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  1. 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.
  2. 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.)