MH_PRODUCTION_IPIA_AND_STATE_ADMINISTRATIVE_AGENCY_DRAFT_PWS.doc
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Performance Work Statement (PWS)
MANUFACTURED HOUSING PRODUCTION INSPECTION PRIMARY INSPECTION AGENCY AND STATE ADMINISTRATIVE AGENCY MONITORING AND INSPECTION SERVICES
08/23/2017
Version 1.0 4Vision Statement
1 General Information
1.1 Introduction
1.2 Background
1.3 Constraints
1.4 Description of Services
1.5 Non-Personal Services
1.6 Period of Performance
1.7 Place of Performance
1.8 Hours of Operation
1.9 Special Qualifications
1.10 Post Award/Kickoff Conference
1.11 Status Meetings
1.12 Contractor Travel
1.13 Transition In
1.14 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
3.5 Quality Assurance (QA)
4 Contractor-Furnished Items and Services
4.1 Facilities
4.2 Equipment
4.3 Material
4.4 Contractor Responsibilities
4.5 Contractor Personnel
4.6 Identification of Contractor Employees
4.7 Quality Control
4.7.1 Quality Control Plan
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 Performance Requirements Summary 8 Related Documents
Performance Work Statement (PWS) MANUFACTURED HOUSING PRODUCTION INSPECTION PRIMARY INSPECTION AGENCY AND STATE ADMINISTRATIVE AGENCY MONITORING AND INSPECTION SERVICES Vision Statement
The vision of the IPIA and SAA monitoring and inspection services is to provide verification that each HUD-approved Production Inspection Primary Inspection Agency (IPIA) and each State Administrative Agency has adequately performed all the relevant functions and responsibilities each organization is responsible for per regulations.
1 General Information
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,
· establish a Manufactured Housing Consensus Committee to make recommendations on new or revised construction and safety standards through an administering organization,
· establish a dispute resolution program, administered through contracted assistance; and
· mandates implementation of an installation program administered by qualifying state agencies or by HUD.
HUD’s role has become increasingly important in assuring that the quality of the home is maintained and that consumer complaint handling by manufacturers service meet regulatory requirements. This role has also been broadened by trends to apply innovation to factory-built housing, employing more creative designs and utilizing new products. This serves to enhance HUD’s role and responsibilities and that of HUD’s contractors, agents, and regulatory partners as they are continuously called upon to respond to questions and concerns regarding designs and construction methods evaluated in accordance with the performance-based Standards.
1.1 Introduction
The Department, with assistance through monitoring and inspection services including collection and analysis of in-plant audit data and State agency audit data, is responsible for performing various types of assessments and evaluations to determine performance of private and state agencies responsible for enforcement of program regulations and oversight of design and construction of manufactured housing. The Departments program includes parallel and concurrent monitoring of Production Inspection Primary Inspection Agencies (IPIAs), Design-Approval Primary Inspection Agencies (DAPIAs), and assessments of state agencies that perform State Administrative Agency (SAA) functions.
See 24 Code of Federal Regulations Part 3280 for the Manufactured Home Construction and Safety Standards and Part 3282, Manufactured Housing Procedural and Enforcement Regulations (the Regulations) for the regulations governing the program requirements and for details of each entity’s regulatory responsibilities
1.2 Background
Through the Department of Housing and Urban Developments (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 HUD’s Manufactured Housing Construction and Safety Standards Program since 1976. About 50 companies produce manufactured housing in 129 plants (production lines) with current production of about 100,000 floors per federal fiscal year.
HUD administers the program, supported by agreements with SAAs and various contractors.
HUD also uses the services of an administering organization to support the Manufactured Housing Consensus Committee; a committee that provides recommendations to the Secretary of HUD to adopt and revise certain standards and regulations. In addition to SAAs and HUD’s contractors there are currently six (6) DAPIAs and fourteen (14) IPIAs, both public and private, approved by HUD to conduct design review and in-plant surveillance, respectively. Nine (9) of the fourteen (14) active HUD-approved agencies are units of State government and the remaining five (5) are private for-profit corporations.
All designs and design changes must be approved by a manufacturers DAPIA that also approves each plants quality assurance manual. The DAPIA is responsible to ensure that designs conform to the requirements of the Standards and incorporate acceptable engineering practices.
