I work for a DOE M&O contractor. About 1 1/2 years ago, we issued a number of BOAs for staff augmentation services for positions that are subject to the SCA. We obtained a Wage Determination for the BOA solicitation, and all the BOAs incorporate the appropriate SCA articles and the applicable Wage Determination. We compete all positions among the BOA holders, and issue TOAs to the successful BOA holder. The TOAs incorporate all terms and conditions of the BOA via reference, and in addition, contains the following statement: By signature of its duly authorized representative below, Supplier certifies that it is in compliance with the Service Contract Act, as required by its applicable BOA per Article 15 - Service Contract Act - therein. This approach was blessed by our lawyers. However, a subcontractor to DOE, who is considered an expert on the SCA, has stated that we should be obtaining a new wage determination for each release, because the BOAs are not subcontracts. We have been unable to find anything in writing that prohibits the approach we are using. Getting a new wage determination for each release would create a huge amount of extra work for us, and we do not have the personnel to handle it. Therefore, we would have to replace the BOAs with ID/IQ subcontracts (which is also extra work, but less cumbersome that individual wage determinations for each release). I would appreciate any input on this!