Yes, in fact I started my analysis with the 22.1003-3 and -4 exemptions. The scope of work at issue here is arguably 22.1003-5( m) work, data collection, processing services (commercial item services) that are priced under our IT 70 schedule. What I have taken away from this conversation is that we need to flow down the SCA and the sub should perform its due diligence regarding applicable wage determinations that might apply.
I am a new member and relatively new to govt contracting so please excuse if the answer is obvious. Similar to the inquiry below, I am trying to determine if wage determinations apply to BPAs under an IT 70 schedule contract where the Service Contracts Act is a mandatory flow-down but the CO has not put the contract holder on notice regarding the applicable WDs. My ultimate goal is to determine what I need to flow down to my subs who will perform some of this commercial item service labor as 100% of their job description (so that the FAR 52.22.52 20% exemption would appear inapplicable.)