Posts in Service Contract Act
Late Notice Does Not Preclude a SCA Price Adjustment, but Feeble Proof Will Bar the Claim

While the Service Contract Act (“SCA”) price adjustment clause requires contractors to submit their price adjustment prposals within 30 days of the contract modification adding a new wage determination, the Board says that requirement is not jurisdictional and doesn’t bar the claim. However, a failure of proof of actual costs will bar the recovery.

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GWAC Out of Whack: How a GWAC shifted liability for SCA violations to the Government

Ordinarily, a service contractor has the duty to compare the employee positions that will be providing service under a contract with an applicable SCA wage determination so as to ascertain how much the employees should be paid and what benefits they receive. In a recent case, the Civilian Board of Contract Appeals held that that is not always the case.

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Now You See It; Now You Don’t -- Service Contract Act Coverage of Indirect Employees

The Service Contract Act (“SCA”) covers all “service employees” working on or in connection with a government service contract. But that begs the issue of when a worker is directly working on a contract versus indirectly facilitating the performance of the work. As to where the coverage line is drawn, that depends on the contract terms and the employee’s job duties.

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DOL Investigations: Check their Math!

Responding to Department of Labor investigations is not a simple exercise. While you are required to cooperate, provide documents and access to employees, you are not obligated to accept an investigator’s findings and you can question them. But, before you push back, be thoughtful. And,don’t forget to check the math.

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What Me Worry -- New SCA H&W Rates Issued by AAM 230.

The U.S. Department of Labor issued All Agency Memorandum (“AAM”) no. 230 posting new health and welfare (“H&W”) fringe benefit rates for Service Contract Act (“SCA”) covered contracts effective July 5, 2019. The new H&W rates are $4.54 an hour, except if there is a sick leave Executive Order clause in the contract, whereupon the H&W rates are set at $4.22 an hour.

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Claims for CBA Negotiation Costs Are Not In Time and Not Subject to Any Price Adjustment In Fixed Priced Contracts

The Court of Federal Claims decsion in Just In Time Staffing maintains the long-established practice of limiting the FAR price adjustment clause to its plain language – covering the increased costs of wages and fringe benefits of the contractor’s employees and certain enumerated payroll taxes — and not to the cost to negotiate a CBA.

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