Attachment 1 IPIA PWS .pdf

Attachment 1 – Performance Work Statement (PWS) Solicitation 86615624R00002 IPIA and SAA Monitoring and Inspection Services

Performance Work Statement (PWS)

Manufactured Housing In-Plant Primary

Inspection Agency (IPIA) and State

Administrative Agency (SAA) Monitoring and Inspection Services

6/11/2024

Version 2.0

Vision Statement

1 General Information

1.1 Scope of Work

1.2 Background

1.3 Constraints

1.4 Non-Personal Services

1.5 Period of Performance

1.6 Place of Performance

1.7 Hours of Operation

1.8 Special Qualifications

1.9 Post Award/Kickoff Conference

1.10 Status Meetings

1.11 Contractor Travel

1.12 Transition In

1.13 Transition Out

2 Definitions and Acronyms

2.1 Definitions

2.2 Acronyms

3 Government-Furnished Property and Services

3.1 Government Services

3.2 Facilities

3.3 Equipment

3.4 Materials and Information

3.5 Quality Assurance (QA)

4 Contractor-Furnished Items and Services

4.1 Facilities

4.2 Equipment

4.3 Materials

4.4 Contractor Responsibilities

4.5 Contractor Personnel

4.6 Identification of Contractor Employees

5 Specific Tasks

5.1 Management and Administration

5.2 IPIA Monitoring

5.3 SAA Monitoring

5.4 Ancillary Services

6 Deliverables

6.1 Quality Control Plan

6.2 Acceptance Criteria

7 Related Documents

8 Performance Requirements Summary

Vision Statement

To successfully ensure compliance with the National Manufactured Housing Construction and Safety (MHCSS) Act of 1974 (amended by the Manufactured Housing Improvement Act of 2000) and monitor the activities of all private in-plant primary inspection agencies and state administrative agencies approved by HUD in accordance with all standards and regulations.

1 General Information

1.1 Scope of Work

The Department of Housing & Urban Development (HUD), Office of Manufactured Housing Programs (OMHP) requires contractor support to assist with performing all monitoring responsibilities outlined in the MHCSS Act. Monitoring activities include inspections and assessments of the private and state agents who are responsible for inspections, and oversight of the manufacturer’s adherence to their quality assurance programs of manufactured housing (In plant Production Primary Inspection Agency functions) as well as enforcement of notification and correction campaigns and related recordkeeping pursuant to Subpart I of the Regulations (State Administrative Agency functions).

Detailed descriptions of specific tasks are provided in Section 5 – Specific Tasks and Deliverables.

1.2 Background

The National Manufactured Housing Construction and Safety Standards Act of 1974 (the Act), implemented in June 1976, established the framework for HUD’s development and implementation of the federally preemptive manufactured housing construction program. The Act, as amended by the Manufactured Housing Improvement Act of 2000 sets forth authority for HUD to develop and enforce federal manufactured housing construction and safety standards.

Through HUD’s manufactured housing program, unsubsidized affordable housing is available for many families who might otherwise not be able to afford home ownership. Approximately eight (8) million manufactured homes have been built under HUDs Manufactured Housing Construction and Safety Standards Program since 1976. About 50 companies produce manufactured housing in 146 plants (production lines) with current production of about 100,000 floors per federal fiscal year.

HUD administers the program, supported by agreements with thirty-three (33) State Administrative Agencies (SAAs) and various Contractors. Agreements with the states are between HUD and the SAA. In addition to 33 SAAs and HUDs Contractors, there are currently six (6) Design Approval Primary Inspection Agencies (DAPIAs)and twelve (12) IPIAs, both public and private, approved by HUD to conduct design reviews and in-plant surveillance, respectively. Eight (8) of the thirteen (13) active HUD-approved agencies are units of State government and the remaining five (5) are private for-profit corporations.

Each manufacturer must obtain the services of a DAPIA. The DAPIA is responsible for ensuring that designs conform to the requirements of the Standards and incorporate acceptable engineering practices. All designs and design changes must be approved by a manufacturer’s DAPIA that also approves each plant’s quality assurance manual.

Each manufacturer must also obtain the services of an IPIA. The IPIA must determine that the plants under its purview can produce homes in conformance with the Standards on a continual basis and issue a certification. After the certification, the IPIA is responsible for monitoring the implementation and effectiveness of the manufacturer’s quality control program through surveillance and inspections of each home at some stage of production. If the IPIA is satisfied, it may issue the HUD-required certification labels that are attached to each section of each home upon completion. Combined, the IPIAs certify and provide ongoing surveillance at all active manufacturing plants.

Each SAA with manufacturers in state have responsibilities to approve and monitor manufacturer systems for compliance 24 CFR 3282 Subpart I in addition to responsibilities for handling consumer complaints. Each SAA without manufacturers in state have responsibilities for handling consumer complaints (i.e., forwarding complaints to the manufacturer and to the SAA in the state of manufacturer, and or HUD if there is no SAA).

