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Hi there,

I have seen agencies issue task orders under GSA schedules and state the task order it is not SCA applicable because they believe all employees will be bona fide executive, administrative or professional employees. Here's the issue: many vendors have labor categories that are SCA applicable in their GSA schedules - e.g., word processors, support staff,  clerks, etc.

Since the agency says SCA is not applicable on the task order due to the "bona fide executive, administrative, or professional employees" assumptions, is the contractor supposed to ignore their SCA wage determinations? Or is the contract office at the agency wrong and cannot overrule the SCA? I have not found a clear answer on this.

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It’s hard for anybody here to answer without seeing things like the ordering agency SOW.  Perhaps the ordering agency contracting officer feels the nature of the work doesn’t utilize SCA covered employees?  If you are uncomfortable with the issue, ask the CO.  You could email and use the response to document your file.

However it’s difficult to imagine categories like word processors, support staff, and clerks being anything other than SCA covered.  

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On 12/29/2021 at 8:07 AM, CuriousContractor_22 said:

Since the agency says SCA is not applicable on the task order due to the "bona fide executive, administrative, or professional employees" assumptions,

 

A few thoughts -

A contractor has the ultimate responsibility for compliance with SCA.   An agency may assume some type of staffing yet the contractor is the one that makes the final decision as to what an employee may or may not be doing, how they are paid etc.   This may help on what the tests are for a contractor to determine exemption - https://www.dol.gov/sites/dolgov/files/WHD/legacy/files/fs17c_administrative.pdf 

Also do not forget about this document that assists a contractor in determining applicability of SCA as well - https://www.dol.gov/sites/dolgov/files/WHD/legacy/files/SCADirectVers5.pdf  In fact if you read some of the GSA FSS schedules many contractors have positions described that appear to be in direct correlation to the position described in the Directory.

Also consider FAR 22.1015.  However as a contractor I would not depend on this citation as a hoped for bail out because as noted it is really the contractor's ultimate responsibility to comply with SCA.

As to more info another missing link is with regard to the GSA schedule itself.  What are the clauses in it besides the SCA 52.222-41 such as 52.222-52 & 53.  

And finally for the heck of it I will throw this out as a reference.   You might find it handy - https://www.dol.gov/agencies/whd/field-operations-handbook/Chapter-14#B14c00

 

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Is the principal purpose of the contract and/or the task order to furnish services in the United States through the use of service employees?  This is the acid test for SCA applicability -- not the irrelevant fact that a word processor or clerk will be used somewhere during performance.

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On 12/29/2021 at 8:07 AM, CuriousContractor_22 said:

I have seen agencies issue task orders under GSA schedules and state the task order it is not SCA applicable because they believe all employees will be bona fide executive, administrative or professional employees... Since the agency says SCA is not applicable on the task order due to the "bona fide executive, administrative, or professional employees" assumptions, is the contractor supposed to ignore their SCA wage determinations? 

I presume that question is about GSA FSS contracts. I don't know much about them anymore, but I believe that they are all IDIQ contracts and contain the clause at FAR 52.216-18, Ordering, which says in part:

Quote

(b) All delivery orders or task orders are subject to the terms and conditions of this contract. In the event of conflict between a delivery order or task order and this contract, the contract shall control.

Based on that clause, it seems to me that if a GSA FSS contract contains the SCA clause at FAR 52.222-41, then all orders issued thereunder are "subject to" the clause, unless the contract states otherwise based on an authorized FAR deviation. I haven't seen anything in FAR to the contrary. I have not checked the GSAR.

It may be that somewhere in GSA's myriad policies and procedures or in some special clause in its FSS contracts that the FAR 22.1003-1 principal "contract" purpose test applies on an order-by-order basis, and that an order is thus not "subject to" the SCA clause if the ordering CO determines that the order does not meet the SCA applicability criteria. I don't know. But I sure as heck wouldn't accept some agency's assertion to that effect or something posted to some website. I would demand to be shown where it says that in the contract. If it doesn't say that in the contract, then my initial position would be that the agency is wrong.

Of course, if an order does not entail performance of any work by any "service employees," then, while the order is still "subject to" the SCA clause, there is no one to be compensated in accordance with the clause.

Contractors cannot trust what they are told by government personnel, orally or in writing, about the applicability or interpretation of laws and regulations, and they can't trust all website information. They must independently verify. If after award the agency turns out to have been wrong, you might have serious trouble.

