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buddyandme

Evaluating Fringe Benifits

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I'm bringing the subject of contract specialist evaluating fringe benefits in the context of contracts that include a DOL SCA wage determination. Over the past several years our company has bid on several service contracts for admin support services. We won some and lost some but recently have lost more than we have won. We always ask for a debrief and for the most part are given one. I've noticed a troubling trend that indicates many winning contractors are not including the mandatory fringe benefit in their proposals. We can make this comment because we almost always use the lowest DOL labor category available that best matches the requirement and only include a very small mark-up so we can remain competitive but still make a profit. If we lose we only lose by a small margin but recently the gap has widened.

Math does not lie. After comparing what the winning contractor bid with ours we have often found there is no way possible the winning contractor included the fringe benefit. Losing a bid in a competitive environment is just part of the game but when contractors purposely violate the LAW and the contracting specialist does not recognize what is obviously going on, I become concerned. I understand that for a majority of these procurements contractors are not required to provide a break out of their price. I'm just saying they should be more aware of this trend and take steps to make sure the hourly rates paid to the employees includes the mandatory fringe benefit.

This can be done by doing more that just adding the wage determination and expect that the contractor will read and follow its direction. I believe contract specialists should use some simple mechanism that requires contractors to acknowledge they have included the fringe benefit in their total cost. They could also require a simple break-out of the contractor's price so they can verify the fringe benefit has been included.

In absence of any support by the government in this matter, contractors are left to police themselves. It?s not desirable to complain to the contracting officer, although I have on occasion. And going to DOL is a real struggle since they only want to hear from the contracting officer or an employee of the contractor who is not being paid the fringe benefit.

I sure would appreciate any comments related my post. Both from the government who may have already instituted some measures to ensure that the contractors have included the fringe benefit and from the other contractors who may have experienced this same problem.

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buddyandme,

An offeror may propose a price that is below SCA wage and benefit rates. See Group GPS Multimedia, B-310716, January 22, 2008.

On a fixed-price contract, as here, under which the awardee is required to pay the actual SCA wages and benefits out of whatever price it offers, and where the proposal contains no indication that the company will not meet its statutory obligations in this regard, labor rates or benefits that are less than the SCA-required rates or benefits may constitute a below-cost offer but one which is legally unobjectionable. Biospherics, Inc., B-285065, July 13, 2000, 2000 CPD para. 118 at 12. That is, regardless of what wage rates K-MAR used in calculating its proposed price, it will still be required to compensate its employees at the appropriate prescribed SCA wage rates. Free State Reporting Inc., B-259650, Apr. 4, 1995, 95-1 CPD para. 199 at 7. Further, the determination of prevailing wages and fringe benefits, and the issuance of appropriate wage determinations under the SCA, are matters for the Department of Labor (DOL). Concerns with regard to establishing proper wage rate determinations or the application of the statutory requirements should be raised with the Wage and Hour Division in DOL, the agency that is statutorily charged with the implementation of the Act. See 41 U.S.C. sections 353(a); 40 U.S.C. sect. 276a; SAGE Sys. Techs., LLC, B-310155, Nov. 29, 2007, 2007 CPD para. 219 at 3. Thus, to the extent the protester?s contention is that K-MAR may not properly categorize its employees under the SCA or compensate some of its employees at the required SCA wage rate, it is not a matter for our consideration, since the responsibility for the administration and enforcement of the SCA is vested in DOL, not our Office, and whether contract requirements are met is a matter of contract administration, which is the function of the contracting agency. SAGE Sys. Techs., LLC, supra; Free State Reporting Inc., supra, at 7 n.7.

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In all honesty, I never gave the subject much thought. We used to get the appropriate wage determination, include it in the solicitation, and award the contract. We assumed the winning contractor would pay the minimums and someone (usually employees) would complain to DOL if they didn't.

At best, a CO has the winning contractor's bundled hourly rate (assuming it's not a cost reimbursable contract). Often it's just a total firm fixed price rate that may be for the total job or a monthly rate that includes multiple positions. It's very unlikely a CO can look at the wage determination and figure out a company isn't paying the required fringe benefits. That bundled hourly rate has labor, fringe benefits, and all the indirects, plus profit.