1.3 Constraints

The services identified in this PWS will adhere to the rules, regulations, laws, standards, and conventions identified by Housing and Urban Development as well as within the Federal Government. Constraints include the following:

HUD generally implements the monitoring portion of its program through the following Statute and regulations:

• The National Manufactured Housing Construction and Safety Standards Act of 1974 (the Act), implemented in June 1976, and the 2000 amendments are located on Housing and Urban Development website:

https://portal.hud.gov/hudportal/documents/huddoc?id=uscode2012ti.pdf .

• 24 CFR 3280, Manufactured Housing Construction and Safety Standards (the Standards), which is a nationally preemptive set of standards for the design and construction of these homes (commonly known in this industry as the Housing and Urban Development Code); eCFR :: 24 CFR Part 3280 -- Manufactured Home Construction and Safety Standards and

• 24 CFR 3282, Manufactured Home Procedural and Enforcement Regulations (the Regulations), which generally govern the enforcement of the HUD Code eCFR :: 24 CFR Part 3282 -- Manufactured Home Procedural and Enforcement Regulations.

The list of DAPIAs, IPIAs and SAAs, can be found on HUD’s website with the following links:

Inspection Agencies: List of IPIAs and DAPIA's - HUD | HUD.gov / U.S. Department of Housing and Urban Development (HUD) State Administrative Agencies (How and Where to File a Complaint) | HUD.gov / U.S.

Department of Housing and Urban Development (HUD) https://www.ecfr.gov/current/title-24/subtitle-B/chapter-XX/part-3280 https://www.ecfr.gov/current/title-24/subtitle-B/chapter-XX/part-3280 https://www.ecfr.gov/current/title-24/subtitle-B/chapter-XX/part-3282 https://www.ecfr.gov/current/title-24/subtitle-B/chapter-XX/part-3282 https://www.hud.gov/program_offices/housing/rmra/mhs/csp/mhsid https://www.hud.gov/program_offices/housing/rmra/mhs/csp/mhsid https://www.hud.gov/program_offices/housing/rmra/mhs/csp/mhssaa https://www.hud.gov/program_offices/housing/rmra/mhs/csp/mhssaa

1.4 Non-Personal Services

The Government will neither supervise Contractor employees nor control the method by which the Contractor performs the required tasks. Under no circumstances shall the Government assign tasks to, or prepare work schedules for, individual Contractor employees. It shall be the responsibility of the Contractor to manage its employees and to guard against any actions that are of the nature of personal services or give the perception of personal services.

If the Contractor believes that any actions constitute, or are perceived to constitute personal services, it shall be the Contractor's responsibility to notify the Contracting Officer (CO) immediately. These services shall not be used to perform work of a policy, decision making, or management nature, i.e., inherently Government functions. All decisions relative to programs supported by the Contactor shall be the sole responsibility of the Government.

1.5 Period of Performance

The Period of Performance shall be for one (1) Base Period of 12 months and four (4) 12-month Option Period(s), if exercised.

1.6 Place of Performance

The services to be performed under this contract shall be performed at the Contractor’s facility.

1.7 Hours of Operation

Not applicable.

1.8 Special Qualifications

The Contractor is responsible for ensuring all compliance assurance auditors in a lead or primary auditor position are certified quality auditors or quality engineers by the American Society of Quality (ASQ).

1.9 Post Award/Kickoff Conference

The Contractor shall attend any post award conference convened by the contracting activity or contract administration office in accordance with FAR Subpart 42.5 (eCFR :: 48 CFR Part 42 Subpart 42.5 -- Postaward Orientation (FAR Part 42 Subpart 42.5))and HUD Acquisition Regulation (HUDAR) clause 2452.237-79 - Post Award Conference (HUDAR | HUD.gov / U.S.

Department of Housing and Urban Development (HUD)).

1.10 Status Meetings

The Contracting Officer, Contracting Officers Representative (COR), and other Government personnel, as appropriate, may meet periodically with the Contractor to also review Contractor performance, requirement status, etc. At these meetings, the Contracting Officer will apprise the Contractor of how the Government views the Contractor's performance or progress of the requirement. The Contractor will apprise the Government of problems, if any, being experienced. Appropriate action shall be taken to resolve outstanding issues. These meetings shall be at no additional cost to the Government. Post Award Conference and subsequent meetings may be held via teleconference at the Contracting Officer's discretion.

https://www.ecfr.gov/current/title-48/chapter-1/subchapter-G/part-42/subpart-42.5 https://www.ecfr.gov/current/title-48/chapter-1/subchapter-G/part-42/subpart-42.5 https://www.hud.gov/program_offices/cpo/hudar#part_2452.2 https://www.hud.gov/program_offices/cpo/hudar#part_2452.2

1.11 Contractor Travel

Prior to travel, the Contractor shall coordinate with and receive Government authorization from the COR for all travel. Reimbursement of travel costs will be in accordance with the Federal Travel Regulation and in accordance with FAR 31.205-46 (eCFR :: 48 CFR Part 31 -- Contract Cost Principles and Procedures (FAR Part 31).

1.12 Transition In

The Contractor shall, upon the Contracting Officer's written notice, furnish Transition-In services as required. As a successor, the Contractor shall have sufficient personnel on board during the 60-day Transition-In period to ensure a smooth transition with the incumbent Contractor. The Contractor shall provide an orderly transition of work acceptance and accomplishment such that any impact to the program is minimized. During the Transition-In period, the Contractor shall become familiar with the requirements in order to commence full performance of services by the end of the contract Transition-In period. Transition-In is not required if the successor Contractor is the incumbent Contractor.

