centre's top ten ways to minimize risk of violating the sca

1. Train your employees
   Your back office personnel and human resources department should be well-versed in SCA requirements.
   
   
2. Ensure transparency in pay stubs
   Separate out wages and fringe benefits to show clear compliance.
   
   
3. Ask your contracting officer questions
   If any questions arise as to SCA compliance, document, in writing, your questions posed to your contracting officer and/or Department of Labor to show a good faith effort.
   
   
4. Keep detailed records
   Keep extremely detailed records of wages and fringe benefits paid out under the SCA, as well as meticulous time cards. Assume that any records you generate will be reviewed in an audit.
   
   
5. Keep track of your employees
   If an employee works on both SCA-covered and non SCA-covered contracts, keep track of him or her. Otherwise you may be held to an adjustment of his wages on all hours worked, not just those that are SCA-covered.
   
   
6. Keep updated about the SCA rules and regulations
   If statutes and regulations affecting SCA obligations are updated or changed, you are required to know about them. Subscribe to a government contracts newsletter to keep abreast of important changes.
   
   
7. Get legal help
   If a question arises about which you are unsure, ask an attorney. Although this may seem like a pricey investment, it is worth it in context of having to face stiff penalties for violating the SCA which can include debarment for a period of time.
   
   
8. Know that there is no such thing as “averaging.”
   The requirements to pay minimum wages and fringe benefits are separate. If the minimum wage for a labor category is $20.00, and the minimum fringe benefit is $3.00, it is a violation of the SCA if you pay your employee an amount that equals $23.00 but falls beneath the minimum amount required for wages or fringe benefits. 
   
   
9. Be cognizant of holiday and vacation days for part-time and temporary employees
   Government contractors performing service contracts often employ temporary or part-time employees. This may lead to confusion relating to the holiday or vacation pay to which these employees are entitled. Whether a contractor is liable to employees for holiday or vacation pay under the SCA is a very fact-sensitive determination. 
   
   
10. Be cognizant of when the obligation to pay out lunch breaks is triggered
    Contractors have recently come under fire for failing to compensate employees for breaks taken that require them to stay “on the clock” to a degree. For example, security guards who are required to carry a gun and stay on the premises during their lunch breaks may be entitled to compensation for that period of time. Similar to the determination of whether employees are entitled to holiday or vacation pay, whether contractors must pay their employees for “breaks” is fact-sensitive.