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Why are you assuming you are losing because of fringe benefits? Contracting officers are not required to police the contractors on fringe and breakout of pay. When we get a labor contract, we are required to look at the wage and what labor classification the contractor has proposed and make sure there is enough money to cover wage rate. Contractors are required to make sure they pay the correct wages. As a contracting officer, you would not accept a labor rate that did not cover the minimum. How do you know what they are paying them for fringe? The only monetary rate is the health and welfare. The rest would be covered in their G&A/overhead costs. See this from a wage rate I pulled:

ALL OCCUPATIONS LISTED ABOVE RECEIVE THE FOLLOWING BENEFITS:

HEALTH & WELFARE: $3.50 per hour or $140.00 per week or $606.67 per month

VACATION: 2 weeks paid vacation after 1 year of service with a contractor or

successor; 3 weeks after 8 years, and 4 weeks after 15 years. Length of service

includes the whole span of continuous service with the present contractor or

successor, wherever employed, and with the predecessor contractors in the

performance of similar work at the same Federal facility. (Reg. 29 CFR 4.173)

HOLIDAYS: A minimum of ten paid holidays per year, New Year's Day, Martin Luther

King Jr's Birthday, Washington's Birthday, Memorial Day, Independence Day, Labor

Day, Columbus Day, Veterans' Day, Thanksgiving Day, and Christmas Day. (A

contractor may substitute for any of the named holidays another day off with pay in

accordance with a plan communicated to the employees involved.) (See 29 CFR 4174)

THE OCCUPATIONS WHICH HAVE NUMBERED FOOTNOTES IN PARENTHESES RECEIVE THE FOLLOWING:

1) COMPUTER EMPLOYEES: Under the SCA at section 8(B), this wage determination does

not apply to any employee who individually qualifies as a bona fide executive,

administrative, or professional employee as defined in 29 C.F.R. Part 541. Because

most Computer System Analysts and Computer Programmers who are compensated at a rate

not less than $27.63 (or on a salary or fee basis at a rate not less than $455 per

week) an hour would likely qualify as exempt computer professionals, (29 C.F.R. 541.

400) wage rates may not be listed on this wage determination for all occupations

within those job families. In addition, because this wage determination may not

list a wage rate for some or all occupations within those job families if the survey

data indicates that the prevailing wage rate for the occupation equals or exceeds

$27.63 per hour conformances may be necessary for certain nonexempt employees. For

example, if an individual employee is nonexempt but nevertheless performs duties

within the scope of one of the Computer Systems Analyst or Computer Programmer

occupations for which this wage determination does not specify an SCA wage rate,

then the wage rate for that employee must be conformed in accordance with the

conformance procedures described in the conformance note included on this wage

determination.

Additionally, because job titles vary widely and change quickly in the computer

industry, job titles are not determinative of the application of the computer

professional exemption. Therefore, the exemption applies only to computer employees

who satisfy the compensation requirements and whose primary duty consists of:

(1) The application of systems analysis techniques and procedures, including

consulting with users, to determine hardware, software or system functional

specifications;

(2) The design, development, documentation, analysis, creation, testing or

modification of computer systems or programs, including prototypes, based on and

related to user or system design specifications;

(3) The design, documentation, testing, creation or modification of computer

programs related to machine operating systems; or

(4) A combination of the aforementioned duties, the performance of which

requires the same level of skills. (29 C.F.R. 541.400).

2) APPLICABLE TO AIR TRAFFIC CONTROLLERS ONLY - NIGHT DIFFERENTIAL: An employee is

entitled to pay for all work performed between the hours of 6:00 P.M. and 6:00 A.M.

at the rate of basic pay plus a night pay differential amounting to 10 percent of

the rate of basic pay.

3) AIR TRAFFIC CONTROLLERS AND WEATHER OBSERVERS - NIGHT PAY & SUNDAY PAY: If you

work at night as part of a regular tour of duty, you will earn a night differential

and receive an additional 10% of basic pay for any hours worked between 6pm and 6am.

If you are a full-time employed (40 hours a week) and Sunday is part of your

regularly scheduled workweek, you are paid at your rate of basic pay plus a Sunday

premium of 25% of your basic rate for each hour of Sunday work which is not overtime

(i.e. occasional work on Sunday outside the normal tour of duty is considered

overtime work).