1.13 Transition Out

To minimize any decrease in productivity and to prevent possible negative impacts on additional services, the Contractor shall have sufficient personnel on board during the 60-day Transition- Out period. The incumbent Contractor shall ensure a smooth transition with the successor Contractor during the Transition-Out period, prior to completion of contractual performance. The incumbent Contractor shall aid the successor in the development of plans, procedures, and methods for the assumption of all on going work. The Contractor shall provide an orderly transition of work acceptance and accomplishment, such that full control by the successor Contractor is achieved by the end of the new contract Transition-In period.

2 Definitions and Acronyms

2.1 Definitions

Business Day - Every official day of the week which are days between and including Monday to Friday. This does not include federal holidays and weekends.

Calendar Day - Any day of the week.

Contractor - A supplier or vendor awarded a contract to provide specific supplies or service to the Government. The term used in this contract refers to the prime.

Contracting Officer (CO) - A person with authority to enter, administer, and/or terminate contracts and make related determinations and findings on behalf of the Government. Note: the only individual who can legally bind the Government.

Contracting Officer's Representative (COR) - An employee of the U.S. Government appointed by the Contracting Officer to perform contract administration activities in regard to technical issues. This individual has authority to provide technical direction to the Contractor as long as direction is within the scope of the contract, does not constitute a change, and has no https://www.ecfr.gov/current/title-48/chapter-1/subchapter-E/part-31?toc=1 https://www.ecfr.gov/current/title-48/chapter-1/subchapter-E/part-31?toc=1 funding implications. This individual does NOT have the authority to change the terms and conditions of the contract.

Deliverable - Anything that can be physically or electronically delivered but may include non-manufactured things such as meeting minutes or reports.

Manufacturer - Any person engaged in manufacturing or assembling manufactured homes, including any person engaged in importing manufactured homes for resale.

Manufactured Home - A structure, transportable in one or more sections, which in the traveling mode is 8 body feet or more in width or 40 body feet or more in length or which when erected on-site is 320 or more square feet, and 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.

Performance Requirements Summary (PRS) - A listing of the performance requirements under the contract that are to be evaluated by the Government on a regular basis, performance indicators for these requirements, performance standards for these requirement and surveillance methods to be used to determine if performance standards are met.

Performance Standard - The Contractor's performance level required by the Government.

Performance Work Statement (PWS) - A statement of work for performance-based acquisitions that describes the required results in clear, specific, and objective terms with measurable outcomes.

Physical Security - Actions that prevent the loss or damage of Government property.

Primary Inspection Agency (PIA) - A State/or private organization that has been accepted by the Secretary in accordance with the requirement of subpart H of 24 CFR 3282.

In Plant Production Inspection PIA (IPIA) - An agency that evaluates the ability of manufactured home manufacturing plants to follow approved quality control procedures and provides ongoing surveillance of the manufacturing process. Organizations may act as one or both of these types.

Quality Assurance (QA) - Policies and procedures adopted by the Government to ensure that supplies and services acquired under Government contracts conform to the contracts quality requirements.

Quality Assurance Surveillance Plan (QASP) - A plan describing how the agency will survey, observe, test, sample, evaluate, and document the Contractor's performance in meeting critical performance standards identified in the contract.

Quality Control (QC) - All necessary measures taken by the Contractor to assure that the quality of an end product of service shall meet contract requirements.

State Administrative Agency (SAA) - An agency of a State which has been approved or conditionally approved to carry out the State plan for enforcement of the standards pursuant to section 623 of the Act, 42 U.S.C. 5422, and subpart G of 24 CFR 3282.

State plan application - An application of any State organization which is submitted to the

Secretary for approval as a State Administrative Agency under subpart G of 24 CFR 3282.

Subcontractor - Any person, other than the prime Contractor, who offers to furnish or furnishes any supplies, material, equipment, or services of any kind under a prime contract or a subcontract entered into in connection with such prime contract, and any person who offers to furnish or furnishes general supplies to the prime contractor or a higher tier subcontractor. The

Government does not have privity of contract with a subcontractor.

Work Week - Monday through Friday, unless specified otherwise.

2.2 Acronyms

AC - Alternative Construction

ASQ - American Society for Quality

ASTM – American Society for Testing and Materials

AQL - Acceptable Quality Level

CFR - Code of Federal Regulations

CO - Contracting Officer

COR - Contracting Officer's Representative

CCI - Computer Coded Items

CPO - Chief Procurement Officer of HUD (Office of)

CQA - Certified Quality Auditor

CQE - Certified Quality Engineer

DAPIA - Design Approval Primary Inspection Agency

EST - Eastern Standard Time (U.S.)