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Vern Edwards has brought up good points.   Added are.....

  • If an order had a mix whereby the agency indicates application of wage rates to some positions and not to others it might be that the  "not" positions should be sought as  "open market" positions.  I would have to think on this a little more but it is my first reaction.  https://interact.gsa.gov/blog/open-market-items 
  • I think it is appropriate to throw in willing contractors on the trust matter especially with regard to what a contractor is willing to do under the GSA FSS. After all they should know the do's and don'ts of the contract .   Are they willing to bend the rule of the contract to get an order?   Probably depends on the contractor but my bet is that it happens.  And I would bet the same contractor who in turn might yell "Foul" if it wasn't to their benefit.   It does take "Two to tango".   Appropriate or not it seems Federal government contracting these days fits “It's Easier to Ask Forgiveness Than It Is To Get Permission”
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11 hours ago, Vern Edwards said:

I presume that question is about GSA FSS contracts. I don't know much about them anymore, but I believe that they are all IDIQ contracts and contain the clause at FAR 52.216-18, Ordering, which says in part:

Based on that clause, it seems to me that if a GSA FSS contract contains the SCA clause at FAR 52.222-41, then all orders issued thereunder are "subject to" the clause, unless the contract states otherwise based on an authorized FAR deviation. I haven't seen anything in FAR to the contrary. I have not checked the GSAR.

It may be that somewhere in GSA's myriad policies and procedures or in some special clause in its FSS contracts that the FAR 22.1003-1 principal "contract" purpose test applies on an order-by-order basis, and that an order is thus not "subject to" the SCA clause if the ordering CO determines that the order does not meet the SCA applicability criteria. I don't know. 

The GSA link I cited above covers this.  It says while GSA includes the SCA clauses and wage determinations into the contract for various labor categories, the ordering contracting officer determines whether the SCA applies to the task order and labor categories when they place the order.  I’m still using SCA out of habit instead of SCLS.

 

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11 minutes ago, formerfed said:

The GSA link I cited above covers this.  It says while GSA includes the SCA clauses and wage determinations into the contract for various labor categories, the ordering contracting officer determines whether the SCA applies to the task order and labor categories when they place the order.  I’m still using SCA out of habit instead of SCLS.

@formerfedI saw that GSA link, but I don't accept it as authoritative, and I do not trust it. Why should I? It is inconsistent with FAR 52.216-18(b), and it does not cite an FSS contract clause or a GSA or DOL regulation that expressly provides for the procedure it describes.

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@formerfedThe "are subject to" provision of FAR 52.216-18(b) has been invoked in 37 board of contract appeals decisions, five Court of Federal Claims decisions, six Federal Circuit decisions, and in one amicus curiae brief submitted to the Supreme Court. If the government is going to write such clauses, it should conduct its affairs in strict conformity with their terms—no "innovative" shortcut screwing around. In short, it should obey its own #@&&!* rules and communicate clearly about exceptions and deviations!

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@Vern Edwards I remembered something from a couple years.  Labor responded to a GSA question on whether the SCA applied to a government wide IDIQ contract for telecommunication services.  One of the exceptions of the SCA is services subject to the Communications Act.  While not the same thing as discussed here, the interesting point is DOL said “…task orders are the ‘official contractual mechanism’ agencies use for ordering services…”

https://interact.gsa.gov/sites/default/files/EIS Bulletin Volume 14 v1.0 (11.18.20).docx

The response goes on the say agencies must evaluate applicability at the task order level.  What’s funny is it took DOL a year to reply.

GSA could do everyone, contractors included, a service if they simply were clear about these issues and address them in solicitations and contracts.

I searched more and couldn’t find anything else.

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18 hours ago, formerfed said:

I remembered something from a couple years.  Labor responded to a GSA question on whether the SCA applied to a government wide IDIQ contract for telecommunication services.  One of the exceptions of the SCA is services subject to the Communications Act.  While not the same thing as discussed here, the interesting point is DOL said “…task orders are the ‘official contractual mechanism’ agencies use for ordering services…”

@formerfedThe DOL's rules for implementation of the Service Contract Act are in 29 CFR part 4, Labor Standards for Federal Service Contracts. I searched that regulation for any mention of the word "order." The word appears 105 times. I looked at each and every mention. None of those mentions refer to delivery orders or task orders. In fact, the phrase "task order" does not appear anywhere in 29 CFR. In short, I found nothing, NOTHING, in DOL's official rules that support what it supposedly said to GSA.