HAZARDOUS PAY DIFFERENTIAL: An 8 percent differential is applicable to employees

employed in a position that represents a high degree of hazard when working with or

in close proximity to ordinance, explosives, and incendiary materials. This

includes work such as screening, blending, dying, mixing, and pressing of sensitive

ordance, explosives, and pyrotechnic compositions such as lead azide, black powder

and photoflash powder. All dry-house activities involving propellants or explosives.

Demilitarization, modification, renovation, demolition, and maintenance operations

on sensitive ordnance, explosives and incendiary materials. All operations

involving regrading and cleaning of artillery ranges.

A 4 percent differential is applicable to employees employed in a position that

represents a low degree of hazard when working with, or in close proximity to

ordance, (or employees possibly adjacent to) explosives and incendiary materials

which involves potential injury such as laceration of hands, face, or arms of the

employee engaged in the operation, irritation of the skin, minor burns and the

like; minimal damage to immediate or adjacent work area or equipment being used.

All operations involving, unloading, storage, and hauling of ordance, explosive, and

incendiary ordnance material other than small arms ammunition. These differentials

are only applicable to work that has been specifically designated by the agency for

ordance, explosives, and incendiary material differential pay.

** UNIFORM ALLOWANCE **

If employees are required to wear uniforms in the performance of this contract

(either by the terms of the Government contract, by the employer, by the state or

local law, etc.), the cost of furnishing such uniforms and maintaining (by

laundering or dry cleaning) such uniforms is an expense that may not be borne by an

employee where such cost reduces the hourly rate below that required by the wage

determination. The Department of Labor will accept payment in accordance with the

following standards as compliance:

The contractor or subcontractor is required to furnish all employees with an

adequate number of uniforms without cost or to reimburse employees for the actual

cost of the uniforms. In addition, where uniform cleaning and maintenance is made

the responsibility of the employee, all contractors and subcontractors subject to

this wage determination shall (in the absence of a bona fide collective bargaining

agreement providing for a different amount, or the furnishing of contrary

affirmative proof as to the actual cost), reimburse all employees for such cleaning

and maintenance at a rate of $3.35 per week (or $.67 cents per day). However, in

those instances where the uniforms furnished are made of "wash and wear"

materials, may be routinely washed and dried with other personal garments, and do

not require any special treatment such as dry cleaning, daily washing, or commercial

laundering in order to meet the cleanliness or appearance standards set by the terms

of the Government contract, by the contractor, by law, or by the nature of the work,

there is no requirement that employees be reimbursed for uniform maintenance costs.

The duties of employees under job titles listed are those described in the

"Service Contract Act Directory of Occupations", Fifth Edition, April 2006,

unless otherwise indicated. Copies of the Directory are available on the Internet. A

links to the Directory may be found on the WHD home page at http://www.dol.

gov/esa/whd/ or through the Wage Determinations On-Line (WDOL) Web site at

http://wdol.gov/.

REQUEST FOR AUTHORIZATION OF ADDITIONAL CLASSIFICATION AND WAGE RATE {Standard Form

1444 (SF 1444)}

Conformance Process:

The contracting officer shall require that any class of service employee which is

not listed herein and which is to be employed under the contract (i.e., the work to

be performed is not performed by any classification listed in the wage

determination), be classified by the contractor so as to provide a reasonable

relationship (i.e., appropriate level of skill comparison) between such unlisted

classifications and the classifications listed in the wage determination. Such

conformed classes of employees shall be paid the monetary wages and furnished the

fringe benefits as are determined. Such conforming process shall be initiated by

the contractor prior to the performance of contract work by such unlisted class(es)

of employees. The conformed classification, wage rate, and/or fringe benefits shall

be retroactive to the commencement date of the contract. {See Section 4.6 ©(vi)}

When multiple wage determinations are included in a contract, a separate SF 1444

should be prepared for each wage determination to which a class(es) is to be

conformed.

The process for preparing a conformance request is as follows:

1) When preparing the bid, the contractor identifies the need for a conformed

occupation(s) and computes a proposed rate(s).

2) After contract award, the contractor prepares a written report listing in order

proposed classification title(s), a Federal grade equivalency (FGE) for each

proposed classification(s), job description(s), and rationale for proposed wage

rate(s), including information regarding the agreement or disagreement of the

authorized representative of the employees involved, or where there is no authorized

representative, the employees themselves. This report should be submitted to the

contracting officer no later than 30 days after such unlisted class(es) of employees

performs any contract work.