FAR – Full Acceptance Report

HUD - U.S. Department of Housing and Urban Development

HUDAR - HUD Acquisition Regulation https://www.govinfo.gov/link/uscode/42/5422

IPIA - In-Plant Primary Inspection Agency

IPR - IPIA Performance Review

MHCC – Manufactured Housing Consensus Committee

OCPO - Office of the Chief Procurement Officer

PM - Project Manager

POC - Point of Contact

POCA - Plan of Corrective Action

QA - Quality Assurance

QAM - Quality Assurance Manual

QASP - Quality Assurance Surveillance Plan

QCP - Quality Control Plan

QSI - Quality System Issues

RRR - Routine Representative Reviews

SAA - State Administrative Agency

SC – Site Construction

SMA - SAA Monitoring Assessment

STI - Standards Training and Inspection

TBD - To be determined

U.S.C - United States Code

3 Government-Furnished Property and Services

The Contractor shall ensure accurate control and accountability of all Government-Furnished Property in accordance with the terms and conditions of this contract.

3.1 Government Services

Government services will not be provided.

3.2 Facilities

Government facilities will not be provided.

3.3 Equipment

Government equipment will not be provided.

3.4 Materials and Information

The Government shall provide the following materials and information: electronic access to HUD Standards, Regulations, and other information pertaining to oversight, monitoring and enforcement of manufactured home production and design, including historical operating procedures. All materials will remain the property of the Government and will be returned to the Contract Officer Representative upon request or at the end of the contract period.

3.5 Quality Assurance (QA)

The Government shall evaluate the Contractor's performance under this contract in accordance with the Quality Assurance Surveillance Plan. This plan is primarily focused on what the Government must do to ensure that the Contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance, and the minimum acceptable quality level.

4 Contractor-Furnished Items and Services

The Contractor shall furnish, all facilities, equipment, and supplies required to perform the work under this contract that are not listed under Government-Furnished Property and Services.

4.1 Facilities

The Contractor shall furnish all facilities required to perform the services stated within this PWS.

4.2 Equipment

The Contractor shall furnish all equipment required to perform the services stated within this

PWS.

4.3 Materials

The Contractor shall furnish all materials required to perform the services stated within this

PWS.

4.4 Contractor Responsibilities

The Contractor shall only conduct business with designated Government personnel listed as points of contact (POCs). Names of authorized personnel shall be provided to the Contractor by the Government, in writing, and updated as necessary throughout the contract period of performance.

U.S. Government records, copies of original results and reports, verified original data, corrected data, and corrected supporting final reports which are maintained by the Contractor remain the property of the U.S. Government. These files/results must be surrendered to the COR.

4.5 Contractor Personnel

See HUDAR clause 2452.237-70 - Key Personnel in the Key Personnel section of the contract.

4.6 Identification of Contractor Employees

All Contractor/subcontractor personnel shall wear company picture identification badges as to distinguish themselves from Government employees. When conversing with Government personnel during business meetings, over the telephone, or via electronic mail, Contractor/subcontractor personnel shall identify themselves as such to avoid situations arising where sensitive topics might be better discussed solely between Government employees.

Contractors/subcontractors shall identify themselves on any attendance sheet or any coordination documents they may review. Electronic mail signature blocks shall identify their company affiliation. Where practicable, Contractor/subcontractors occupying collocated space with their Government program customer shall identify their workspace area with their name and company affiliation, or at a minimum, "Contractor" after name.

5 Specific Tasks

5.1 Management and Administration

5.1.1 Transition-In Plan

The Contractor shall provide a Transition Plan. The plan will assist the Department, at the end of the contract, in assuming or overseeing the transfer of all files maintained by the Contractor.

The plan shall include the proposed schedule and key steps for transition. At a minimum, the proposed schedule and key steps of the transition plan shall include, but are not limited to:

• Meeting with current Contractor, new Contractor, and HUD staff to discuss background, history, project status, operational rules;

• Transition of appropriate paper records, files, data and related hard copy data;

• Transition of appropriate electronic file and data;

• Meeting with current Contractor, New Contractor, and HUD staff to finalize transition, and close out any other outstanding items.

Within six weeks of contract award, the Contractor shall provide HUD with a Transition Plan outlining the specific transition steps to be taken, the materials to be transferred, and the schedule for transfer.

After the completion of HUD’s review of the transition-in plan, HUD will discuss any concerns with the Contractor then provide approval of the plan.

Performance Standards

a) Standard: Transition-In plan due within six weeks after contract award.

AQL: Zero deviation Deliverables

A001 Transition-In Plan

5.1.2 Management Work Plan

The Contractor shall provide an annual management work plan that addresses each of the required activities of this scope of work. The plan shall address all activities and shall contain timelines, deliverable due dates, and a summary of key personnel responsible for delivery. The Contractor shall ensure that its plan addresses resources necessary to deliver data and reports that are easy to follow and well organized. Due to the nature of the requirement, the Contractor shall expect changes in the industry that may occur during the course of performance. These variables may include:

• The number of plants and production totals of manufactured homes;

• The type and numbers of post-design or post-production problems experienced in the field;

• The frequency and extent of natural disasters;

• Number of agencies requiring monitoring and inspection; and

• Special factory, retailer, transport, installation, or site inspection issue.

The completion of these task activities may require travel in the continental United States as well as Alaska, Hawaii, Mexico, Canada, or the US territories.

