New CDS Questions and Answers-Southern CDS Manager, Terry Stumpff

Contract Delivery Services Questions and Answer by Southern CDS Manager, Terry Stumpff-March 2021
 
I hear from a lot of suppliers on "Am I being paid correctly." Am I paying my employees correctly.”  My answer to these questions is, I don't know, are you?  Lets find out.
 
One way to make sure is, ask yourself; am I following the Register of Wage Determinations Under the U.S. Department of Labor The Service Contract Act.
 
During these times of renewals and new solicitations and 2 year anniversary dates of the contracts, suppliers need to make sure that their contracts DOL Wage Determination (WD) rates are adjusted correctly by the CDS office.  This will insure that you are paying your employees correctly and save you from experiencing any violations with the Department of Labor.
 
When a contract is solicited, the CDS office includes the latest WD Revision No. and the Date of Last Revision for that geographical area of the country. This can usually be found in the last pages of a CDS solicitation or on the DOL website.  As CDS contractors, we fall under the Occupation Code Title - Driver/Caser, Foot Note (see 1) for Health & Welfare rate per hour.  The rates provided in the Revision No. is the base line minimum wage rate set for this craft.   What is not included is the actual rates in which a supplier is to pay Vacation and Holiday hourly wages.  A Supplier is required to pay Driver/Caser rate + Health & Welfare rate + Vacation rate + Holiday rate from Day 1 of service.
 
Even though the CDS office provided a copy of the Revision No. when solicited or in negotiations, the correct WD Revision rate to be enforced is the latest Date of Last Revision that Day 1 of the suppliers new service begins or on the renewal date and on the 2 year anniversary dates that they fall under.  The rates can change from time of solicitation to Day 1.  This rate change will affect your bottom line contract rate and determine if you are paying employees correctly.
 
If you insert the solicited WD rates in your proposal cost worksheet, then on Day 1 of contract the rate should adjust to the current WD rates for that date and adjust your bottom line contract rate.
 
If you do not use the WD rates in your proposal cost worksheet, then your rates will adjust accordingly to the difference in the solicited WD rate and the WD current rate and adjust your bottom line contract rate.  
 
The same goes for on the every 2 year anniversary dates.
 
It is very important that you be aware of the dates and the rates.  If you see any discrepancies, contact CDS office immediately.
 
The SCA requires that contracts not based on annual appropriations be updated every two years for purposes of incorporating the latest applicable WD. Therefore, contracts subject to the U.S. Postal Service should be updated every two years. The regulations (29 CFR 4.4) in the SCA that addresses obtaining a wage determination that will answer questions regarding adjustments to wage determinations.
 
For a copy of the determination in its entirety, please contact Edie Young-Scales at the National Office.
 
Terry N. Stumpff
President
TNStumpff Enterprises, LLC.