Each manufacturer must also obtain the services of an IPIA. The IPIA must determine that the plants under its purview are capable of producing homes in conformance with the Standards on a continual basis and issue a certification. After the certification, the IPIA is responsible to monitor the implementation and effectiveness of the manufacturers 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 with 24 CFR Part 3283 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.
The contractor is responsible to audit IPIA performance and SAA performance with an outcome of each assessment resulting in a determination as to whether the IPIA and SAA is fulfilling all the regulatory responsibilities and is meeting HUD’s expectations.
1.3 Constraints
The services identified in this PWS will adhere to the rules, regulations, laws, standards, and conventions identified by HUD as well as within the Federal Government. Constraints include the following:
1.3.1 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 HUD’s 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 HUD Code); and
· 24 CFR 3282, Manufactured Home Procedural and Enforcement Regulations (the Regulations), which generally govern the enforcement of the HUD Code.
1.3.2 For a list of IPIAs and SAAs, see HUD website at: https://portal.hud.gov/hudportal/HUD?src=/program_offices/housing/rmra/mhs/mhsid.
1.3.3 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 include but are not limited to:
· The number of plants and production totals of manufactured homes;
· The number of design packages and drawings approved;
· 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.
1.3.4 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.
1.4 Description of Services
HUD is seeking a Contractor to perform inspections, assessments, and monitoring of the private and state agents of HUD responsible for the oversight of the construction, inspection, and oversight of quality assurance programs of manufactured housing (IPIA functions) as well as enforcement of notification and correction campaigns and related recordkeeping pursuant to Subpart I of the Regulations (SAA functions). The monitoring and inspection services shall include:
· Management and Administration
· IPIA monitoring audits and assessments
· SAA monitoring audits and assessments
· Ancillary Services including special investigations, regulatory specialist services, and other administrative and technical support
1.5 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.
1.6 Period of Performance
The Period of Performance shall be for one Base Period of 12 months and four 12-month Option Periods.
1.7 Place of Performance
All services, except on-site technical and administrative services (Subtask 5.4.11) shall be performed at the Contractors facility. Service for the on-site technical and administrative subtask is to be provided on-site at HUD headquarters.
1.8 Hours of Operation
The Contractor is responsible for providing services between the hours of 8:00 am and 5:00 pm EST, Monday thru Friday except for Federal holidays or when the Government facility is closed due to local or national emergencies, administrative closing, or similar Government-directed facility closings. Weekly hours shall not exceed a forty (40) hour work week and a typical work day will be 8 hours each day Monday through Friday. The Government reserves the right to change hours of operation or restrict contractor access. Work outside of these daily hours is prohibited without Contracting Officer approval. Government agencies will not be available during scheduled holidays, inclement weather, weekends, and after duty hours.
The Contractor shall at all times maintain an adequate workforce for the uninterrupted performance of all tasks defined within the contract when the Government facility is not closed for the above reasons. When hiring personnel, the Contractor shall keep in mind that the stability and continuity of the workforce is essential.
1.9 Special Qualifications
The Contractor is responsible for ensuring all employees conducting system analysis and compliance assurance possess and maintain current professional certification in accordance with ASTM E-541 during the execution of this contract. All compliance assurance auditors in a lead or primary auditor position are to be certified as quality auditors or quality engineers by the American Society of Quality (ASQ).
1.10 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. The Government intends to convene a Post Award Conference with the Contractor within ten business days after contract award. The Contracting Officer will notify the Contractor of the specific date, location, and agenda within five business days after contract award.
1.11 Status Meetings
The Contracting Officer, Contracting Officer Technical Representative (COTR) 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.
1.12 Contractor Travel
Prior to travel, the Contractor shall coordinate with and receive Government authorization from the COTR for all travel. Reimbursement of travel costs will be in accordance with the Federal Travel Regulation and in accordance with FAR 31.205-46. The Contractor shall travel using the lower cost mode transportation commensurate with the mission requirements. When necessary to use air travel, the Contractor shall use the tourist class, economy class or similar lodging accommodations to the extent they are available and commensurate with the mission requirements. HUD will not reimburse Contractor's local travel. Local travel is defined as travel within fifty (50) miles of Washington, DC. All other travel will be reimbursed on a cost reimbursable basis; no profit or fee will be paid.
1.13 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 90-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.
1.14 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 90-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/Work Days - Every official work day of the week which are days between and including Monday to Friday. This does not include public 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 into, 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 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 funding implications. This individual does NOT have authority to change the terms and conditions of the contract.
