SCA WD adjustments on FSS orders

[kevlar51]

I'm struggling a bit on this one and was hoping to find some guidance or discussion from the helpful folks here.

My company has employees on multiple GSA Schedule orders in multiple states who are covered by the SCA/SCLS--either under wage determinations or collective bargaining agreements. Our WDs are incorporated at the order level, not the Schedule level.

Under SCA, contractors are eligible for a price adjustment when a new WD is incorporated into the contract. How can I reconcile this with the general requirement that we may not charge more than the GSA Schedule billing rates on Schedule orders? It would be difficult to seek an adjustment at the Schedule Contract level when applicable WDs or CBAs are entirely based on locality and take effect as multiple orders are renewed at varying times in a given year.

I'm trying to find something to support the notion that an order-based SCA adjustment is permissible. SCP-FSS-001 almost seems to get me there, but falls short.

Are my only solutions to either adjust at the Schedule level or otherwise reduce profitability during performance as WD refreshes are incorporated? That seems counter to the requirement against pricing in contingencies for future WD refreshes.

Thanks very much!

[C Culham]

7 minutes ago, kevlar51 said:

I'm struggling

Reference - https://www.gsa.gov/cdnstatic/Service_Contract_Labor_Standards_and_GSA_Schedule_Orders.pdf

[kevlar51]

1 hour ago, C Culham said:

Reference - https://www.gsa.gov/cdnstatic/Service_Contract_Labor_Standards_and_GSA_Schedule_Orders.pdf

Thanks, but this document assumes that WDs are incorporated and updated at the Schedule contract level, and I don't believe that is the case anymore (or at least it's not in our contract).

[C Culham]

52 minutes ago, kevlar51 said:

Thanks, but this document assumes that WDs are incorporated and updated at the Schedule contract level, and I don't believe that is the case anymore (or at least it's not in our contract).

I understand.  In 2016 it was implied that WDs would morph to the order level.  But this website suggests otherwise.  If I were you I would call the GSA CO for your contract.

https://www.gsa.gov/buy-through-us/purchasing-programs/gsa-multiple-award-schedule/mas-roadmap/mas-roadmap-gather-information/mas-scope-and-templates