3) The contracting officer reviews the proposed action and promptly submits a report

of the action, together with the agency's recommendations and pertinent

information including the position of the contractor and the employees, to the Wage

and Hour Division, Employment Standards Administration, U.S. Department of Labor,

for review. (See section 4.6(B)(2) of Regulations 29 CFR Part 4).

4) Within 30 days of receipt, the Wage and Hour Division approves, modifies, or

disapproves the action via transmittal to the agency contracting officer, or

notifies the contracting officer that additional time will be required to process

the request.

5) The contracting officer transmits the Wage and Hour decision to the contractor.

6) The contractor informs the affected employees.

Information required by the Regulations must be submitted on SF 1444 or bond paper.

When preparing a conformance request, the "Service Contract Act Directory of

Occupations" (the Directory) should be used to compare job definitions to insure

that duties requested are not performed by a classification already listed in the

wage determination. Remember, it is not the job title, but the required tasks that

determine whether a class is included in an established wage determination.

Conformances may not be used to artificially split, combine, or subdivide

classifications listed in the wage determination.

I think you are blowing smoke in the wrong direction. You need to see DOL regarding wage rates. I suspect you either have too many hours for a job, have too high an overhead or profit rate, or the wrong classification for the job and that is why you are not winning. Remember it is DOL who investigates. Contracting Officers only responsibility is to make sure that there is enough money to cover the wage rate.

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As a contracting officer, you would not accept a labor rate that did not cover the minimum.

What do you mean by that? Accept in a proposal? If that's what you mean, go back and read my earlier post.

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Guest Vern Edwards
Contracting Officers' only responsibility is to make sure that there is enough money to cover the wage rate.

If the competition is for a fixed-price contract, then a CO has no such responsibility, unless price realism is one of the evaluation factors. Price realism is not a mandatory evaluation factor. See FAR 15.404-1(d)(3). In fact, price realism is to be considered in competitions for fixed-price contracts, other than fixed-price incentive contracts, only in "exceptional cases."

If the contract will be cost-reimbursement, then cost realism is a mandatory factor. See FAR 15.404-1(d)(2).

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buddyandme,

An offeror may propose a price that is below SCA wage and benefit rates. See Group GPS Multimedia, B-310716, January 22, 2008.

Thanks for the GAO protest references, I found them informative. So yes, I understand DOL is the enforcer but when does it become a matter for the contracting folks to look into? Is contracting response to the contractor always going to be, not my problem go see DOL.

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Guest Vern Edwards

An offeror promises to comply with the terms of the contract. If the offeror is responsible under FAR Subpart 9.1, there is no reason for the CO to enquire further. The CO is not a nanny. If the offeror does not comply, the Department of Labor can ruin them.

If low prices are a condition of the market, find a way to compete or find another business.

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If the evaluation criteria includes FAR 15.404-1© Cost Analysis, than a review of the proposed fringe dollars should include verification of compliance with the H&W requirements of the WD. This is usually accomplished by exception, where total fringe dollars less Paid Time Off (based on proposed) and known Payroll Additives (FICA @ 7.65%) are subtracted from the available fringe dollars to insure that adequate money is left over to cover the H&W requirement (currently $3.50 per hour).

Example Fringe Dollars of $15,000 less Paid Time Off of $4,800; less FICA of $3,825; less H&W of $7,280; leads me to suspect that their may not be enough money available, since you may still have a requirement for FUI, SUI, WC, Employer 401 Contributions and etc.

My question has always been, how do contractors propose Paid Time Off for Sick Leave (Which I see is now noted by DOL as part of the H&W Benefit)? Is the current $3.50 per hour H&W benefit applied to both Productive and Non Productive Time or just Productive Hours. What is an acceptable level of Time Off Without Pay , or Unpaid Hours for Employee Turnover and Other Time Off. Lately, I have been asking offerors to explain Unpaid Time in Cost Narratives but do not propose any Unpaid Time.

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If the evaluation criteria includes FAR 15.404-1? Cost Analysis, than a review of the proposed fringe dollars should include verification of compliance with the H&W requirements of the WD. This is usually accomplished by exception, where total fringe dollars less Paid Time Off (based on proposed) and known Payroll Additives (FICA @ 7.65%) are subtracted from the available fringe dollars to insure that adequate money is left over to cover the H&W requirement (currently $3.50 per hour).

