Most SCA failures start the same way: the contract was set up correctly at award, and then nobody re-ran the math when the wage determination changed. The gap between reading a WD and correctly applying it across localities, benefit structures, and option years is where the back-pay exposure lives. My work closes that gap and documents the closing, so what you hand a Wage and Hour investigator is a file, not an explanation.
1,500+ SCA employees administered
DoD NGEN program
15+ years federal contractor HR
What the work covers
- Wage determination analysisReading and applying WDs across job classifications and localities, including the mapping decisions that quietly create misclassification exposure.
- Fringe benefit and H&W structuringBona fide plan review, annualization math, cash-in-lieu documentation, and the gap between your benefit spend and the current H&W rate.
- Conformance proceduresSF-1444 requests for unlisted classifications, prepared and justified so the contracting officer can approve them.
- Successor contractor transitionsRecompete workforce planning under the 2026 rules: clause review, Section 4(c) CBA exposure, and day-one wage and benefits compliance.
- DOL audit preparation and responseProactive file review before an investigator asks, and organized support when one does.
How an engagement runs
- A 30-minute consult to scope the problem. You bring the contract and the wage determination; I tell you honestly whether the work is worth doing.
- A fixed-fee proposal with a defined deliverable and a date. No hourly meter.
- The work, done directly by me, with a written work product your team and your counsel can rely on and an auditor can follow.
Common starting points
The H&W rate changed and nobody re-ran the fringe math. A recompete is 60 days out. A DOL letter arrived. A 1099 population touches SCA-covered work. An option year is about to incorporate a new wage determination. If one of these sounds familiar, the fastest next step is the consult.