As a follow-up to MHARR’s memorandum of January 9, 2018 regarding changes within the HUD manufactured housing program and its memorandum of November 28, 2017 regarding the re-solicitation of the HUD manufactured housing program monitoring contract, MHARR can now confirm that the monitoring contract re-solicitation – originally scheduled for December 29, 2017 as reported by HUD’s contracting officer at the Department’s November 16, 2017 “industry day” event – was not issued on the projected date.
MHARR, at the “industry day” event, and, more importantly, in December 12, 2017 correspondence with Trump Administration officials at HUD, specifically objected to the highly-truncated response period for the re-solicitation – just 15 business days – which MHARR maintained (and continues to assert) represents an inequitable and improper advantage for the current, 40-year incumbent monitoring contractor. As MHARR noted in its November 28, 2017 report: “for a contract that during its last five-year term (with options) was valued in excess of $25 million, HUD is expecting to issue a solicitation package just before the end of the current year – i.e., December 29, 2017 – with responses from offerors due just 22 days later, on January 19, 2017. With weekends and federal holidays (i.e., January 1, 2018) removed, this will leave bidders just 15 business days to analyze and digest the extensive bid package and submit an equally-extensive proposal in order to even be competitive with a 40-year incumbent.”
Similarly, the contract was expected to be split into two separate contracts which, as MHARR noted, “will have the de facto impact of making it more costly, particularly for non-incumbent offerors, to bid – i.e., developing and submitting two complete bid packages rather than one – and more difficult and burdensome for those non-incumbent offerors to develop and submit two bid packages within an unnecessarily truncated and limited bid response period.
In its December 12, 2017 correspondence with the Trump Administration’s Deputy Assistant Secretary responsible for the HUD program, MHARR specifically asked her to “intervene in this process as soon as possible to prevent it from replicating [the contract’s] history of non-competitive procurements.”
MHARR will continue to carefully monitor this monitoring contract solicitation as part of its ongoing engagement with Trump Administration officials at HUD.