Federal Labor Compliance Officer

The City of Pasadena Housing Department is seeking proposals from qualified consultants to provide federal labor compliance services for construction projects funded through the U.S. Department of Housing and Urban Development (HUD), including the Community Development Block Grant (CDBG) & Home Investment Partnership (HOME) programs.

The consultant will support the City throughout all phases of project implementation, including pre-construction, construction monitoring, and project close-out. Responsibilities will include reviewing bid documents, verifying wage determinations, conducting contractor compliance monitoring, reviewing certified payroll records, performing worker interviews, and ensuring proper documentation and reporting in accordance with federal regulations.

Through this procurement, the City seeks to engage an experienced labor compliance professional or firm with demonstrated expertise in administering federal labor standards requirements for municipal construction projects. The selected consultant will work closely with Housing Department staff, contractors, and project managers to help ensure projects remain compliant and that federal funds are administered effectively and in accordance with HUD requirements.

Background

The City of Pasadena Housing Department administers federally funded housing and community development programs that support neighborhood improvements, public infrastructure, and affordable housing initiatives throughout the City. These programs are funded in part by the U.S. Department of Housing and Urban Development (HUD) entitlements including the Community Development Block Grant (CDBG) Program and Home Investment Partnership (HOME) Program.

Entitlement funds are used for a variety of projects including public facility improvements, infrastructure projects, and housing affordability projects. Construction activities funded in whole or in part with federal funds are subject to federal labor standards requirements.

Federal regulations require compliance with the Davis-Bacon and Related Acts, Section 3 of the Housing and Urban Development Act of 1968, Build America Buy America (BABA) and other applicable federal labor and reporting requirements. These regulations require contractors and subcontractors to pay prevailing wages, submit certified payroll records, and comply with federal labor standards monitoring and documentation requirements.

To ensure compliance with these requirements, the City seeks to retain a qualified consultant to provide labor compliance services for federally funded construction projects administered by the Housing Department.

Project Details

• Reference ID: 2026-RFP-0188
• Department: Housing Department
• Department Head: Jim Wong (Director)

Important Dates

• Questions Due: 2026-05-04T19:00:00.000Z

Evaluation Criteria

• Relevant Experience & Qualifications (30 pts) —

  Proposals will be evaluated based on the firm’s demonstrated experience and qualifications in providing federal labor compliance services for federally funded construction projects. Emphasis will be placed on experience with U.S. Department of Housing and Urban Development (HUD)-funded programs, including Community Development Block Grant (CDBG) and other federally assisted projects.

  Evaluation will consider the proposer’s experience with Davis-Bacon and Related Acts (DBRA) compliance, Section 3 requirements in accordance with 24 CFR Part 75, and experience working with public agencies. Proposers should demonstrate a clear history of successfully administering labor compliance monitoring, resolving compliance issues, and supporting agencies during audits or monitoring reviews.

• Project Approach & Understanding (20 pts) —

  Proposals will be evaluated based on the proposer’s understanding of the scope of services and the quality and completeness of their proposed approach to delivering federal labor compliance services.

  Evaluation will consider the proposer’s methodology for administering and monitoring compliance with Davis-Bacon prevailing wage requirements, Section 3 requirements, and Build America, Buy America (BABA) provisions. Proposers should clearly describe their approach to certified payroll review, contractor compliance monitoring, labor hour tracking, reporting, and coordination with City staff.

  The City will evaluate the practicality, clarity, and effectiveness of the proposed approach, as well as the proposer’s ability to proactively identify and resolve compliance issues.

• Key Personnel (15 pts) —

  Proposals will be evaluated based on the qualifications, experience, and availability of the key personnel assigned to perform the work.

  Proposers must identify the primary staff person who will be responsible for day-to-day labor compliance services and describe their relevant experience in administering federal labor standards and Section 3 requirements. Evaluation will consider the individual’s experience with HUD-funded projects, knowledge of applicable regulations, and demonstrated ability to perform the required services.

  The City will place emphasis on the experience of the personnel who will actually perform the work, rather than firm qualifications alone.

