycle, which includes development of requirements, purchase, storage, transportation, 10 installation, training, maintenance, deactivation, and disposal. FEMA provides TTHUs under the 11 Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended (Stafford Act) 12 and related authorities as well as through the Economy Act and other legal authorities. The 13 Stafford Act authorizes FEMA to provide direct temporary housing, acquired by purchase or 14 lease, to individuals or households who would be unable to make use of financial assistance due 15 to a lack of available housing. FEMA uses TTHUs to provide for this need. FEMA defines a 16 TTHU as a dwelling, acquired by purchase or lease, that are designed to be transported in 17 addition to being able to be used for housing for a limited period of time. 18
FEMA primarily uses manufactured homes and travel trailers. FEMA may also use other 19 TTHUs, including but not limited to modular homes, recreation vehicles (RVs), collapsible, soft-20 sided structures, tiny homes, park models, and hard-sided container homes. TTHUs must be in 21 compliance with established industry standards—e.g., Manufactured Homes with U.S. 22 Department of Housing and Urban Development (HUD) standards, set forth in 24 CFR 3280 the 23 Manufactured Home Construction and Safety Standards; Recreational Vehicles must be 24 constructed under the consensus standards promulgated by the Recreational Vehicle Industry 25 Association (RVIA); etc. In addition, FEMA has developed performance requirements for 26 MHUs that enhance the HUD standards and describe the types of MHUs that FEMA requires. As 27 FEMA is provided with technical or production questions from the HUD Code or RV 28 manufacturers, the Agency provides Technical Bulletins and revisions to production or 29 acquisition contracts for TTHUs. FEMA will provide the TSS vendor(s) with updated 30 documentation as appropriate to allow the TSS vendor(s) to perform required monitoring and 31 investigations. For manufactured homes, the contractor's efforts shall be independent of the 32 Production Inspection Primary Inspection Agencies (IPIAs); the Design-Approval Primary 33 Inspection Agencies (DAPIAs); other entities who are permitted under HUD Regulations to 34 monitor the manufacturing of MHUs; and the manufacturer’s quality process. For other types of 35 TTHUs similar restrictions shall apply when applicable. 36
PURPOSE: FEMA is seeking technical support from contractors to ensure the Agency’s 38 effectiveness in executing its mission to provide transportable temporary housing. Contractors 39 will observe and provide recommendations for design and production processes to ensure that 40 FEMA receives high quality TTHUs that are ready for deployment when an incident occurs. 41 Throughout the TTHU lifecycle (from design through disposal), the contractor will investigate, 42 analyze, train and recommend changes when issues are discovered in the program. The Agency 43 understands that the results of these services will lead to better TTHUs. 44
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SCOPE: This contract shall encompass the following phases of the TTHU lifecycle: Design, 45 Production, Transportation, Storage, Use, and Deactivation/Disposal. During any of these 46 phases, the contractor may be called upon to review designs, production facilities, or individual 47 TTHUs to determine if there are any design, health/safety, or product issues related to 48 construction, transportation, operational, or environmental issues. The contractor shall conduct 49 forensic analysis and investigations, as required, to determine the root cause of defects, damages, 50 or failures. The contractor may also be tasked with other projects related to the goals of this 51 requirement. 52
Technical Requirements Overview: The contractor shall ensure that the TTHUs adhere to 53 established industry standards, FEMA contract requirements, the Uniform Federal Accessibility 54 Standards (UFAS), National Fire Protection Association (NFPA) standards, NFPA 13 D, and 55 other applicable regulations and standards. 56
The contractor shall have expertise in the manufactured home industry and shall be familiar with 57 various types of TTHUs. The contractor shall provide all labor, materials, tools, and equipment 58 (unless specified as government-provided property). 59
The contractor may have to work with or interact with state, local, tribal, territorial governments, 60 and their regulatory agencies, including but not limited to the following: 61
Building Inspection 62
Planning 63
Zoning 64
Law Enforcement 65
Fire Departments of Public Safety 66