Contracting Officer Technical Representative (COTR) - An employee of the U.S. Government, designated by the Contracting Officer to assist in providing technical direction and monitoring performance under the contract.
Defective Service - A service output that does not meet the standard of performance associated with the Performance Work Statement.
Deliverable - Anything that can be physically delivered, but may include non-manufactured things such as meeting minutes or reports.
Government Furnished Property (GFP ) - Government-furnished property means property in the possession of, or directly acquired by, the Government and subsequently furnished to the Contractor for performance of a contract. Government-furnished property includes, but is not limited to, spares and property furnished for repair, maintenance, overhaul, or modification. Government-furnished property also includes contractor-acquired property if the contractor-acquired property is a deliverable under a cost contract when accepted by the Government for continued use under the contract.
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 describe the required results in clear, specific and objective terms with measurable outcomes.
Physical Security - Actions that prevent the loss or damage of Government property.
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.
Service Contract - A contract that directly engages the time and effort of a Contractor whose primary purpose is to perform an identifiable task rather than to furnish an end item of supply.
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
ASQ - American Society for Quality
AQL - Acceptable Quality Level
ARAMS - Automated Renewal and Amendment System
BAA - Business Area Analysis Study
CBT - Computer-Based Training
CCB - Change Control Board
CCMB - Configuration Change Management Board
CMMI - Capability Maturity Model Integration
CFO or OCFO - Office of the Chief Financial Officer of HUD
CFR - Code of Federal Regulations
CIO or OCIO - Office of the Chief Information Officer of HUD
CO - Contracting Officer
COR - Contracting Officer Representative
COTR - Contracting Officer Technical Representative
COTS - Commercial Off-the-Shelf
CPO - Office of the Chief Procurement Officer of HUD
CQA - Certified Quality Auditor
CQE - Certified Quality Engineer
DAPIA - Design Approval Primary Inspection Agency
DPR - DAPIA Performance Report
EST - Eastern Standard Time (U.S.)
ETC - Estimate to Completion
GAO - U.S. General Accounting Office
HUD - U.S. Department of Housing and Urban Development
HUDAR - HUD Acquisition Regulation
HUD/ISG - Internet Services Group within the Telecom Processing Division
HUD Web - HUD’s Intranet Web Site and related WEB pages.
IG or OIG - Inspector General (Office of)
IPIA - Production Inspection Primary Inspection Agency
IPR - IPIA Performance Report
IT - Information Technology
IV&V - Independent Validation and Verification
LOOCS - Line of Credit Control System
OCPO - Office of the Chief Procurement Officer
OIG - Office of Inspector General
OMB - Office of Management and Budget
PL - Public Law
PM - Project Manager
POC - Point of Contact
POCA - Plan of Corrective Action
PPM - Project Planning and Management
QA - Quality Assurance
QAM - Quality Assurance Manual
QASP - Quality Assurance Surveillance Plan
QCP - Quality Control Plan
SAA - State Administrative Agency
SMA - SAA Monitoring Assessment
SF - Standard Form
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. The Government will furnish, at no cost to the Contractor, the GFP shown below.
3.1 Government Services
No Government services will be provided.
3.2 Facilities
The Government will provide office space and office supplies while a staff person is on-site to deliver technical and administrative support services under the on-site technical and administrative assistance requirement (Subtask 5.4.11).
3.3 Equipment
The Government will not provide equipment.
3.4 Materials
The Government will provide electronic access to HUD Standards, Regulations, and other information pertaining to oversight, monitoring and enforcement of manufactured home production and design.
Copies of required materials may be provided to the Contractor in hard copy or soft copy. All materials will remain the property of the Government and will be returned to the COTR 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.
4.2 Equipment
The contractor shall furnish all equipment.
4.3 Material
The contractor shall furnish all materials.
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.
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
The Contractor shall provide a Contract/Project Manager who shall be responsible for the overall performance of work. An alternate shall also be designated to act in the absence of the Contract/Project Manager. The Contractor shall also provide Task Managers responsible for tasks, activities, and deliverables within each Primary Task.
These Contractor personnel (main point of contact, alternate point of contact, and Task Managers) are considered Key Personnel by the Government and shall be listed as such in accordance with HUDAR 2452.237-70, "Key Personnel. The Contract/Project Manager and alternate shall have full authority to act on all contact matters relating to daily operations of this contract.