• References / Past Performance (10 pts) —

  Proposals will be evaluated based on the proposer’s past performance on similar projects and the quality of services provided to previous clients.

  Proposers must provide references for comparable work performed for public agencies within the past five (5) years. Evaluation will consider client satisfaction, responsiveness, ability to meet project requirements, and effectiveness in administering labor compliance services.

  The City may contact references to verify the proposer’s performance and ability to successfully deliver the requested services.

• Company Staffing Assigned to the Project (10 pts) —

  Points will be assigned based on an implementation timeline and milestone plan in the form of a Gantt chart that includes but is not limited to dates for installation, training, project rollout, and payment milestones.

• Proposed Schedule (10 pts) —

  Points will be assigned for the proposed schedule to complete the project. .

• Proposer’s Qualifications Criteria & Capability to Implement Project (15 pts) —

  Proposals will be scored on the following:

  1. The Proposer provides a detailed overview of Core Team organization, structure, firm experience, and key personnel that demonstrate expertise and capacity to both develop and operate the proposed Project.
  2. The Proposer includes an experienced development entity that can provide evidence of experience in predevelopment phase services (i.e. during an ENA period in which entitlement and environmental clearances are pursued, and ground lease agreements are negotiated) and then subsequent execution of ground lease agreements. 
  3. The Proposer includes an experienced development entity, and such disciplines as licensed architects, engineers, and planners. 
  4. The Proposer provides experience through a list of completed project examples similar to the scale of the Project Site. Examples of project experience should highlight, but are not limited to, the following: scale, design, new construction, entitlement effort, working with a public agency, working with community stakeholders, achievement of public benefits, on- time and on-budget project delivery (or satisfactory explanation where not on-time or on-budget), ground lease structure utilized, and experience with any other deal structures being proposed as part of the Proposer’s approach. 
  5. The Proposer demonstrates strong expertise and capacity in meaningfully engaging community stakeholders. 
  6. The Proposer has experience working successfully with local and state regulators. 
  7. Prior construction experience or other relevant experience to effectuate similar development projects. 
• Project Financing Strategy (15 pts) —

  Points will be awarded based on the following factors:

  1. The Proposer has clearly identified a reasonable financing structure for the overall Project Site that allows the City to ground lease the City Property to the Proposer.

  2. The reasonableness of the proposed Project Budget and assumptions of construction costs.

  3. Clarity of proposed financial structure and relative strength of proposed Core Team, partners and/or lending institutions identified to provide such funding or other support. 
  4. Experience and success in prior securing the proposed financing/funding sources. 

  5. The Project Pro Forma demonstrates financial feasibility and Proposer has identified proposed sources of funds to cover financial gaps. The Proposer clearly identifies the anticipated sources of proposed Project funding, in the predevelopment, construction and permanent financing phases. 
  6. The Applicant is proposing affordable housing beyond the minimum requirement outlined for the entire proposed Project. 
  7. Zero (0) points will be awarded in this category to any proposal with a financing strategy that requires City subsidy beyond the ground leasing of the City’s parcel and the City reserves the right to disqualify the Proposal entirely.
• Financial Capacity (20 pts) —

  Points will be awarded based on the following:

  1. The Proposer has experience managing large development projects (50 units or larger) and securing similar funding sources contemplated in the proposed Project, including in-depth knowledge and a high comfort level with ground lease structures. 
  2. The proposal evidences the Proposer’s ability to fund pre-construction activities immediately upon award of an ENA. 
  3. The Proposer clearly demonstrates ability to provide or obtain its proposed financing or other identified funding sources for the proposed Project. 
  4. The Proposer demonstrates strong relationships with financial institutions and there are no reported bankruptcies, histories of defaulting, or having non-performing loans that may negatively affect the proposed Project. Proposer has provided at least three (3) reference letters from previous lenders and/or equity providers. Proposer has provided preliminary evidence of interest from financial institutions and/or equity partners for the project. 
• Project Design/Concept & Narrative Description (20 pts) —

