UPDATED: New SCA Wage Determinations Incorporated into Several Major GSA Schedules
February 24, 2011
UPDATE (2/25/11): Since this post was originally published, additional GSA solicitation refreshes have been released incorporating new SCA wage determinations dated January 11, 2011. Affected GSA Schedules include Facilities Maintenance and Management (03FAC), Advertising and Integrated Marketing Solutions (AIMS), and Human Resources and EEO Services (HREEO).
In a recent round of solicitation refreshes, GSA’s Management Services Center (MSC) incorporated an updated index (dated January 11, 2011) of Service Contract Act (SCA) wage determinations into the Schedules it manages – MOBIS, PES, LOGWORLD, Environmental, Language Services, and Consolidated. If you hold one of these contracts and have any SCA-covered labor categories, it is important that you review your contract and determine which economic price adjustment (EPA) clause you have chosen for SCA labor categories. If you are basing SCA rate increases on FAR 52.222-43, Fair Labor Standards Act and Service Contract Act Price Adjustment, then you only have 30 days from the date you are notified of the mandatory modification that incorporates the new wage determinations. Since the GSA Schedules typically only update wage determinations every two years, if you miss the window to increase your rates now, you will likely be stuck at your current rates for the next two years – even though you will be legally required to pay service employees in accordance with the new wage determinations to request any changes in pricing for SCA-covered labor categories
As we all know, the Department of Labor is not known for reducing pay rates or health and welfare benefits, so you will definitely lose margin if you are not on the ball. Please be aware that GSA is very stringent in enforcing this 30-day rule. Draft your modification request and make sure that you have your digital certificate in place now to save yourself two years of pain!
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