Accordingly, at a minimum, the Key Personnel shall have the technical knowledge of the requirement and be in the position to actually receive assignment, guidance, and direction from the COR, COTR and CO per HUDAR 2452.237-73, "Conduct of Work and Technical Guidance" and shall be allocated enough hours to the requirement to ensure successful performance.
These points of points of contact shall each be an employee of the Contractor. An employee of a subcontractor is not acceptable for either of these positions. The Contract/Project Manager or alternate and the Task Managers shall be available between the hours of 8:00am to 5:00pm Monday through Friday EST, except Federal Holidays or when the Government facility is closed for administrative reasons.
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 work space area with their name and company affiliation, or at a minimum, "Contractor" after name.
4.7 Quality Control
The Contractor shall establish and maintain a complete quality control program that shall ensure services are performed in accordance with this contract. The Contractor shall develop and implement procedures to identify, prevent, and ensure non-reoccurrence of defective services. The Contractor's quality control program is the means by which he assures himself that his work complies with the requirements of the contract. The Contractor shall provide the associated Quality Control Plan to the Government as directed.
4.7.1 Quality Control Plan
The Contractor shall develop, maintain, enforce, and document a Quality Control Plan (QCP). The QCP shall ensure the Government receives the level of quality that is consistent with the requirements specified in this contract. The QCP shall be sufficiently detailed to provide the Contractor's methodology for identifying and recruiting qualified personnel. The QCP shall also provide the Contractor's methodology for resolving problems identified by the Government during reviews conducted in accordance with its Quality Assurance Surveillance Plan (QASP). The QCP shall also provide the Contractor's methodology for establishing an internal feedback system for support personnel, and for resolving problems identified by that feedback system. The QCP shall demonstrate and validate that the services or deliverables to be provided under the contract are completed with a level of quality that meets the minimum performance threshold established in the Government's QASP. The QCP shall address Quality Management Approach, Quality Assurance, Quality Control and Quality Standards.
5 Specific Tasks
5.1 Management and Administration
5.1.1 Final Transition Plan
The contractor shall provide a Final 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.
Within twelve weeks of contract award, the Contractor shall provide HUD with a draft Final Transition Plan outlining the specific transition steps to be taken, the materials to be transferred, and the schedule for transfer.
After receiving HUD’s review comments on the draft Final Transition Plan, the Contractor shall deliver the Final Transition Plan to HUD within 15 business days.
Deliverables A001 Final Transition Plan
5.1.2 Annual 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 plans shall also provide a high-level summary of contractor activities specific to each task. The Contractors capacity shall include design, editing, and graphics support for professional deliverables completed IAW HUD's publication style guide.
Staff and equipment utilized under the contract may be located to suit the Contractors business needs, but all the Contractors staff, including central organization staff, must have access to the Contractors computer system used to maintain the program data.
A draft Annual Management Work Plan shall be submitted within 10 business days of contract award.
A draft plan for each option period shall be submitted at least 30 days prior to the expiration of each option period, except for the last option period.
After completion of HUD’s review of the draft plan, the Contractor shall forward a final plan to HUD within 10 business days of receiving HUD comments.
Note that the 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 (maximum quarterly).
Performance Standards
a) Standard: Timeliness - Draft plan submitted within 10 days after contract award. Option year plans submitted at least 30 days prior to expiration of option period.
AQL: Zero deviation
b) Standard: Completeness - Plan addresses 100% of contract Tasks, Subtasks, resources, and deliverables.
AQL: Zero deviation
A002 Annual Management Work Plan
5.1.3 Operating Procedures
The Contractor shall prepare uniform procedures and checklists to be followed by its project resources for all activities addressed in the Performance Work Statement. 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 is to 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 draft Operating Procedures must be submitted within 30 days of contract award. After completion of HUD’s review of the draft Operating Procedures, the Contractor shall forward final Operating Procedures to HUD for approval within 10 business days of receiving HUD comments.
The contractor shall review and update the procedures and checklists at least annually. The Contractor shall also provide an opportunity for the IPIAs and/or SAAs to review and comment on any major revisions to the procedures and the contractor shall organize necessary teleconferences or meetings to accomplish this requirement. 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. The contractor shall resubmit updates or revisions within 15 business days of the start of each option period.
Performance Standards
a) Standard: Timeliness - Draft procedures submitted within 30 days of contract award. Updated procedures provided within 10 business days before the start of each option period.
