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  1. My company was issued an award that included an Individual Subcontracting Plan. Over the years (since 2018) I have reported (ISR) in eSRS twice a year. Now the agency has come back and said that I am delinquent in submitting an SSR. I explained that I did not put a commercial plan together for this contract as it was not the requirement. The Commercial Plan that I report on is on our GSA contract. The agency is insisting that I also need to do the SSR in addition to the ISR. I am somewhat confused. If anyone can shed on this one, it would really be appreciated. Thanks
  2. We have a BPA that is expiring and the work has been awarded to another vendor, it is a Service Contract. The question we are trying to get resolved is what are acceptable and reasonable Transition/Phase Out costs. We have been doing this work for over a decade and have facilities we have to shut down and vehicles we have to sell. My company is presenting to the government transition out costs that include severance packages for the overhead staff that are not required to be offered employment by the new contractor (severance package is less than what the company normally provides), location close out costs (remaining lease amount on facilities and moving out costs), and balance remaining on vehicles that were purchased for this work and approved by the client for purchase. I have not been involved in a Transition of this size for a service contract and was wondering if the government will see these type of costs as reasonable. Thanks for any input.
  3. They did not incorporate either of these clauses. The CO told me in an email that he had inadvertently left out the Service Contract Act but he knew we were complying and did not issue a modification.
  4. We have a contract that is one (1) Base Month and six (6) one month options. After the Base Period and the first two (2) Month Options were exercised the CO issued a modification exercising the remaining four (4) Option Months under this one modification. This contract is covered by the Service Contract Act. The DOL changed the H&W amount and some of the wages in the middle of the four (4) month options that the CO had already exercised prior to the DOL change. Do we still have grounds to increase the wages and H&W based on the applicable WD revisions and request adjustment from the agency? Or does it make a difference that the CO exercised four (4) months worth of options prior to the DOL change? Any information on this subject would be greatly appreciated.
  5. The U.S. Government declared 12/24 as a Federal Holiday. This holiday is not specified in the applicable DOL Wage Determinations that governs my Federal service contracts. Do the employees receive the holiday benefit for this U.S. Government declared day? Or do they just get Christmas as determined by the Wage Determation as we normally provide? This extra day was not built into our pricing model, so I am not sure how this is handled. I appreciate any input.
  6. We have been awarded a subcontract from a construction company where the Prime is a Federal Agency that has incorporated the Davis-Bacon Act in the prime contract which flows down to us. We are providing security at the construction site so the labor category for Guard is not included under the Davis-Bacon Wage Determinations. Given this is a Federal contract, would our company need to follow the Service Contract Act Wage Determinations since Guards are included there? Or would the SCA have to be incorporated also in the Prime contract for this to apply? This happens regularly in our industry so I would like some opinions on how to handle. My first thought is that because the Prime contract is a construction contract and not a service contract per se, we are not subject to the SCA since it is not incorporated in the contract. But I do not want to get audited by DOL and be in violation. Any opinions would be greatly appreciated.
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