For the contractor’s reference, when performing any function related to manufactured homes, or 67 travel trailers, the contractor must be aware that FEMA meets the needs of individuals with 68 access and functional needs. To meet these requirements all MHUs are built to meet the Uniform 69 Federal Accessibility Standards (UFAS) standards, which are the Federal Government’s 70 implementation of the Architectural Barriers Act (ABA), as amended (42 U.S.C. §4151 et seq.) 71 and Section 504 of the Rehabilitation Act (Rehab Act), as amended (29 U.S.C. §701). The ABA 72 requires facilities to be accessible to people with disabilities when they are designed, built, 73 altered, or leased with funds supplied by the Federal Government. The contractor shall 74 understand the requirements of UFAS since it is a key requirement for certain units. When 75 reviewing designs and overseeing production the contractor shall insure that units are built to 76 UFAS standards. The contractor must understand UFAS requirements and their implementation 77 in FEMA MHUs. 78
FEMA also has an internal policy that requires MHUs to be built with Residential Fire Sprinkler 79 Systems. The contractor shall insure that MHU designs and manufacturing meet FEMA’s 80
Technical Support Services Draft SOO- 3
Residential Fire Sprinkler Systems requirements. FEMA’s MHUs must comply with the 81 following National Fire Protection Association (NFPA) standards, as of 2021 or more recent: 82
NFPA 501—Standard on Manufactured Housing 83
NFPA 501A—Standard for Fire Safety Criteria for Manufactured Home Installations, 84 Sites, and Communities 85
NFPA 13D—Standard for the Installation of Sprinkler Systems in One- and Two-Family 86 Dwellings and Manufactured Homes 87
FEMA installs TTHUs for disaster survivors at the following locations: 88
Private sites—sites located on private land that either the disaster survivor or someone 89 known by the survivor owns. 90
Commercial sites—existing manufactured home parks operating as a commercial 91 business. 92
Group sites—FEMA-built manufactured home/travel trailer parks for disaster survivors. 93
For MHUs, the contractor may be required to consult with MHU vendors; HUD; HUD-approved 94 Production Inspection Primary Inspection Agencies (IPIAs) and Design-Approval Primary 95 Inspection Agencies (DAPIAs); State agencies and private third-party agencies that inspect 96 manufactured homes at various stages of production; FEMA storage sites; and FEMA 97 installation contractors. Information regarding the IPIAs can be found at 24 CFR 3282.362, and 98 information regarding the DAPIAs can be found at 24 CFR 3282.361. Some of the third-party 99 agencies also approve the manufacturer’s designs to ensure that plans are consistent with HUD 100 standards. There will be additional stakeholders that are included for other types of TTHUs. 101
PLACE OF PERFORMANCE 102
The place of performance will be at one or more of the following locations: 103
The Contractor’s facility 104
TTHU manufacturing facilities 105
FEMA Headquarters – 500 C Street SW Washington, DC 20024 106
FEMA’s Transportable Temporary Housing Units Storage Sites (TTHUs) – Cumberland, 107 MD and Selma, AL 108
FEMA’s Manufactured Housing Staging Areas (MHSAs) – In Disaster-Affected Areas 109
Other locations within the contiguous United States 110
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The Contractor shall be required to perform at some or all of the required tasks simultaneously at 111 multiple locations. 112
PERIOD OF PERFORMANCE: 113
The Period of Performance is one (1) twelve (12) month base period from the date of contract 114 award with four (4) one (1) year option periods. 115
PERFORMANCE OBJECTIVES, GOALS AND OUTCOMES 116
I. Overall Objectives 117
Personnel: The contractor shall provide qualified personnel with the proper skill sets 118 and experience and the required number of personnel to accomplish the performance 119 objectives. 120
Materials: The contractor shall provide all necessary supplies, spare materials, tools, 121 test equipment, consumables, hardware, software, automatic data processing 122 equipment, documentation, and other applicable properties (Unless otherwise directed 123 by FEMA). 124
Facilities: No facilities are required in this solicitation. 125
Organizational processes: The contractor shall provide internal controls, management 126 oversight, and supply support. 127
Reporting: The contractor shall provide applicable reports in formats agreed to by 128
FEMA. 129
II. Contract Objectives 130
This contract will support the TTHU Program by providing the following services through 131 each phase of the TTHU lifecycle: Design Phase 132
Current and future TTHU designs reviewed by the contractor are in compliance with 134 FEMA’s requirements in direct support of a FEMA TTHU mission or at other times 135 as required. 136
TTHU requirements enhanced to make the TTHUs easier to manufacture to help 138 improve current and future solicitations. 139
Production Phase 141
