Are the HUD contracts subject to SCA?
Yes! See the second file down on the right side under “Solicitation 1” and “May 25, 2012”, then scroll within the file to the top/intro of page 102 (as labeled, page 100 in reality) and the bottom of page 103 (again, as labeled).
Have I indeed paid my office staff less than what the government requires?
Put your hand up if you think so, and then hold it there. With the other hand visit the US Department of Labor (DoL). Then, look up your county and state, hit “NO“, hit “NO,” and then scroll down, and perhaps use the “Print Friendly Version,” and then see what the minimum wage for “01011 – Accounting Clerk I” (or the next listing, Accounting Clerk II) and “01320 – Service Order Dispatcher,” two classes that describe much of your office staff members’ functions. Of course, the government lets you pick the most appropriate designation, but if they find that the person better fits a different classification then they will make the choice.
After this, scroll down to almost the end of the page and find the following:
ALL OCCUPATIONS LISTED ABOVE RECEIVE THE FOLLOWING BENEFITS: HEALTH & WELFARE: $3.71 per hour or $148.40 per week or $643.07 per month
So, not only do you need to be paying a certain $ amount per hour, but you need to be contributing at least $643.07 per month, tax-free, to either a health care plan or to the employee’s pocket as cash (again, tax-free). Then, there’s the issue that your employee is entitled to paid time off for all 10 of the federal holidays, not to mention an accrual of other paid time off, etc.
Okay, now keep your hand up if you think you’ve exceeded all these expectations with your office folks. Just what I thought…no hands are up now. “But no one told me about this!” Yep, and even your HUD contracting client did fully inform you they would be on the hook for any shorfalls in your employees’ pay, not you. Why? They hold a contract with the taxpayers and you do not.