A plan shall be submitted within 10 business days of contract award. HUD will review the plan and discuss any concerns with the Contractor. A plan for each option period shall be submitted at least 30 business days prior to the expiration of the preceding period of performance.

Note: Annual plans shall be treated as living documents that may need to be updated and resubmitted for HUD’s approval, as needed throughout a contract year.

Performance Standards

a) Standard: Management Work Plan submitted within 10 business days of contract award.

AQL: Zero deviation

Deliverables A002 Management Work Plan

5.1.3 Monitoring Procedures

The Contractor shall prepare uniform procedures and checklists to be followed by its project resources for all activities addressed in the PWS. The procedures used must contain criteria by which the Contractors monitoring teams can perform a reasonable and uniform evaluation of the IPIAs surveillance of manufacturer quality assurance program in each manufacturing plant, adequacy of manufacturer records, and the effectiveness of the IPIA and SAA performance.

The Contractor shall develop procedures for Contractor audit teams to follow in monitoring quality control systems and determining compliance to the Standards and Regulations in manufactured housing plants. The Contractor shall propose methods of monitoring IPIA and SAA performance through auditing activities by using one or two person teams comprised of quality auditors and other qualified personnel. Use of one-person audits must be justified by the Contractor and approved by HUD. The procedures shall also provide for a process by which all reports, letters, and other correspondence involving technical issues affecting a number of parties will be digitally imaged for storage and distribution. HUD must review and approve these procedures before use by the Contractor.

Initially, the Contractor may utilize historically developed procedures to conduct the IPIA and SAA monitoring. These historical procedures have included the following documents:

• Computer Coded Items (CCI) Guidelines,

• Standards Training and Inspection (STI) Guidelines,

• Quality System Issues (QSI) Guidelines,

• State Monitoring Assessment procedures, and

• Manufacturer Record Review Procedures.

The Contractor shall submit the draft monitoring procedures within 30 business days of contract award. After HUD’s review of the procedures, the Contractor shall provide the final monitoring procedures to HUD for approval within 10 business days of receiving HUD’s comments.

The Contractor shall review and update the procedures and checklists at least annually and provide an opportunity for the IPIAs and/or SAAs to review and comment on any major revisions to the procedures and organize necessary teleconferences or meetings to discuss revisions. All comments received are to be evaluated by the Contractor and necessary modifications shall be recommended to HUD. Copies of the HUD-approved procedures and guidelines are to be provided to the IPIAs and/or SAAs, upon request.

Performance Standards

a) Standard: Submit the draft monitoring procedures within 30 business days of contract award.

AQL: Zero Deviation

b) Standard: Submit final monitoring procedures to HUD within 10 business days of receiving HUD’s comments.

AQL: Zero deviation

A003 Monitoring Procedures

5.1.4 Contract Status Meetings

The Contractor shall be readily accessible to the PM, CO, COR, and other appropriate HUD personnel for scheduled monthly meetings (TBD) at HUD Headquarters in Washington, D.C., and for any impromptu meetings that shall arise to brief the Department on contract activities, progress, and special issues. Some meetings may require in-person attendance. Consequently, phone, email communications, and video conferencing for some meetings will not be acceptable.

The purpose of these meetings is to brief the Department on contract activities, progress, and special issues and encourage clear and concise communication between HUD and the Contractor in making swift decisions and taking timely action. Certain decisions regarding safety or legal issues raised by stakeholders often must be made on short notice. Examples of stakeholders include manufacturers, suppliers, retailers, installers, Primary Inspection Agencies, State Administrative Agencies, representatives of the Manufactured Home Consensus Committee, Federal and State Governmental entities, consumers, and members of the public.

Some issues may require joint review of designs, plans, audit information, or similar data.

The Contractor shall provide a calendar of proposed monthly meeting dates within 30 calendar days of contract award.

Performance Standards

a) Standard: Attend Monthly Contract Status Meetings & provide a calendar of proposed monthly meetings within 30 calendar days of contract award.

AQL: Zero Deviation

5.1.5 Monthly Activity Report

Monthly, the Contractor shall provide a report on current data collected for all tasks in this PWS and is due five business days before the monthly contract status meeting. The report is to be provided electronically. The Department anticipates one report per month, reviewed during a monthly status meeting.

The monthly report shall include as attachments:

• A summary of finalized in-plant audit results, including an executive summary by the lead auditor and comments solicited from the IPIA headquarters after the audit. This summary is to recommend plants for follow-up and/or special audits. The monthly summary shall be arranged and indexed by the Contractor so that manufacturing plants with the highest recommendations for follow-up are first and then based on relative descending priority.

• An updated and accurate list of the names of all manufacturers that includes each manufacturing facility, locations, telephone numbers, dates of opening and closing, IPIAs and DAPIAs with their effective dates of service, current facility status, effective date, and most recent in-plant audit date and summary of audit results.

• A log of all disputes that have been referred to HUD.

• Other attachments as deemed appropriate by the Contractor.

The monthly activity report will be discussed during the monthly meeting.