@Contractors—Don't trust what government personnel say about rules that cannot back up by citing regulation, contract, and authoritative interpretation. Informal communications, such as the ones cited by formerfed, are worthless in my opinion. If you rely on them and they turn out to be wrong, they will not provide you with a reliable defense.

The United States has created a system of procurement rules—statutes (positive and nonpositive law), executive orders, regulations, policies, handbooks, website postings, and case law—so voluminous, badly written, convoluted, and complex that no one fully understands all of it or even a substantial part of it. It's madness.

If you have a question about what a law, regulation, or contract clause requires of you, and if you are potentially at risk of noncompliance, then consult an attorney who practices in that field. Get a legal opinion. Then keep your fingers crossed. Most contractors don't get into serious trouble when they break a rule, because no one spots it or does anything about it. But every now and then...

It's too bad that it is this way, but that's the system our government has created.

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On 12/29/2021 at 8:07 AM, CuriousContractor_22 said:

I have seen agencies issue task orders under GSA schedules and state the task order it is not SCA applicable because they believe all employees will be bona fide executive, administrative or professional employees.

 

13 hours ago, Vern Edwards said:

Don't trust what government personnel say about rules

In an attempt add clarity let me offer this.  The "rules" are dictated by the GSA FSS contract.

"Service Contract Labor Standards (SCLS) Schedule contracts contain both SCLS and non-SCLS labor categories. Bona-fide executive, administrative, and professional labor categories are exempt from the SCLS. GSA has applied the SCLS at the Schedule-contract level where applicable. OCOs may order, as ancillary support, any labor typically found in the Department of Labor’s “Service Contract Act Directory of Occupations” if this labor is deemed necessary to deliver a total mission solution integrated across professional disciplines and/or the enterprise. In this situation, it is the responsibility of the OCO to ensure the SCA is properly applied and administered to any non-Schedule labor categories."  (emphasis added)  REF - https://www.gsa.gov/cdnstatic/MAS_Ordering_Quick_Reference_Guide_FINAL_508.pdf 

In other words a GSA FSS contract with a particular contractor has pricing by labor category.  For each labor category priced GSA has applied SCLS or in other words determined if the labor category is SCLS applicable or not.  

An Ordering Contracting Officer (OCO) errs in stating that the categories are or are not exempt as GSA has already done so.  In an "Order"  quote the GSA FSS contractor will propose labor categories and their respective pricing to get the work done.  The OCO has no authority to suggest the category is this or that with regard to SCLS, as noted this has already been done at the GSA FSS contract level.    

If a OCO asks for a labor category not priced in the contractor's particular GSA FSS it is a non-Schedule (open market) labor category.

To understand this further consider the following wording from the current solicitation on the street for various categories/SINS for GSA FSS.  Go here https://sam.gov/opp/ec77a8ef4af24c229fc199cb96af7f55/view and wade through as I did and you will find this language in the "Office Management_Attachment" document.   By comparison I suggest a look see at "Information Technology_Attachment" document as I think it will open eyes that a CO can not just willy nilly suggest SCA does not apply, again GSA has already done so.  (PS Hint - search all documents you might download from the solicitation site  on the term "SCLS")

"Service Contract Labor Standards and Health and Welfare: The Service Contract Labor Standards (SCLS) applies to all nonprofessional services to be provided under this Schedule except for any pricing offered for services outside of the United States. The SCLS index of applicable wage determinations can be viewed at beta.sam.gov. Some of the proposed labor categories may be subject to the SCLS (usually nonprofessional categories). As such, the Offeror should verify that its proposed base rates and fringe benefit rates for these labor categories meet or exceed the SCLS wage determination rates and fringe benefits for the areas included in the geographic scope of the contract (i.e., nationwide). SCLS wage determination(s), including determination number, revision date, state and counties for the preponderance of work location must be submitted. *When submitting Labor Categories subject to SCLS Wage Determination (WD), the offeror is required to provide rates for their intended places of performance along with any supporting documentation. The offeror should indicate any differences in WD base rates for proposal pricing, for instance if Accounting Clerk I is being proposed for a lower WD base rate than Janitor, the appropriate WD should be indicated. The contractor is responsible to adjust their proposal and for paying the appropriate WD for the locality for the intended performance local. Offerors must comply with applicable SCLS wage determination rates and fringe benefits regardless of the price proposed and awarded on any resultant Schedule contract. The Offeror may be required to submit supporting documentation for the proposed rates that will allow the contracting officer to conduct a cost analysis to determine that offered prices are fair and reasonable. Schedule contractors must comply with the base rate and fringe benefit rate requirements of the prevailing rate SCLS Wage Determination (WD) Revision Number currently incorporated into the GSA Schedule contract. No prevailing rate WD may be incorporated into a task order as the order may then be in conflict with the Schedule contract terms and conditions."