  Points will be awarded for projects that maximize the site potential and capitalize on the site constraints. This includes neighborhood continuity:

  1. The proposal provides architectural plans for the proposed Project, showing and labelling setbacks, easements, and key features of the design concept including sustainability, open space, and a demonstrated understanding of ADA requirements.
  2. The proposed design complements the surrounding community.
  3. The proposed design effectively supports the Proposer’s affordable housing mix and any proposed commercial tenant(s).
  4. Proposer demonstrates a viable strategy towards achieving its development concept with respect to affordable housing mix and proposed market-rate unit mix.
  5. The development schedule is realistic, phased appropriately, and evidences the Proposer’s grasp of the necessary elements of predevelopment and construction, including entitlements and permitting requirements.
  6. The development plan demonstrates an understanding of the site’s opportunities and constraints.
  7. Proposer provides a community outreach and engagement plan, that includes, but not limited to, team experience and meaningful approach across each stage of the process.
• Project Schedule (20 pts) —

  Points will be awarded if the project’s timeline is reasonable and project can move from predevelopment to construction quickly. Points will be awarded as follows for schedules deemed reasonable:

  1. Full points will be awarded to projects that anticipate beginning construction in less than 12 months from the execution of the Development Agreement 
  2. ## points will be awarded for projects that anticipate beginning construction between 13 and 24 months from execution of the Development Agreement
  3. ## points will be awarded for projects that anticipate beginning construction between 25 and 36 months from execution of the Development Agreement
  4. ## points will be awarded for projects that anticipate beginning construction between 37 and 48 months from the execution of the Development Agreement
  5. No points will be awarded for projects that anticipate beginning construction 49 months or after the execution of the Development Agreement.
• Cost Proposal (25 pts) —

  Points will be assigned based on a “Ratio Method.” The proposer’s cost must include the delivery of the proposed solutions, as well as any recurring costs (if any) as delineated in the Scope of Work and the PRICE PROPOSAL.

  With this method, the proposal with the lowest cost receives the maximum points allowed. All other proposals receive a percentage of the points available based on their cost relationship to the lowest price. This is determined by applying the following formula:

  Lowest Price / Evaluated Price X maximum points available = Awarded Points

  Example: The cost for the lowest proposal is $100,000. The next lowest proposal has a cost of $125,000. The total points available for cost = 30 points.

  ( $100,000 / $125,000 ) X 30 = 24 points

• Local Pasadena Business (5 pts) —

  To be awarded a 5 point preference for this category, the proposer must have an official business address within the City of Pasadena at the time that this RFP is posted on the City’s Website.

• Small or Micro-Business (5 pts) —

  To be awarded a 5 point preference for this category, the proposer must be certified by the State of California as a small or micro-business. Refer to the State of California Department of General Services Division for further information. https://caleprocure.ca.gov/pages/sbdvbe-index.aspx

Submission Requirements

• Acknowledgements
• Proposer Certification (required) —

  By submitting this bid the proposer hereby certifies under penalty of perjury of the laws of the State of California that all representations made in the documents that comprise the proposal for Federal Labor Compliance Officer due on Friday, May 8, 2026 are true and correct to the best of my knowledge at the time of the proposal’s submission.

  By confirming, the vendor is acknowledges the following:

  • We have reviewed and agreed to all of the documents contained in this solicitation and understands that the City will not be responsible for any errors or omissions on the part of the vendor in making up this bid or proposal.
  • The representations herein are made under penalty of perjury.
  • We hereby offer to sell the City of Pasadena the materials, products, and/or services at the prices shown and under the terms and conditions included hereon or attached or referenced.
• CONTENTS OF PROPOSAL —

  The entire proposal must be formatted on standard-size 8½”x11” pages; 12 point font only. The "Technical Proposal," "Additional Data," and "Statement of Qualifications" can be no more than 50 grand total pages.

