2017_Industry_Day_Monitoring_Svcs_Slides.pdf

MANUFACTURED HOUSING

MONITORING SERVICES

INDUSTRY DAY

Pamela Beck Danner, Administrator Jason McJury, PE Civil Engineer Eric 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.

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

The Act

• 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

•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

•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?

Example Of A Single Wide Home

Example Of A Double Wide Home

•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

•24 CFR 3280

Nationally Preemptive Manufactured Home Construction and Safety Standards

•24 CFR 3282

Manufactured Home Procedural and Enforcement Regulations (sets forth requirements for industry participants)

Program Standards & Regulations

•24 CFR 3285

Model Manufactured Home Installation Standards

•24 CFR 3286

Manufactured Home Installation Program

•24 CFR 3288

Manufactured Home Dispute Resolution Program

Program Standards & Regulations

•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

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

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

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)

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)

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

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

Key Regulation References

• Management

• IPIA Monitoring

• SAA Assessment

• Ancillary Services

Four Principal

Tasks:

Overview of IPIA/SAA M&I Services

• SAA Assessment

• Ancillary Services

Four Principal

Tasks:

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

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

• SAA Assessment

• Ancillary Services

Four Principal

Tasks:

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

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

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

• SAA Assessment

• Ancillary Services

Four Principal

Tasks:

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

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

• SAA Assessment

• Ancillary Services

Four Principal

Tasks:

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

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

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

MANUFACTURED HOUSING

DAPIA MONITORING SERVICES

INDUSTRY DAY

Eric L. Bers, P.E.

Office of Manufactured Housing Programs

Program Manager

DAPIA Monitoring &

Inspection Contract

–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)

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

•24 CFR 3280

Nationally Preemptive Manufactured Home Construction and Safety Standards

•24 CFR 3282

Manufactured Home Procedural and Enforcement Regulations Subpart H --Primary Inspection Agencies Subpart J –Monitoring of PIAs

Standards & Regulations

Overview of Tasks

THREE Principal Tasks:

• Management and Administration

• Design Review/DAPIA Monitoring

• Ancillary Services

Management & Administration

• Transition Plan

• Annual Management Work Plan

• Operating Procedures

• Monthly Meetings

• Monthly Activity Report

• Data Management & Security Plan

• State Participation (DAPIA)

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

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

• 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

Service 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

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

• 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

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

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

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??

Manufactured Housing Monitoring Services

Acquisition Information

Jerl Traylor, Contracting Officer

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

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

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

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)

Who Can Bid?

Capability Statements

Send Us Your Capability Statement

• Send Statements To:

ManufacturedHousingMonitoringServices@hud.gov

• Due Date: November 27, 2017 by 4:00PM EST mailto:ManufacturedHousingMonitoringServices@hud.gov

Questions ??