 

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3 hours ago, C Culham said:

In an attempt add clarity let me offer this.  The "rules" are dictated by the GSA FSS contract.

Not quite.

Generally, there is a hierarchy of rules, starting with statutes, then regulations (in the case of the SCA, DOL, then FAR, then FAR Supps). Contract terms implement those rules. If the terms of a contract are inconsistent with a higher-level rule, a court or board of contract appeals is likely to toss or ignore the contract terms. Contract deviations must be properly authorized.

See Nash et al., Formation of Government Contracts, 4th ed., II. Contracting Powers, C. Contracts Varying from Statutory or Regulatory Requirements, pp. 69 - 81.

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2 hours ago, Vern Edwards said:

Not quite.

Generally, there is a hierarchy of rules, starting with statutes, then regulations (in the case of the SCA, DOL, then FAR, then FAR Supps). Contract terms implement those rules. If the terms of a contract are inconsistent with a higher-level rule, a court or board of contract appeals is likely to toss or ignore the contract terms. Contract deviations must be properly authorized.

See Nash et al., Formation of Government Contracts, 4th ed., II. Contracting Powers, C. Contracts Varying from Statutory or Regulatory Requirements, pp. 69 - 81.

Okay so I mis-spoke but in the case of the matter raised in this thread GSA's FSS solicitation process and wording in finalized contract(s) is consistent with the rules.  Any way you cut it the implied actions by the "agencies" that the OP references are not consistent with the rules and the contract.

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39 minutes ago, C Culham said:

GSA's FSS solicitation process and wording in finalized contract(s) is consistent with the rules. 

If you say so. I don't know.

I haven't participated in or studied that process, and I haven't studied the contract in question. Apparently, you have done those things.

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Just now, Vern Edwards said:

If you say so. I don't know.

I haven't participated in or studied that process, and I haven't studied the contract in question. Apparently, you have done those things.

The process yes, but not "the contract" as by my read I could not pinpoint a specific contract mentioned by the OP.   The OP's stated questions appeared to be in general with regard to GSA schedule contracts and SCA.

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GSAs position is they have no idea what agency requirements are and what task orders might look like.  Therefore they don’t know when and where the SCA applies to individual agency requirements.  

They decided the best approach is to establish rates for some labor categories assuming the SCA applies but also knowing those same labor categories might not apply in all situations.  Their FSS contracts then are awarded on the basis of SCA coverage. That leaves agency contracting officers the latitude to decide if the required work is SCA based or not and how to proceed.  


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2 hours ago, formerfed said:

GSAs position is they have no idea what agency requirements are and what task orders might look like.  Therefore they don’t know when and where the SCA applies to individual agency requirements.  

They decided the best approach is to establish rates for some labor categories assuming the SCA applies but also knowing those same labor categories might not apply in all situations.  Their FSS contracts then are awarded on the basis of SCA coverage. That leaves agency contracting officers the latitude to decide if the required work is SCA based or not and how to proceed.  

 

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This seems converse to the references I have posted.   GSA solicitations request contractors to provide rates that meet SCA.  GSA contracts say SCA applies.  Additionally GSA instructions on use of schedules indicate that GSA has evaluated schedule hourly rates with regard to application of SCA.

I will agree that agencies are allowed latitude in negotiating more favorable rates, which might include whether a labor category price could be reduced but their instructions imply that such a category, where SCA is determined to not apply, is a non-schedule labor category.  

Example - GSA solicits pricing.  Contractor says here are my rates and for these labor categories SCA applies and for these , exemption applies.   GSA evaluates and agrees or disagrees, negotiates as appropriate and the rates become the schedule pricing.  Yet the labor category is determined to be applicable to SCA or exempted under SCA.   A labor category can not have it both ways, sometimes SCA and sometimes not.  I say this with the reminder that the SCA Directory of Occupations determines the labor category to which SCA applies.   If the tests for SCA exemption for administrative, clerical and professional apply GSA would have already determined that pursuant to SCA.  I view exemption as different than not applicable as the exemption is part of SCA.   