Performance Standards

a) Standard: Provide Monthly Activity Report five business days before the monthly meeting AQL: Zero deviation

A004 Monthly Activity Report

5.1.6 Data Management and Security Plan

The Contractor shall provide HUD staff with electronic access to any data prepared, collected and maintained by the Contractor. The data shall be accessible using web-based technology or some other method that does not require configuration of HUD devices. The Contractor shall safeguard all data in relation to the requirements of this PWS. As result, work to be performed under this contract shall be segregated from all other work performed by the organization.

Further, the Contractor shall take proactive steps through a Nondisclosure and Confidentially agreement to separate work functions so as to not create conflicts of interests.

The Contractor shall provide a written description of its security plan within 10 business days of contract award and shall be consistent with the proposal submitted in response to this PWS.

The plan shall address data and system security, network security, application security, data security, quality control of data, reliability, server function and capacity, storage capabilities, back-up and recovery, off-site back-up requirements, electronic file transfer with other parties, and the procedures for HUD staff to view data and report information remotely. Support for off-site contract staff may include laptop computers and/or tablets and digital cameras suitable for inspection documentation and report preparation during field inspections

The plan shall also describe how the Contractor will manage data. The Contractor shall maintain an electronic file on each manufacturer, IPIA, audit, SAA, plan of corrective action, dispute, IPR, SMA, and record review.

Performance Standards

a) Standard: Data Management and Security Plan within 10 business days of contract award

A005 Data Management and Security Plan

5.1.7 State Participation on IPIA Monitoring Teams Conducting In-Plant Audits

States may participate in the Monitoring Program in accordance with 24 CFR 3282.308. The Contractor shall canvas SAA states to determine interest and capacity to provide personnel for participating in joint monitoring activities related to IPIA monitoring services. The Contractor can generally expect participation of up to 10 SAAs. For those SAAs expressing interest and having capacity, the Contractor shall secure agreements between the contract and the respective SAAs. Thereafter, SAAs may participate in the monitoring program. The Contractor shall pay states for the participation in accordance with the agreements. These payments should be included in the price proposal and is not a reimbursable item, however travel is reimbursable under the same guidelines as the contractor. These agreements are to be provided to HUD annually and include the following:

• an agreement with respect to the number of person-hours to be provided by the State for participation in IPIA monitoring teams organized by the Contractor. The agreement may call for as many qualified personnel as a State can provide. The Contractor shall determine annually whether any state personnel are qualified and shall only accept those that it determines to be qualified, in accordance with established criteria for selecting and evaluating in-plant audit personnel.

• a provision that upon termination of the contract between the Contractor and HUD, the Contractor’s rights under the agreement with the SAAs shall be assigned to HUD.

To the extent possible, state personnel shall participate in monitoring activities related to manufacturers that export manufactured homes to their States. Personnel from a SAA shall not participate on joint monitoring teams conducting audits at facilities within their States. Prior to involvement, the Contractor shall determine whether SAA personnel are qualified (per ASTM

E541 Standards) to participate, however, state personnel are not required to meet the Special Qualifications unless the personnel are used by the Contractor as lead-auditors. The Contractor shall provide a roster of state personnel that will assist in IPIA monitoring efforts, shall report on the status of state agreements and state personnel participation in each monthly activity report.

Deliverables A004 Monthly Activity Report A006 Roster of State Personnel

5.2 IPIA Monitoring

The Contractor, with data from its monitoring activities, shall make recommendations to HUD with respect to continued acceptance, disqualification, or requalification of each IPIA. The Contractor shall also provide recommendations for changes and enhancements that IPIAs shall make in their operations to improve services and maintain approval to function as an IPIA. The Contractor shall carry out inspections and other investigations on behalf of the Government. The Contractor shall also monitor the IPIAs compliance with applicable regulations, including the conflict-of-interest provisions in 24 CFR 3282.359 of HUD’s Manufactured Home Procedural and Enforcement Regulations. The Contractor shall refer all issues of noncompliance to HUD.

5.2.1 Schedule In-Plant Audits

The Contractor shall possess scheduling capabilities that will organize and coordinate all field audits with auditors, IPIAs, and SAAs. This scheduling capability shall be used to schedule audits to keep costs to a minimum, achieve uniformity by rotating auditors on a national basis, and staff the audit team based on availability and required experience of the auditors of each team, including providing for integration of SAA supplied personnel. Any scheduling conflicts shall be directed to the HUD Program Manager (PM) and Contracting Officer Representative (COR) for a decision.

The Contractor shall deliver proposed in-plant audit schedules and travel cost estimates to HUD at least 30 business days in advance of the start of a given month’s proposed audits. HUD will review and recommend changes or accept each month of audit activities and travel. The Contractor must obtain HUD’s approval prior to performing audits and travel. The Contractor shall provide the proposed in-plant audit schedule and travel estimate in the monthly activity report for the upcoming month at a minimum.