Example Fringe Dollars of $15,000 less Paid Time Off of $4,800; less FICA of $3,825; less H&W of $7,280; leads me to suspect that their may not be enough money available, since you may still have a requirement for FUI, SUI, WC, Employer 401 Contributions and etc.

My question has always been, how do contractors propose Paid Time Off for Sick Leave (Which I see is now noted by DOL as part of the H&W Benefit)? Is the current $3.50 per hour H&W benefit applied to both Productive and Non Productive Time or just Productive Hours. What is an acceptable level of Time Off Without Pay , or Unpaid Hours for Employee Turnover and Other Time Off. Lately, I have been asking offerors to explain Unpaid Time in Cost Narratives but do not propose any Unpaid Time.

You say "Which I see is now noted by DOL as part of the H&W Benefit". I am not aware that as you say "non-productive time" is part of the H&W benefit. Can you please let me know where you found this?

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Guest Vern Edwards
If the evaluation criteria includes FAR 15.404-1? Cost Analysis... .

DOECPA:

I do not understand the above clause from your post. In what sense would the criteria "include" FAR 15.404-1( c):

(1) Do you mean that the RFP would quote the FAR passage or cite it explicitly?

(2) Do you mean that the RFP would expressly state that the evaluation of cost or price would include a cost analysis?

(3) Do you mean that the source selection plan would require a cost analysis, even if the RFP didn't say so in so many words?

(4) Or do you mean something else?

Also, what is the objective of your cost analysis? Are are you trying to determine whether the offeror has proposed an estimated cost or price that is too high, or are you trying to determine whether the offerior has proposed an estimated cost or price that is high enough to cover the cost of the fringe benefits?

(1) Is it to determine the reasonableness of the estimated cost or the price (whether it is too high)?

(2) Or is it to determine the realism of the estimated cost or price (whether it is too low)?

Do you perform such an analysis of all kinds of proposals, including both proposals for cost-reimbursement contracts and fixed-price contracts, or only for cost-reimbursement contracts?

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One of my responsibilities as a member of a Cost Committee (The Team that Counts) is to make sure that Offerors comply with the Area Wage Determnation, particularly, the H&W Benefit. "Buddyandme" has stated that other Offerors are under-bidding him and he feels that they may not be in compliance with the Wage Determination.

When I work an SCA covered effort, including fixed price, I include 15.404-1 (B) and © in the TOR or RFP, and I ask for labor buildup. When proposals arrive, we review the labor build-up to verify that the Offerors have adequate money available for the benefits they state they intend to provide. If it appears the Fringe Pool, can not satisfy the required H&W benefit, that we issue an IFC, to determine if the Offeror understands the requirement. If it is a fixed price effort, and the Offeror replies that they understand the requirement, but are not concerned, their is not much we can do but transfer the information to the Management Committee. We do not include FAR 15-404-1(d) Cost Realism in our Fixed Price TOR's.

In other words, we try to verify compliance with the H&W Benefit. Oftentimes, Offerors will have Approved FPRA's that include Fringe Rates which will satify the H&W benefit at all their locations but may be too low for the local workforce. Local workforce may have more senority or slightly higher FICA costs and FPRA Pool is not adequate locally. Is it right for us to shift our cost to others? Why should other CO's have to be burdened with our indirect cost?

How do we protect the other Bidders from a buy in?

In my earlier post, I mentioned that Paid Time Off for Sick Leave was now in the DOL Wage Determination under the H&W Benefit. My question was about how much Un-Paid Leave do you expect to see in a Cost Proposal? Un-Paid leave shows up as the difference between a Full Man Year of 2,080 Hours less Direct Labor Hours (Productive Hours) ; and, Paid Time Off (Non Productive Paid Hours for Vacation, Holidays and etc.). If an Offeror develops a Cost Proposal using low productive hours and Un-Paid Leave, your funds may run out early.