You referenced information regarding IT positions in a previous post.   Consider this from the current GSA solicitation on the street.....

Cloud related IT professional labor categories are within scope of this SIN. Cloud related IT professional labor categories are not subject to adherence to the NIST definition of cloud computing; therefore, no technical response is required for a labor proposal. Non-professional labor categories subject to Service Contract Labor Standards (SCLS) (e.g., IT help desk support) that are incidental to and used solely to support specific Cloud related IT professional labor categories and/or fixed-price professional services solutions must be offered under a different SIN that specifically covers the proposed services.

Or in other words if an entity needed non-professional labor categories for IT they would go to another GSA FSS SIN to get them. 

 

 

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@formerfed

I just stumbled on this.  No intent to pile on.  Do not even know if it is the most current case law.  Just thought it was interesting.  Maybe the best advice to the OP is that if they were to encounter the situation portrayed on a specific contract action they may want to ask the GSA CO if the agency is doing something correct with regard to SCA.

https://www.cbca.gov/files/decisions/2017/O'ROURKE_03-31-17_5458__CONSULTIS_OF_SAN_ANTONIO_INC.pdf

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2 hours ago, C Culham said:

A labor category can not have it both ways, sometimes SCA and sometimes not.

C Culham:  Respectfully, your first post included a link to the DOL Field Operations Handbook Chapter 14. One of the exemptions and exclusions listed at 14c07, states: “…For example, a contract for professional services performed essentially by bona fide professional employees, with the use of service employees being only a minor factor in contract performance, is not covered by the SCA...” Paragraph (b) of that section mentions a 10 to 20 percent guideline to determine whether there is more than a minor use of service employees.  As an example, if I were performing a study which ordered 900 hours of engineering services, and the report required 100 hours of a clerk-typist; it seems as though the clerk-typist would be exempt from SCLS.  But if that same study required 750 hours of engineering services and 250 hours of a clerk typist, then clerk-typist would not be exempt.  Agree... disagree?

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Is the following plausible?

1. The SCLS applies to contracts, as prescribed by the SCA, DOL regulations, and FAR 22.1003.  The key applicability rule is the "principle purpose test" prescribed by FAR 22.1003-1.

2. Under contract, the SCLS are implemented by the SCLS clause, FAR 52.222-41.

3. The statute, regulations, and contract clause require that contractors compensate and manage a specific category of contract workers in certain ways. That specific category of workers is referred to and defined in 29 CFR 4.113(b) as "service employees," of which there are many different classifications.

4. By ordinary standards of contract interpretation, if an agency issues an IDIQ contract that includes the SCLS clause, then pursuant to FAR 52.216-18(b), each task order is "subject to" the clause, no matter what its principle purpose. Nothing I could find in 29 CFR part 4, FAR Subpart 22.10, or FAR 52.222-41 provides for application of the principle purpose test to individual task orders. Did I miss something?

5. Thus, assuming I haven't missed something, under an IDIQ contract containing FAR 52.222-41, under an individual task order that requires work primarily by professionals but requires support by service employees, the contractor would have to compensate and manage the service employees in accordance with FAR 52.222-41. It doesn't matter that the principle purpose of of the task order is to obtain the services of professionals, because all orders are "subject to" FAR 52.222-41. In other words, under a contract subject to FAR 52.222-41, service employees are to be compensated and managed in  accordance with FAR 52.222-41, regardless of the task order to which they have been assigned. The clause applies to the contract as a whole.

6. But an agency could issue an IDIQ contract with one line item for task orders primarily for professional services, not subject to the SCLS and with a clause set that does not include FAR 52.222-41, and one line item for task orders primarily for the services of service employees, subject to the SCLS and with a clause set that does include 52.222-41. See my Briefing Paper on contract line items, which is posted at Wifcon in Articles. In that case, FAR 52.216-18(b) would be interpreted and applied accordingly. Then, service employees working under a professional services task to which 52.222-41 does not apply would not be covered by the clause, while service employees working under a service employee task would be covered.

Plausible?

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Quote

A labor category can not have it both ways, sometimes SCA and sometimes not. 

Sure it can at least in the context discussed here.  An ordering agency has a task order requirement.  The agency decides the work involved.  A contractor responds with a proposal that includes one or more labor categories and associated rates.  It’s not the labor title that decides whether the work is exempt or not.