5.2.2 In-Plant Audits and Information Exchange

The Contractor shall perform in-plant audits to determine whether the IPIA is assuring that the following aspects of the manufacturing process are carried out (refer to 24 CFR 3282.362):

• the manufacturer is capable of following the quality control procedures set out in the quality assurance manual to be followed in the plant;

• the manufacturer is continuously following all provisions and aspects of its approved quality assurance manual;

• any part of the manufactured home that it actually inspects conforms with the design or that it conforms to the standards where the design is not specific;

• wherever it finds a manufactured home in production that fails to conform with the design or the standard, the failure to conform is corrected before the manufactured home leaves the manufacturing plant;

• if a failure to conform to the design standards is found in one manufactured home, all other homes still in the plant which the IPIAs record of the records of the manufacturer indicate might not conform to the design or standards are inspected, and if necessary, brought up to the design or standards before they leave the plant.

The Contractor, over the course of a determined review period (approximately one year) for each IPIA, shall conduct audits at manufactured home production facilities under each IPIAs surveillance. Approximately, 179 audits occur each year. The in-plant audits are performed in order to evaluate the effectiveness of an IPIAs inspection and surveillance activities and overall effectiveness of the IPIAs procedures and oversight. The Contractor's audit activities shall include inspection of homes, review of the effectiveness of the manufacturer’s quality control program and procedures, review of the IPIA and manufacturer inspection documents, information exchange as-needed, and post-production home inspections at retailer sites.

Audits are conducted in accordance with established written guidelines periodically modified by the Contractor and approved by HUD as outlined in Task 5.1.3. Audits require Contractor teams to enter a production facility for typically three business days to review the effectiveness of the IPIA's oversight and surveillance of all quality control and production operations in place at the facility. This includes review and inspection of testing procedures and equipment to determine if the IPIA is complying with applicable Standards and Regulations and an opportunity for information exchange during the last day of the audit.

The audit team also reviews the IPIAs inspection reports, the manufacturers quality assurance manual and quality control procedures to verify that all quality control inspections are being conducted by the manufacturer at each station and there is accountability by title and position of each person responsible for conducting inspections of completed work at each station, the station by station description in the QA manual accurately describes the production process, and also reviews training, service, and other records. Audits shall also evaluate the adequacy of the source of problems investigations identified and conducted by the manufacturer, IPIA and previous Contractor audits.

Historically, in-plant audits are comprised of the following types:

• Regular Audits - In-plant audits conducted to collect IPIA performance data that are not post-certification audits or follow-up audits. Approximately 150 audits per year.

• Post-Certification Audits - In-plant audits conducted within 30 business days after an IPIA certifies a new plant, takes over IPIA services for an existing plant, or updates an existing plant approval due to significant changes at existing facilities. These audits are performed to evaluate the effectiveness of the IPIAs plant certification and surveillance processes. Approximately 15 audits per year.

• Follow-Up Audits - In-plant audits conducted to monitor the IPIAs evaluation and implementation of remedial actions taken through a Plan of Corrective Action (POCA) and determinations made by manufacturers concerning homes with similar problems generally by reviewing appropriate records in accordance with Subpart I of the regulations (Subpart I investigation). Contractor teams shall review the remedial action records of manufacturers and IPIAs when conducting multi-day audits. Approximately 20 audits per year.

Note: Audit activities conducted at retailer sites under this task are for purposes of evaluating IPIA performance in connection with the manufacturing location where the in-plant audit is being conducted. Other types of audits at retailer sites are to be conducted separately and under other tasks as specified in the PWS.

The Contractor shall conduct in-plant audits at manufacturing plants (production lines) and compile a preliminary report at each audit to be left with the respective IPIA and manufacturer on the last day of the audit. The preliminary audit reports shall be provided to HUD within five business days of the last day of the audit for HUD’s review and acceptance.

Performance Standards

a) Standard: Submit preliminary audit report within five business days after last audit

A007 Preliminary In-Plant Audit Reports

5.2.3 Resolution of In-Plant Audits

In resolving each in-plant audit, the Contractor shall ensure that the IPIA responds to each in-plant audit and the Contractor shall carefully review the IPIA’s written response to audit findings to ensure that each audit issue can be closed out. Since there may be several communications between the Contractor and the IPIA before some audit findings are resolved, the Contractor’s final report to HUD shall contain a chronological sequence of the communications for each audit finding. If the IPIA does not respond in a timely manner, the Contractor shall follow up with a letter and/or phone call to expedite resolution.

The Contractor shall provide a final report to HUD along with its recommendation regarding whether a POCA is recommended within 15 business days after completion of the audit at the plant. The Contractor will be either notified that the report is acceptable or may be asked to address any feedback or comments provided by HUD before submitting a final report within five business days of receiving HUD’s comment. Once the report is approved by HUD, HUD may direct the Contractor to distribute the final report to all parties affected by the report.

Performance Standards

a) Standard: Submit final report with its recommendations to HUD within 15 business days after completion of the audit at the plant.

AQL: Zero Deviation

A008 Final In-Plant Audit Report

5.2.4 Handling Disputes

For any audit finding that cannot be resolved between the Contractor and the IPIA, the issue is to be sent to HUD as a “Dispute”. HUD will make a final determination, which both parties accept. The Contractor shall provide the dispute request to HUD with full documentation of the issue and position statements from all parties involved. Historically, 12 disputes are reported annually. Dispute reports shall be submitted to HUD within five business days of a request for dispute by the IPIA and after obtaining all support documentation for the disputed issue and a position statement from the IPIA. The intent of the dispute report shall be to provide all parties an opportunity to present their views. The dispute report also provides HUD with information and comments about disputes between IPIAs and the Contractor so that HUD can make an informed determination.