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Actually even on a fixed price contract, the CO is still responsible for ensuring that the line item has the minimum wage in it. I was the lucky recipient of dealing with a labor dispute with DOL for a Contractor that was not paying her workers the correct wage rate (to the tune of $150k!!!! for one year). I can't remember where in the regulations it says all of that. It was a darn good thing I document. Because I had documented where we had questioned her rates as not meeting the minimum. If the contractor proposes rates below the minimum wage rate (this is when you are breaking wages per hour out on a fixed price contract) the CO still has to make sure the rates are above the minimum. So this contractor had crazy wages for several areas. Then for the librarian, she had enough money to just cover the wage and fringe. Nothing for overhead or profit. Same on another position. We went back to her during negotiations. She still insisted that rate. We said fine and took it. Then SHE tried to sue us for the overhead and profit that was missing from the line item even though we verified. The outcome of the investigation was she owed some of her employees hefty amounts. Thankfully I had documented the negotiations. Had we have not paid the minimum wage, we would have been required to modify the contract for the difference. Since we verified and she had enough money on the line item, she was on the hook for the whole amount.

The last I heard of that contract since I left the agency was that she was suing the agency for the amount that DOL levied against her. She didn't have a chance of he!! in winning. We let her out of her contract quietly by not renewing the option year. We could have gone after reprocurement costs. We ended up not taking the option and explaining it to her. Oh and she was suing for not taking the option too. Whatever......

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Guest Vern Edwards
Actually even on a fixed price contract, the CO is still responsible for ensuring that the line item has the minimum wage in it.

Prove that. I know of nothing in the FAR that requires that a CO verify that a proposed price is high enough to cover the minimum wage or SCA or DBA wages and fringes.

A CO may not consider the realism of a proposed fixed-price unless realism is a stated evaluation factor.

If a proposed firm-fixed price is so low that the CO suspects a mistake, then the CO must put the offeror on notice and ask the offeror to verify its offer.

Otherwise, if a CO thinks a price is too low to cover wages and fringes and that the contractor will suffer a loss, then the CO must handle it as a matter of financial responsibility.

Anyone who says otherwise had better produce a regulation or a protest decision in support.

I am not saying whether a CO should or should not verify. I say only that there is no requirement to verify.

A CO must consider the realism of a proposed estimated cost for a cost-reimbursement contract.

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In years past, I frequently requested Information Other Than Cost or Pricing Data so I could establish what rate was being paid by the Contractor for purposes of establishing a baseline for future adjustments (resulting from updated wage determinations). But, I too am unaware of any requirement to ensure that the Contractor is charging me enough to cover the minimum wage. That's a different issue than the Contractor not actually paying the minimum wage but even in that scenario my experience has been that DOL will only act on a complaint from an employee. Back in the 80's, I frequently contracted for mapping services and the industry was hard hit and it was routine for vendors to propose less than their costs. They chose to do this to cover a portion of their fixed costs. Their alternative was for their employees to sit idle so as Vern pointed out unless the vendor is going to run into financial difficulty from taking on the work then I'm not sure why I would care.

I think a more interesting question for this thread might be what to do if a Contractor submitted an adjustment (as a result of an updated wage determination) that increased its employees wages from below wage determination level up to a new minimum established in an updated determination. I don't think that scenario is handled very well in FAR 52.222-43.

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Guest carl r culham

Gns - Doesn't © of the clause address the issue? The contractor must pay either the SCA wage or the FLSA wage. If at time of requested adjustment the government is made aware of the contractor not paying either as appropriate is it not a matter requiring back wages be paid and/or turn the matter over to DOL? So the action that would result in the end would be the contractor bringing wages up to minimum for the previous performance period and allowance of adjustment in contract price for the exercised option period.

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Carl - sorry, the second paragraph in particular of my post was not very clear. The thread was discussing a vendor proposing less than the wage determination amount (not necessarily paying less). It was in that context that I wondered what to do if a Contractor submitted an adjustment (as a result of an updated wage determination) that increased the below determination wages originally "proposed" up to a new minimum established in an updated determination.

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Carl - sorry, the second paragraph in particular of my post was not very clear. The thread was discussing a vendor proposing less than the wage determination amount (not necessarily paying less). It was in that context that I wondered what to do if a Contractor submitted an adjustment (as a result of an updated wage determination) that increased the below determination wages originally "proposed" up to a new minimum established in an updated determination.

GNS, I assume that you are saying that the contract price doesn't reflect the higher wage being paid. Then a new wage decision requires a higher rate. You are wondering if the contractor is entitled to the difference between the under cost contract price and the new requirement? So a contractor that buys-in can be made whole? How would that occur?

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Guest carl r culham

Gns - With your clarification (f) of the clause then addresses the matter. What the contractor is actually paying as supported by required statement and data (payroll records) of (f) is used to determine the economic adjustment not the proposal.

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