Serge E. Gaudry, Senior Consultant at Government Compliance Consultants, Inc., summed up the outrage and frustration the real world, outside of the Atlanta Progressives, have with respect to the fraud, waste and abuse which Julián Castro’s US Department of Housing and Urban Development (HUD) is serving up,
According to the HUD FY 2016 Contracting Opportunities Forecast, HUD intends to issue an RFP for FSM 3.9 (APP-HU-2016-172) during the second quarter of this year. The FSM 3.8 RFP was issued using the “lowest priced, technically acceptable” (LPTA) procurement model which is not appropriate for the type of services required to maintain HUD properties. The FSM 3.8 contracts being procured under LPTA has resulted in the prices paid to field subcontractors being driven so low that it creates an impossibility of performance. HUD has high expectations for the quality of services it expects from its FSM contractors but they have driven the prices so low no field subs would agree to do the work for what the FSM contractors can afford to pay them.
I predict that many FSM 3.8 contractors will find it so difficult to find subs willing to do inspections,
clean outs etc. that HUD will have to re-compete these contracts. The answer to the FSM mess is for HUD to use the “best value” model and conduct Cost Realism Analysis to evaluate specific elements of each offeror’s proposed cost estimate to determine whether the estimated cost elements are realistic for the work to be performed. This would solve the problem for the FSM contractors as well as the field subcontractors who would be paid a fair price for their services. Furthermore, this would enable FSM contractors to comply with the requirements of the Service Contract Act which.
Mr. Craig Karnes who is in charge of the HUD M&M process should consider issuing the FSM 3.9 RFP under the “best value” procurement model.
Gaudry is not a wet behind the ears promulgator. Gaudry’s career spans nearly three and a half decades. I want that to sink in just a moment. While people like Castro may come and go; while people like Craig Karnes may take his bribes and hit the L Train on the way out, Gaudry is a man whom has experienced the Pentagon Papers fallout.
On the real, Karnes and his Sharptonesque entourage are rapidly running off the rails. If he and Himes believe they will make it through the latest round of fraud unscathed I believe they are sadly mistaken and have drank the Progressive Kool Aid.
As Foreclosurepedia begins to release the documentation on the twisted and corrupt Marketing and Management (M&M) offerings; as we begin to release the internal correspondence between William Collins, Ivery Himes, Craig Karnes and Phil Mayer the picture painted is going to merely confirm what Gaudry so eloquently pointed out.





