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.