• Mandatory Content (required) —
  • Cover letter
  • Table of Contents
  • Proof of SAM.GOV Clearance
  • Technical Proposal
  • Single Blended Rate Price Proposal
  • Statement of Qualifications and/or Experience with HUD labor compliance
  • Good Standing with CA Secretary of State
  • Additional Data (if required)

  Subsequent to the closing of this solicitation, the selected vendor will be required to provide the following documents within 10 calendar days of being notified, otherwise the submitted proposal may be deemed non-responsive.

  • Request for Tax Payer Identification Number and Certification (IRS Form W-9)
  • Pasadena Business License (if required)
  • Any Required Licenses or Certifications

  • All Insurance Required by this Solicitation (If Required) #Insurance Requirements

• Additional Mandatory Content for Developments (required) —

  Proposers must provide a response for all requirements detailed in the Scope of Work and in the General Development Requirements.

  • Sources and Uses & Operating Pro Forma - in Price Proposal
  • Development Concept (Vision and Usage) - in Technical Proposal
  • Partnerships: Description of any additional partners - in Technical Proposal
  • Constraints & Assumptions - in Technical Proposal
  • Project Timeline - in Technical Proposal

   

• Cover Letter and Table of Contents (required) —

  Upload your Cover Letter and Table of Contents :

  “Cover Letter” shall be a maximum one-page letter including the name and address of the organization submitting the proposal; whether the proposing firm is an individual, partnership, corporation or joint venture; and the name, mailing/e-mail addresses, and telephone/fax numbers the contact person who will be authorized to make representations for the organization.

• Separate Technical Proposal Only - Proposal Submittal (required) —

  The Technical Proposal shall demonstrate the Proposer’s understanding of the Scope of Work and their approach to providing federal labor compliance services for the City.

  The Technical Proposal shall be clear, concise, and well organized, and shall include sufficient detail to allow the City to evaluate the Proposer’s qualifications, experience, and proposed approach to performing the work.

  No pricing information shall be included in the Technical Proposal. Any proposal containing cost or pricing information in this section may be deemed non-responsive.

• Separate Price Proposal Submittal: —

  The Price Proposal shall be submitted separately from the technical proposal.

  Proposers shall provide a single blended hourly rate for all services described in the Scope of Work using the pricing table provided in this RFP.

  The hourly rate shall be fully loaded and inclusive of all costs necessary to perform the services, including but not limited to:

  • Labor and personnel costs
  • Administrative support
  • Overhead and profit
  • Travel and mileage
  • Equipment, materials, and supplies
  • Subconsultant costs (if applicable)
  • Any other direct or indirect costs associated with performing the services

  The City will not accept multiple hourly rates for different staff classifications. Proposals that include multiple rates or fail to provide a single blended hourly rate may be deemed non-responsive.

  No additional compensation will be allowed beyond the approved hourly rate unless specifically authorized in writing by the City.

  Reimbursable expenses are expected to be included in the hourly rate. If a proposer believes certain extraordinary expenses are necessary, they must be clearly identified and pre-approved by the City.

  The hourly rate provided will be used for evaluation purposes and may form the basis for compensation under the resulting agreement.

• Additional Data (if necessary) —

  “Additional Data” shall include any other data the PROPOSER deems essential to the evaluation of the proposal, i.e., letter of reference, other related projects, etc., or other required documents.

  The entire proposal must be formatted on standard-size 8½”x11” pages; 12 point font only. The "Technical Proposal," "Additional Data," and "Statement of Qualifications" can be no more than a grand total of 50 combined.

• Preferences (if applied)
• Is your company currently certified with the State of California Department of General Services (DGS) as a Small or Micro Business? (required) —

  If this preference is applied to the solicitation, and your company is seeking this preference, you must provide a copy of the certification from DGS.

• Please upload a copy of your Current California DGS Certification (required)
• Is your company currently located within the boundary of the City of Pasadena? (required)
• Please upload a copy of your Company's Pasadena Business License (required)
• QUALIFICATIONS
• Copy of License or Certification (required) —

  Please upload a copy of your: TBD

• California Department of Industrial Relations Registration Verification (required) —

  Solely for the purpose of verification. Please enter your Public Works Contractor Registration Number. This will be verified against the state database for the Department of Industrial Relations Registration.