1. Adequate personnel to Perform in-plant inspections and monitoring of the quality 143 assurance program and manufacturing process 144
2. Forensic analysis and investigations of potential defects to determine the root cause 146
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3. Vendor’s proposed repairs are available for review 148
Storage and Use Phases 150
Obtain analysis of issues that have developed in TTHU program items and 152 corresponding methodology for repairs. 153
Obtain analysis of environmental, health and safety of TTHUs to determine if there 155 are any issues that could impact health or safety. 156
Obtain analysis of post-damage environmental, health and safety reviews of TTHUs. 158
Obtain analysis of post-event cases of a fire in a TTHU to determine cause. 160
Obtain analysis of post-event effectiveness of the residential fire sprinkler system. 162
Obtain analysis of post-event residential fire sprinkler systems and/or fire detection 164 systems for compliance with relevant FEMA’s contract requirements, HUD 165 Standards, FEMA NextGen MHU Additional Requirements, FEMA NextGen Design, 166 UFAS, NFPA 501, NFPA 501A, and NFPA 13D. 167
Review recommendations for any issues resulting from manufacturing, storage, 169 transportation, installation, or maintenance. 170
Obtain analysis of root causes of issues within TTHUs, such as fires, leaks, and all 172 other potential failures within TTHUs. 173
Ability to review failure mode analysis (FMA); failure mode and effects analysis 175 (FMEA); and/or failure mode, effect, and criticality analysis (FMECA) on 176 commercial or other program items. 177
Ability to review TTHU and associated systems performance reports. 179 Ability to review other technical support services for TTHU quality assurance and 181 forensic analysis, as needed. 182
III. Technical objectives 183
The contractor’s PWS shall propose services to accomplish the technical objectives of the 184 project, which include the following: 185
Reduction of the initial procurement and lifecycle costs of the units. 187 Improved quality of TTHUs. 188 Enhanced FEMA requirements. 189 Determine areas of improvement and recommend new technical requirements. 190
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Quality inspections. 191 Obtain analysis of causes for any defects in TTHUs. 192 Assurance of all work being performed without impacting FEMA milestones. 193 Documentation of procedures for managing the contract, including a Quality Control 194
Plan 195 Improvement of processes. 196 Assurance that manufacturers meet or exceed all FEMA, HUD, NFPA and RV 197 industry requirements. 198 Achieve improved performance, reliability, and reduced cost of the delivered service 199 throughout the life of this effort. FEMA anticipates a potential cost reduction after the 200 base year. 201
IV. Training Objectives 202
The contractor’s PWS shall propose technical support services to accomplish the program 203 objectives of the project which include: 204
Training for FEMA and USACE employees and, in some cases, contractor 205 employees who support the TTHU mission under other contracts. 206
Training to train-the-trainer programs for each training provided. 207 A purpose and opening for each training. 208 Clear key topics, related concepts and course/module timing. 209 Clear presentation techniques and materials. 210 Evaluation, assessment, and reflection for each training. 211 A Survey or Quiz that will be given at both the beginning and end of the training. 212
V. Program objectives 213
The objective of Transportable Temporary Housing Unit (TTHU) Program is to design, test, 214 manufacture [end item(s)] to satisfy the user's need/performance requirements. 215 The contractor’s PWS shall propose technical support services to accomplish the program 217 objectives of the project, which include the following: 218
Assist FEMA’s goal of providing high quality TTHUs to disaster survivors. 220 Assist FEMA’s goal of ensuring that manufacturers meet the contract requirements. 221 Assist FEMA with monitoring contract quality. 222 Determine the root causes of TTHU and related system deficiencies. 223 Reduce manufacturing and production cost. 224 Improve performance. 225 Assist FEMA’s goal of providing training courses and materials to FEMA personnel 226 and contractors as needed. 227
VI. Performance Work Statement Requirements 229
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The contractor shall provide a Performance Work Statement (PWS), which shall propose 231 how the contractor will perform the monitoring, inspections, reviews, analyses, and 232 investigations for review of TTHU designs; in-plant inspection and monitoring of TTHU 233 manufacturing; forensic analysis (root cause analysis); TTHU safety, health, and 234 environmental reviews; and review of FEMA’s TTHU requirements. 235
a) Review TTHU designs 236