AQL: Zero deviation
b) Standard: Completeness - The procedures address all auditing activities included in the PWS.
AQL: Zero deviation
A003 Operating Procedures
5.1.4 Attend Contract Activity Meetings
The Contractor shall be readily accessible to the CO, COR, COTR 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 within 24 hours of a request. Consequently, phone, email communications, and video conferencing for some meetings will not be acceptable.
The purpose of these meetings is to encourage clear and concise communications between HUD and the Contractor in making swift decisions and taking timely actions. 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 days of contract award.
A004 Monthly Activity and Information Report
5.1.5 Provide Monthly Activity and Information Report
Monthly, the Contractor shall provide a report on current data collected for all tasks in this PWS. The report is to be provided in digital (pdf) format prior to monthly meetings (see Task 5.1.4). The Department anticipates one report per month.
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 report shall be received by HUD at least 5 business days before the corresponding monthly meeting date.
Performance Standards
a) Standard: Completeness - Monthly reports include 100% of contract tasks, subtasks, and required attachments.
AQL: Zero deviation.
b) Standard: Timeliness - Each report is provided at least 5 business days before the correlating monthly meeting.
AQL: 1 business day.
A004 Monthly Activity and Information Report
5.1.6 Provide Data Management and Written Security Plan
The Contractor shall provide HUD staff with electronic access to any data prepared, collected and maintained by the Contractor. The Contractor shall maintain an electronic file on each manufacturer, IPIA, audit, SAA, plan of corrective action, dispute, IPR, SMA, and record review.
The Contractor shall safeguard all data in relation to the requirements of this PWS. As a 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 to not create conflicts of interests.
The Contractors data collection and management system 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 ability for HUD staff to view data and report information remotely. Workstations requirements may vary by specific use. Computer workstations for Contractor staff shall be functional within 15 business days from contract award. Support for off-site contract staff is also required including laptop or other mobile computers and digital cameras suitable for inspection documentation and report preparation during field inspections.
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. After completion of HUD’s review of the plan, the Contractor shall forward a final Security Plan to HUD within 10 business days of HUD’s request or receipt of HUD comments.
This plan shall be reviewed by the contractor prior to each option period and at least 10 days prior to the start of the option period the contractor shall either provide notification that the plan, as approved, remains current, or the contractor shall submit a revised plan for HUD review and acceptance.
A005 Data Management and Written Security Plan
5.1.7 Provide for 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 for the respective SAAs participation. Thereafter, SAAs may participate in the monitoring program and the Contractor shall pay states for the participation in accordance with the agreements. 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 Contractors rights under the agreement with the SAAs shall be assigned to HUD.
To the extent possible, state personnel should participate in monitoring activities related to manufacturers that export manufactured homes to their States. Personnel from an 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 E-541 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 and shall report on the status of state agreements and state personnel use in each monthly 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, disqualifications or requalification of each IPIA. The Contractor shall also provide recommendations for changes and enhancements that IPIAs should 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 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 COTR for a decision.
The Contractor shall deliver proposed in-plant audit schedules and travel cost estimates to HUD at least 45 days in advance of the start of a given months proposed audits. HUD will review and recommend changes or accept each month of audit activities and travel.
5.2.2 Perform In-Plant Audits
The contractor shall 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. The in-plant audits are performed in order to evaluate the effectiveness of an IPIAs inspections 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 manufacturers quality control program and procedures, review of the IPIA and manufacturer inspection documents, 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 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. 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 129 audits.
· Post-Certification Audits - In-plant audits conducted within 30 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 20 audits.
· 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 30 audits.
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 5 business days of the last day of the audit for HUD’s review and acceptance.
A007 Preliminary In-Plant Audit Reports
5.2.3 Resolution of In-Plant Audits
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).
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 IPIAs 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 Contractors final report to HUD should 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 draft final report to HUD along with its recommendation regarding whether a POCA is recommended within 15 business days after completion of the in-plant audit.
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 revised final report within 5 days of receiving HUD 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.
A008 Final In-Plant Audit Reports
5.2.4 Handling Disputes
For any audit finding that cannot be resolved between the contractor and the IPIA, the contractor shall provide a request for dispute determination from HUD. The Contractor shall provide the dispute request to HUD with full documentation of the issue and position statements from all parties involved. HUD will make a final determination, which both parties accept
Dispute reports shall be submitted to HUD within 5 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.
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