This frequently happens with IT services.  Several job titles such as system analysts, developers and programmers are covered by Wage Determinations.  The exact nature of the work performed determines if the work is SCA covered and not the job title.  The key thing is contractors are proposing using contract categories and rates and in response to an agency need.  

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9 hours ago, Vel said:

Agree... disagree?

Agree.  However I would offer this is a complicated discussion in that there is the general standards of SCA and then there is the specific standards as related to a GSA FSS.  Along the same thoughts that Vern has brought up in his most recent post and using some general references that I have already noted (remember the OP has not pinpointed a specific GSA FSS contract).....

GSA requires a contractor to provide information during the solicitation process as I have previously noted.  I directed attention to a solicitation via link currently out on the street.  Here is another excerpt from it (in italics at the very end of my comments and question).   I know I am cherry picking but I am trying to keep my post as brief as possible.  I also want to note that if you look at the referenced solicitation, and as I already noted in a previous post, with regard to a specific SIN GSA does not require SCA compliance info.  Again I quote the language with regard to IT - "Cloud related IT professional labor categories are not subject to adherence to the NIST definition of cloud computing; therefore, no technical response is required for a labor proposal."

So in consideration of the below quote the question loops back to you, considering what GSA asks for with regard to compliance to SCA in the solicitation/contract   in establishing pricing for a specific labor category (CLIN) on a specific GSA FSS contractors contract, can the contractor have it both ways, sometimes have that contract labor category SCA and sometimes not?  

"Applicable to this solicitation (Service Contract Labor Standards 52.222-41, and related clauses 52.222-17, 52.222-42, 52.222-43, 52.222-49, and 52.222-55) (A) The Service Contract Labor Standards (SCLS), formerly known as the Service Contract Act (SCA) applies to some nonprofessional services to be provided under this Schedule excluding pricing offered for services outside of the United States. The SCLS wage determinations applicable to this solicitation and resultant contract are located on the MAS roadmap. Some of the proposed labor categories may be subject to the SCLS (usually nonprofessional categories and fixed-price services). As such, the offeror should verify that its proposed base rates and fringe benefit rates for these labor categories meet or exceed the SCLS wage determination rates and fringe benefits for the areas included in the geographic scope of the contract (i.e., nationwide); the offeror will be required to comply with applicable SCLS wage determination 47QSMD20R0001 Refresh: 0009 Section I A. Instructions to Offerors Page: 13 of 141 locality rates and fringe benefits regardless of the price proposed and awarded on any resultant Schedule contract. The offeror may be required to submit supporting documentation for the proposed rates that will allow the contracting officer to conduct price analysis to determine that offered prices are fair and reasonable. (B) Schedule contractors must comply with the base rate and fringe benefit rate requirements of the prevailing SCLS Wage Determination (WD) Revision Number currently incorporated into the GSA Schedule contract. Task orders may not incorporate WDs different from those incorporated into the Schedule contract, as the order may then be in conflict with the Schedule contract terms and conditions. However, Schedule contractors must comply with the WDs incorporated into the Schedule contract based on the rate applicable to the locality in which the work is to be performed, regardless of the pricing proposed and awarded on the contract. WDs based on collective bargaining agreements (CBAs) may be incorporated into a task order if the task order is found to be a successor contract as used in FAR Subpart 22.10; a CBA WD would be applicable only to the task order it is incorporated into and no other orders under that Schedule contract. (C) In the price proposal template (PPT), indicate which of the proposed labor categories or fixed price services are subject to the SCLS by placing a double asterisk (**) next to the labor category name or fixed price service. (D) For each SCLS eligible contract labor category or fixed price service, complete the following information in the below spreadsheet format directly in eOffer (labor categories shown are for example purposes): SCA/SCLS Matrix SCLS Eligible Contract Labor Category/Fixed Price Service SCLS Equivalent Code Title WD Number Secretary 01115 General Clerk I 052059 Driver 31361 Truck driver, Light Truck 052059 Engineering Technician 29081 Engineering Technician I 052059 Administrative Assistant 01011 Accounting Clerk I 052059 (E) The following language must be inserted below the SCLS/SCA matrix in the authorized price list posted on GSA Advantage: "The Service Contract Labor Standards, formerly the Service Contract Act (SCA), apply to this contract and it includes SCLS applicable labor categories. Labor categories and fixed price services marked with a (**) in this pricelist are based on the U.S. Department of Labor Wage Determination Number(s) identified in the SCLS/SCA matrix. The prices awarded are in line with the geographic scope of the contract (i.e., nationwide)."

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