The contractor’s PWS shall propose services to ensure that current and future TTHU 237 designs meet FEMA’s requirements, applicable regulations, and all required 238 certifications. Review of current designs shall include the review of specific elements of 239 existing TTHU designs and may include up to a full design review of existing TTHU 240 designs. Review of future designs shall include a full design review of future TTHU 241 designs and may include a full design review of other future TTHU designs. 242 At a minimum, the contractor shall: 244
Verify the TTHU designs’ compliance with established industry standards and 245 other applicable regulations and identify instances of non-compliance. 246
Verify that each vendor’s written quality assurance programs reflect best 247 practices and contain bona-fide methods for assuring homes can be built in 248 compliance with FEMA’s requirements and identify areas that require 249 improvement. 250
Identify areas of potential improvement for the TTHU designs. 251
Evaluate future changes proposed by the manufacturers for the FEMA NextGen 252 Designs and identify how the proposed changes will impact the quality, cost, 253 schedule, and risk for TTHUs. 254
Provide technical support (SMEs, etc.), as needed. 255
b) In-Plant Inspections and Monitoring of TTHU manufacturing 256
The contractor’s PWS shall propose services to ensure that the TTHU production 257 plant/facility and quality assurance and manufacturing processes are adequate, meet 258 applicable regulations, and have obtained all required certifications. Also, the contractor 259 shall provide services during production to ensure that the TTHU meets all applicable 260 FEMA requirements. 261
At a minimum, the contractor shall perform the following actions in the planning, 263 production, or post-production stages, as applicable: 264 Planning 266
Develop uniform monitoring/auditing procedures. 267
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Develop quality monitoring checklists. 268
Schedule audits 269
Recommend audit frequency based on quality data. 270
During Production 271
Conduct audits at each active TTHU plant. 272
Conduct audits of TTHUs while they are in production. 273
Prepare and analyze in-plant audit reports. 274
Ensure that manufacturer and other in-plant inspections are occurring in 275 accordance with FEMA’s quality procedures and the manufacturer’s Quality 276 Control Plan 277
Review and evaluate the TTHU factory processes. 278
Review and evaluate the TTHU production line. 279
Perform inspections of the factory to ensure the manufacturers have adequate 280 quality control. 281
Identify any issues that could impact the manufacturer capacity of production. 282
Identify any issues that could lead to quality or performance issues. 283
Evaluate and analyze if the manufacturer is continuously following all provisions 284 and aspects of its approved quality assurance manual. 285
Evaluate and ensure any and all parts of the TTHU conform with the FEMA 287 requirements. 288
Evaluate TTHUs in production that fail to conform with the design or standard; 290 ensure that the failure to conform is corrected before the TTHU leaves the 291 manufacturing plant. 292
Ensure the manufacturer’s inspections are effective. 294
Post-Production 296
Conduct post-production audits. 298 Conduct post-production follow up audits/consumer sites. 299 Evaluate and ensure any and all parts of the TTHU conform with the FEMA 300 requirements. 301
Technical Support Services Draft SOO- 9
All Stages 302
Provide recommendations for changes and enhancements. 303 Monitor compliance with regulations and the FEMA requirements. 304
Reporting all findings and results to the COR and other designated government 305 officials 306
Monitor compliance with regulations and the FEMA requirements. 307
Refer all issues of non-compliance to the government representative. 308
Perform inspections in accordance with the offeror’s written procedures. 309
c) Forensic analysis (Root Cause Analysis), investigations and Technical Assistance. 310
The contractor’s PWS shall propose technical support services to perform forensic 311 analysis (root cause analysis) and investigations during the period of performance. 312 At a minimum, the contractor shall 314
Perform root cause problem analysis for issues that may arise before, during, and 315 post-production. 316
Find and propose a solution/alternative to issues/problems. 317
Maintain records of issues, including but not limited to the cause, manufacturer, 318 resolution, and mitigation strategy for use in future contracts. 319
Perform inspections in support of forensic analysis of the factory to ensure the 320 manufacturers have adequate quality control. 321
Maintain records of important conversations/meetings. 322
Provide technical expertise to assist the government when non-compliance 323 occurs. 324
