Pricing ceiling rates for SCA-covered labor categories on a MATOC

[elgueromeromero]

Scenario: The Gov't issues a solicitation for a FFP MATOC that requires offerors to provide "ceiling rates" for several labor categories, some of which are SCA-covered. The solicitation includes a sample task with an SCA WD applicable to the location of the work for the sample task. The solicitation states that future task orders will be performed at other locations but does not include any other WDs or identify the locations of future tasks. 

Question: How have you seen this handled with respect to pricing the SCA-covered labor categories? Are offerors expected to propose SCA rates high enough to cover any potential WD? That could be a big range if, for example, the sample task will be performed in San Antonio, TX but with the potential for future tasks to be performed somewhere like San Diego, CA. This pricing strategy would of course cover the contractor's risk, but wouldn't make a lot of sense with regard to being price competitive. Can the Gov't award a task order with SCA rates higher than the "ceiling" rates in the awardee's contract if there's a future task order RFP that includes a WD with rates that exceed the SCA rates in the contract?

[ji20874]

For a contract with a principal purpose to furnishing services subject to the Service Contract Act, FAR Subpart 22.10 requires a wage determination for all government-required performance locations.  The contracting officer may meet this requirement by incorporating several wage determinations, or by getting a nationwide WD.

You might want to ask the contracting officer for a listing of all places where it will require contractor performance, and for a wage determination (or combination of wage determinations) that cover all of those places.