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The Sleeping Giant is Starting
By George Porter
Things are changing at HUD! After 22 years with the same contractor
doing all the monitoring of the manufactured housing industry,
HUD decided, to the great surprise of everyone, (especially the
contractor) that the job needs to be broken down into five parts.
You might wonder how the need for a contractor to do the governments
work got started in the first place. If you know anything about
politics then you know it has something to do with politicians
getting elected. Contractors are how we reduce the cost of government!
When someone gets a job within the government then it increases
the government payroll, but when you hire consultants and outside
companies, "the cost of government payroll" goes down.
When the HUD program started there were dozens of people on staff
that ran all sorts of services. Now there are about five people
due to the downsizing of government. The work that needs to be
done is greater than ever and that is where the contractor comes
in. As government shrinks the contractors grow. This is the consequence
of electing the people who are for "reducing" the cost
of government. You didn't notice your taxes going down over the
years did you?
Needless to say the HUD program could not begin to function
without contractors and they have retained the same one since
the inception of the HUD Code in 1976. This breakup of the current
contract is a very large departure from business as usual and
it makes one wonder what prompted such a decision.
At any rate the original contract is to be broken into five
parts according to information obtained from MHI. These parts
are the following:
1. IPIA monitoring and performance of SAA functions in the
2. DAPIA monitoring
3. Administration of monitoring fee collections and distribution
of funds and certification labels
4. Electronic data management (EDM)
5. Technical training and administrative support
The first item is twofold and has the most impact on the important
topic of proper home installation. IPIA stands for In plant Primary
Inspection Agency and refers to those people who inspect homes
in the factories. The performance of SAA functions in states that
do not have a State Administrative Agency has far reaching implications.
SAA's are the people within an individual state that are empowered
to enforce the HUD Code. There are presently 14 states that do
not have an SAA. Whoever is awarded this first contract will presumably
be administering those functions in fourteen states. Theoretically
HUD oversaw these states before, but they were never really active.
It now it seems that these states may receive much more attention.
In the past all the functions listed in the five contracts
have been done by some entity so everything should run more or
less the same way it ever did. This decision may serve to improve
the program or unfortunately, might also totally dismantle it.
The down side is that over the years there is only one entity
that really has maintained a grasp of how this program functions.
Since the HUD staff has continually changed every few years the
old contractor is really the only entity to have hands on knowledge
of how to make the program operate. The new people at HUD usually
come from a completely different field and have a rather steep
learning curve becoming comfortable with how the program works.
They must become familiar with the HUD Code to be sure, but the
hardest part of any new higher level job is the politics. Who
or who not to listen to, and whose advice to follow. How do most
of the players feel about certain policies of the past? What is
reality as opposed to theory? By the time the new people have
this all figured out and are starting to act on their own intuition
and instinct they usually move on, and so the process starts all
over again. In a way the possibility of eliminating the contractor
is a bit disconcerting. Who will have the big picture of the program
and know how to make it work?
Historically the HUD staff has had little to do with the every
day running of the program and was mainly concerned with policy
decisions. With this dividing of contracts they will be in the
position of coordinating the efforts of all five contracts. They
have never done that before. Added to this is the fact that the
top two executives in the department at HUD are brand new making
the task seem all the more difficult.
On the other hand, these changes could prove to be a great
thing. To have five different areas of focus on the program means
the possibility of five new groups of contractors with fresh views
and ideas on how to get the job done. If the old contractor did
all five functions listed above, then there is the possibility
that they performed some of their functions better than others.
This was acceptable because their overall performance was adequate.
To judge them on the merits of each individual function, as may
be the case if five new contractors evolve from this change, then
it will be a different story. If the performance of one is not
really up to standard at the end of the contract they can be replaced
by someone who proposes to do a better job. This dividing of the
contract could be a good thing, it will demand accountability
in all five areas.
The purpose of all this explanation and what it possibly has
to do with installation can be summed up with this question, "what
installation regulation and licensing program in any state in
the country is not run by the SAA"? The answer is none. If
you have been following the HUD policy of total denial with any
involvement with installation, then this presents a new problem.
If HUD gives authority to one contractor for the SAA functions
in all fourteen states that do not currently have an SAA, does
this mean that those states will never have installation regulations?
Does this also mean that if a person in the state has an installation
problem that they will not be able to go to the SAA contractor
because that office is forbidden to discuss it? Will the SAA contractor
have an office in all the fourteen different states? When COSAA
(Congress of State Administrative Agencies) meets it votes on
various motions so does this mean that this new HUD contractor
has 14 votes?
It would be hard to imagine HUD telling any state they can
not have installation regulations, but at the same time, it is
equally difficult to imagine a state installation regulation and
licensing program without the involvement of the SAA. Something
is going to have to change here. If I were a betting man I would
put money on HUD weakening its position on becoming involved with
installation. They might say that the new contractor is doing
the regulating, not HUD, or put forth some other arms length scenario.
When they award this contract this issue must be addressed. It
will be very interesting to see what happens when this sleeping
giant called HUD has to wake up and start administering their
own programs at the state level. If I were one of the 14 states
without an SAA, I think I would get real busy and find myself
somebody in my own state to be my SAA, right now. You are about
to become federally regulated by a contractor you haven't met