Propose recommendations for solutions to non-compliance or other issues by the 325 manufacturer and provide feedback to the government representative. 326
Work with the government representative to carry out inspections and other 327 investigations. 328
Analyze new technical issues. 329
Coordinate with the IPIA, DAPIA, the government representative, and 330 manufacturers to facilitate satisfactory resolution of any issues that may occur. 331
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Conduct design and instruction review to evaluate and make recommendations 332 on each special request. 333
Coordinate and assist the review of special alternative construction proposals that 334 may be needed to build manufactured homes that are not in conformance with 335 one or more HUD Standards. 336
Assist with all follow-up monitoring and assessment activities, including site 337 investigation, records reviews, and telephone discussions 338
Perform environmental analysis. 339
d) TTHU Safety, Health, and Environmental Reviews 340
The contractor’s PWS shall propose technical support services to execute and deliver 341 comprehensive industrial hygiene, safety, and environmental health to ensure TTHUs do 342 not adversely affect the well-being of disasters survivors. 343 At a minimum, the contractor shall: 345
Be a subject matter expert (SME) and possess experience with conducting 346 occupational safety, safety engineering, industrial hygiene, or environmental 347 health evaluations. 348
Develop applicable sampling strategies for performing area, personal, baseline, 349 and ambient air monitoring for chemicals and other hazards as identified in 350 sampling strategies, hazard assessments, or historical background. 351
Perform third party quality assurance and quality control development, including 352 oversight and review of occupational safety; safety engineering; industrial 353 hygiene and environmental health issues; and projects or concerns. 354
Develop applicable sampling strategies for collecting and analyzing air and 355 surface samples for contaminants not commonly associated with baseline indoor 356 air quality or environmental evaluations, such as volatile organic compounds 357 (VOCs), formaldehyde, hydrogen sulfide, carbon disulfide, carbonyl sulfide, and 358 others as requested. 359
Conduct indoor air quality assessments, hygiene assessments, and 360 mold/microbial growth assessments of the FEMA TTHUs 361
Have industry recognized certifications and capability to perform applicable 362 studies. 363
Possess adequate equipment to perform industrial hygiene, safety, and 364 environmental health evaluations of TTHUs. 365
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Maintain, store, and share data gathered during assessments and evaluations, 366 including written reports, environmental readings, facility/building 367 characteristics, and other applicable parameters. 368
Analyze data and provide written technical reports with data interpretation and 369 recommended courses of action. 370
Evaluate TTHUs for recognized hazards, including but not limited to, asbestos-371 containing materials, lead-based paint, or radon. 372
Conduct fire protection assessments, including but not limited to life safety 373 assessments, fire suppression system evaluations, and compliance evaluations 374 with other fire protection standards. 375
Conduct other safety and environmental health related activities, as assigned. 376
Perform inspections on TTHUs to ensure they meet safety, health, and 377 environmental applicable standards. 378
Provide final results and recommendations of the studies performed. 379
Provide recommendations for corrective actions to ensure TTHUs are in 380 compliance with applicable environmental, safety, and health standard. 381
Conduct environmental assessments of units if there is damage (e.g., from water 382 intrusion). 383
e) Review FEMA’s TTHU requirements 384
The contractor’s PWS shall propose technical support services to enhance current 385 requirements to obtain high quality, cost-effective units. 386 At a minimum, the contractor shall 388
Review FEMA requirements 389
Develop new technical requirements to be provided to FEMA for consideration 390 for future use based on findings of monitoring and inspection activities. 391
Document lessons learned and proposed new requirements. 392
Research issues, using existing information to the greatest extent possible, 393 regarding acceptance or new technologies, products, components, and designs to 394 determine conformance to existing standards. 395
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CONSTRAINTS 396
The services identified in this Statement of Objectives (SOO) shall adhere to the rules, 397 regulations, laws, standards, and conventions identified by FEMA as well as those within the 398 Federal Government. Constraints may include but are not limited to the following: 399