• Statement of Qualifications and/or Experience (required) —

  The Proposer shall provide a Statement of Qualifications demonstrating its experience and capability to perform federal labor compliance services for federally funded construction projects.

  The statement shall clearly describe the firm’s experience in administering and monitoring compliance with:

  • Davis-Bacon and Related Acts (prevailing wage requirements)
  • Section 3 requirements in accordance with 24 CFR Part 75
  • Build America, Buy America (BABA) requirements (if applicable)
• FORMS —

  Please download, complete and submit any required forms below.

• AA1; AA2; AA3; SIGNATURE & LEGAL STATUS; AND DECLARATION OF NON-Collusion (required) —

  If your proposal does not include all of the below items, it may be deemed non-responsive.

  • Each PROPOSER must submit a completed Form AA-1. Failure to submit this form will result in automatic disqualification with no exceptions unless PROPOSER has an approved form on file with the City.
  • Form AA-2 is required to be submitted for projects involving labor or services in excess of $25,000.
  • Form AA-3 is Optional. (Copies attached)
  • A completed and signed "Declaration of Non-Collusion." (Copy attached)
  • SIGNATURE & LEGAL STATUS (Copy attached)

  • Evidence of certification by State of California as a small or micro-business, if claiming such preference – https://caleprocure.ca.gov/pages/PublicSearch/supplier-search.aspx

• Taxpayer Protection Amendment Disclosure (required) —

  Please download the below documents, complete, and upload.

  ADDITIONAL REQUIREMENT

  For RFP/RFQ where the selected vendor/contract will require City Council approval (check with City project manager for clarification), the following requirement applies:

  • TAX PAYER PROTECTION ACT – PROPOSER SUBMITS A COPY OF THE COMPLETED TPA FORM TO THE CITY CLERK’S OFFICE

  E-MAIL: OfficialRecords-CityClerk@Cityofpasadena.net

• Conflict of Interest (required) —

  Please download the below documents, complete, and upload.

• Designated Representative (required) —

  Please download the below documents, complete, and upload.

• Consultant Listing —

  Please download the below documents, complete, and upload.

• Technical Questionnaire Form —

  This form is only required for the purchases of technology. If selected, proposers will be required to complete the Pasadena Department of Information Technology Technical Questionnaire. The questionnaire is included in the #Attachments. When completing the questionnaire, please note:

  • Section 4.0 must be completed for externally hosted/SAAS applications; and
  • Section 5.0 must be completed for City hosted/on-premises software
• Data Security for Printers/Copiers/Scanners (required) —

  In order to comply with the section named “Data Security for Printers/Copiers/Scanners,” My company will:

• DISQUALIFICATION DISCLOSURE (required) —

  Please download the below documents, complete, and upload.

• Federal Forms
• Federal Required Certification (required) —

  Please download the below documents, complete, and upload.

• Disclosure_of_Lobbying_Activities (required) —

  Please download the below documents, complete, and upload.

• Unique Entity Identifier (required) —

  Please download the below documents, complete, and upload.

• PROOF OF AUTHORITY
• Proof of Authority - Identity Confirmation (required) —

  Please download the below documents, complete, and upload.

• Proof of Authority - Incumbency Certificate (required) —

  Please download the below documents, complete, and upload.

• Proof of Authority - Certificate of Secretary —

  Please download the below documents, complete, and upload.

• Proof of Authority - Resolution (required) —

  Please download the below documents, complete, and upload.

• HUD REQUIREMENTS
• HUD Federal Forms (Over $200k) (required) —

  In addition to the items listed above, the following list is provided for the convenience of both you and the City and to help eliminate errors and omissions which may render your bid unacceptable. The following forms are required to be submitted with your bid: https://www.cityofpasadena.net/finance/wp-content/uploads/sites/27/HUD-Federal-Forms-over-200k.pdf?v=1674593673378

  HUD Federal Forms (Over $200k)

  • Worker’s Compensation Certification
  • Federal Lobbyist Certification
  • Past Performance Certification
  • List of Proposed Subcontractors
  • Section 3 Business Concern
  • Business Concern Affirmation
  • Notice of Section 3 Commitment
  • Section 3 Economic Opportunity Plan
• Active SAM Registration (required) —

  All vendors responding to this solicitation must provide a copy of their Active SAM Registration with their proposal.