In addition to individual dispute records, the Contractor shall maintain a log of all disputes that have been referred to HUD. This log is to be provided monthly and is expected to allow HUD to easily identify the nature of an issue, the status of an issue (i.e., open or closed), the primary parties involved, and the outcome of the issue. The log shall be transmitted to HUD monthly and shall be an attachment to the monthly activity report.

Performance Standards

a) Standard: Submission of dispute reports within five business days of a receipt of a dispute AQL: Zero Deviation

Deliverables

A009 Dispute Report

5.2.5 IPIA Plant-Specific Plans of Corrective Action (POCA)

Upon acceptance of preliminary in-plant audit reports by HUD, the Contractor shall work to finalize each in-plant audit report and provide a recommendation as to whether the IPIA should be required to develop a plant-specific Plan of Corrective Action (POCA). Approximately, 30 POCAs are required annually. For each in-plant audit where the Contractor recommends and HUD agrees that a plant-specific POCA be developed by the IPIA, the Contractor shall provide a draft letter of the POCA request for HUD’s review, finalization, and issuance to the IPIA. Once HUD finalizes, the Contractor will forward the POCA letter to the IPIA within five business days.

The IPIA will be required to respond with a POCA addressing the concerns and recommendations identified by HUD. The Contractor shall review each POCA submitted by the IPIA and shall provide HUD with a written report containing its comments as well as any recommendations for performing a follow-up audit and any further actions HUD should require of the IPIA. These reports consist of a written analysis with comments addressing how adequately an IPIA has addressed HUD’s concerns and recommendations.

The Contractor shall review the POCA submitted by the IPIA and provide the analysis report to HUD within 10 business days of receipt of each plant-specific POCA. The Contractor will either be notified that the report is acceptable or may be asked to address comments provided by HUD. The Contractor shall forward a final report to HUD within five business days of HUD’s receipt of comments. Once the report is approved by HUD, HUD may direct the Contractor to distribute the report to all parties affected by the report. The Contractor shall maintain a tracking and filing system for all plant-specific POCAs and shall provide status reports of POCA-related actions on the monthly activity report.

a) Standard: Request letter for POCA to IPIA within five business days of HUD approval AQL: Zero Deviation

b) Standard: Analysis report of POCA to HUD within 10 business days of receipt from the IPIA

A010 Plant-Specific POCA Analysis Report

5.2.6 Post Production Follow-Up Audits/Consumer Sites

The Contractor shall conduct post-production inspections of homes at retailer lots and/or consumer sites to follow-up on in-plant audit findings or to evaluate the IPIA’s performance for responsibilities under Alternative Construction or On-Site Construction approvals.

Approximately, 20 post production inspections occur annually. The Contractor shall coordinate the inspections with HUD, the SAA, the manufacturer, and when appropriate, the retailer and/or homeowner. The Contractor shall share results of the inspection with the IPIA, SAA, retailer, and homeowner, as appropriate, and as any technical issues are resolved.

These audits are in addition to any inspections that are typically conducted in conjunction with in-plant audits (refer to Task 5.2.2). The Contractor shall prepare a post-production preliminary audit report to be submitted to HUD for review and acceptance. The Contractor will be either notified that the report is acceptable or may be asked to address any feedback or comments before submitting a final report within five business days of receiving HUD's comment. Once the report is approved by HUD, HUD may direct the Contractor to distribute the report to all parties affected by the report.

Performance Standards

a) Standard: Submit final post production site inspection report within five business days of receiving HUD’s comments

A011 Post Production Site Inspection Report

5.2.7 IPIA Performance Assessment and Reports

The Contractor shall evaluate the performance of each IPIA at least annually based on the requirements outlined in the relevant sections of the regulations (e.g., 3282.204 and 3282.362) and in accordance with the Contractor's HUD-approved Monitoring Procedures. Each year, the Contractor shall perform a minimum of one IPIA Performance Review (IPR) for each HUD-approved IPIA. Approximately, 12 IPRs occur annually. The report for a state-exclusive IPIA may have the IPIA performance report included as part of the SAA monitoring and assessment report. The Contractor shall execute information exchange and identify poor performance by an IPIA and, with HUD’s approval, appropriately increase monitoring of the agency, as needed. Up to three (3) IPIAs may require a mid-year review and evaluation report in each contract period due to repetitive failures to maintain acceptable performance determinations.

The Contractor shall review all data, including the IPIAs response to the Contractors in-plant audit reports to identify performance trends including specific areas of strength and weakness, organizational competence, procedural adequacy and implementation, compliance with Alternative and On-Site Construction approvals, and the effectiveness and thoroughness of plant-specific and IPIA performance Plans of Corrective Action. The Contractor shall also review each IPIAs operational procedures and any tools the IPIA has developed to fulfill its regulatory responsibilities.

The Contractor shall execute its IPIA performance reviews integrating various activities to be completed before a visit to the IPIAs headquarters, activities to be completed during the visit at the…