HUD generally implements the monitoring portion of its program through two sets of 400 regulations: 401
(1) 24 CFR 3280—Manufactured Housing Construction and Safety Standards (the 402 Standards), which is a nationally preemptive set of standards for the design and 403 construction of these homes (commonly known as HUD Code) 404
(2) 24 CFR 3282, Manufactured Housing Procedural and Enforcement Regulations 405 (the Regulations), which generally govern the enforcement of the HUD Code. 406
The National Manufactured Housing Construction and Safety Standards Act of 1974 407 (the Act), implemented in June 1976—located on HUD’s website. 408
Established industry standards for other TTHUs, including the consensus standards 409 promulgated by the Recreational Vehicle Industry Association (RVIA) 410
Due to the nature of the requirement, the contractor shall expect changes in the industry 411 that may occur during the course of performance, including but not limited to: 412
The quality, number of plants, and production totals of TTHUs 413
The number of design packages and drawings generated. 414
The type of TTHUs and applicable standards required. 415
The frequency and extent of natural disasters 416
The type and numbers of post-design or post-production problems experienced in 417 the field. 418
Problems with the quality control operations, which could require increased or 419 shifted monitoring and audits. 420
Special factory, retailer, transport, installation, or site inspection issues 421
New regulations or statutory requirements. 422
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ADDITIONAL DETAILS 423
1. Certifications 424
All employees conducting system analysis and compliance assurance shall possess and 425 maintain current professional certifications in accordance with ASTM E-541 during the 426 execution of this contract. 427
All compliance assurance auditors are to be certified as quality auditors by the American 428 Society of Quality (ASQ) or have demonstrated experience. 429
QUALITY ASSURANCE SURVEILLANCE PLANS 430
Offerors shall include their Quality Assurance Surveillance Plan (QASP) as part of their 431 proposal. These plans shall focus specifically on the following three areas: 432
How the contractor will ensure the quality of forensic investigations of TTHUs post-433 delivery of units 434
How the contractor will ensure quality in the level of services they are providing 435 How the contractor will use metrics or standards to determine if the contract, technical 436 work, program objectives, and contract/task order objectives are met 437
ORGANIZATIONAL AND PERSONAL CONFLICTS OF INTEREST (OCI/PCI) PLAN 438
Contractors shall provide a written code of business ethics and conduct applicable to contractor 439 personnel working on this technical support services contract to 440
Prohibit contractor personnel from participating in a government contract in which they 441 have a personal conflict of interest. 442
Require contractor personnel to avoid the appearance of loss of impartiality in 443 performing contracted duties for FEMA. 444
Require contractor personnel to disclose personal conflicts of interest to their employer 445 prior to beginning work on this contract. 446
Require the contractor to review and address any personal conflicts of interest its 447 employees might have before assigning them to deliver contracted services. 448
Prohibit contractor personnel from using non-public government information obtained 449 while performing work under the contract for personal gain. 450
Prohibit contractor employees providing procurement support services from having 451 future employment contact involving a bidder in an ongoing procurement. 452
Impose limits on the ability of the contractor organization and its employees to accept 453 gifts (defined as almost anything of monetary value, such as cash, meals, trips, or 454 services) in connection with contracted duties. 455
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Prohibit misuse of FEMA contract duties to provide preferential treatment to a private 456 interest. 457
Report any contractor personal conflict of interest violations to the applicable 458 contracting officer or contracting officer’s representative as soon they are identified. 459
Maintain effective oversight to verify compliance with personal conflict of interest 460 safeguards; have procedures in place to screen for potential conflicts of interest for all 461 employees in a position to make or influence findings, recommendations, and decisions, 462 regarding FEMA contracts and other quality control and assurance functions. This 463 screening can be done on a task-by-task basis or on an annual basis, such as a financial 464 disclosure statement. 465
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