• Funding
• How is this Procurement Funded? (required) —

  Select a general funding source

• Confirm requirements from the Grantor are Satisfied (required)
• Please include the full name of the funding agency (not the program): (required) —

  For Example: "Homeland Security"

• Amount of Award from HUD was: (required) —

  This amount is the dollar value of the award from HUD. Contact Housing if you have questions.

• Federal-Aid Project No. (required) —

  Do not erase the text below. Enter the number after the text that reads "FEDERAL-AID PROJECT NUMBER:"

• Additional Federal Attachments —

  Below is a list of potential attachments that may or may not apply to your procurement.  Please review the attachments in the section named "Attachments" to ensure they are relevant and appropriate.

• Setup
• Include a Price Proposal? (required)
• Does this procurement include any of the following (check all that apply)
• Has DoIT approved your specifications? (required)
• Has BSFMD approved your specifications?
• Type of Technology Included (required) —

  Goods/Equipment, Services, SAAS, Printers, Copiers/Scanners)

• Has HR approved your Scope of Work, or Specification? (required)
• HR Compliance with AB 339 (When buying a service or labor) —

  If any of the following items apply, please contact HR (Jaime Arellano, jarellano@cityofpasadena.net; (626) 744-7301) for approval before you proceed.  DO NOT SUBMIT BEYOND THIS POINT UNTIL YOU HAVE OBTAINED APPROVAL FROM HUMAN RESOURCES.

• How many grand total pages should be included in the "Technical Proposal," the "Additional Data," and the "Statement of Qualifications" combined? (required)
• Are there any License or Certification Requirement? (required) —

  This particular question is to be answered for the company (or their subcontractors) not their employees.

• License or Certification Type: (required) —

  Please enter the specific License or Certification required to be eligible to compete on this solicitation. For example, "CPA - Certified Public Accountant."

• Is this a License from the State of California Licensing Board? (required)
• Does this procurement include buying a public work? (required) —

  State of California Definition: Construction, alteration, demolition, installation, or repair work done under contract and paid in whole or in part out of public funds. It can include preconstruction and post-construction activities related to a public works project.

• Is experience required to be eligible to compete on this solicitation? (required)
• Evaluation Criteria
• Select Evaluation Criteria to Include —

  Choose your evaluation factors. Below are example factors you can consider for your Evaluation Criteria. It is important that your actual evaluation of proposals is consistent with the factors and criteria you include in the RFP document. You will be able to add or edit any custom criteria along with the point values (using a 100-point-scale) while you are editing the Evaluation Section of this project.

• Contract Terms
• Base Contract Duration: How many years will be included for the base contract? (required)
• Optional Renewals: How many one-year optional contract renewals will be included with the contract? (required)
• Award Method? (required) —

  General definitions and parameters of each approach.

  • Award to the Winner: This is a traditional public procurement where the winning bid or proposal is selected based on the Lowest, Responsive and Responsible Bidder when using a Competitive Bid process; or the Highest Scored Proposal when using the Competitive Selection process.
  • Split Award: A “Split-Award” is designed to specify and distinguish separate Groups of awards based on separate specifications or Scopes of Work. A vendor can respond to any combination of the Groups provided they are responsive and responsible. Each Group is evaluated and awarded independently. Effectively, there could be a separate winner for each Group.
  • Back Up Vendor (RFPs Only): This method is intended to contract with a back up vendor in the event the winner is unable to fulfill the contract.
• UNIQUE INDUSTRY PROCUREMENT METHODS
• Soliciting Proposals from Developers (required) —

  Used for development projects typically by Housing or Economic Development.

• Select Unique Sections to Include
• Evaluation Criteria
• ENGINEERING ONLY: required to comply with AIA requirements? (required)