Two clearance-flagged labor categories, pulled the same July morning, both on SIN 541611 at a customer facility. One requires a bachelor’s plus eight years and caps at $46.51 an hour; the other, a bachelor’s plus five, caps at $104.40. The clearance is constant. What moved is the labor category the work was mapped to at bid time.

Why does the labor category, not the clearance, set the ceiling?

Short answer: A labor category is a written spec of minimum education, years and duties, priced when the contractor bid the vehicle. The ceiling attaches to that spec, and two categories that both require a Top Secret clearance can price 2.24x apart.

GSA’s CALC+ Labor Ceiling Rates tool exposes not-to-exceed hourly ceilings from Multiple Award Schedule contracts, each with its education and experience gate, drawn from vendors’ Prices Proposed Templates. The user guide (version 1.6, 03/12/2026) says those prices “have been determined to be fair and reasonable.”

One disclosure first. Every dollar figure below is a ceiling bill rate, not pay. It already contains fringe, overhead, G&A and fee, and it is not what the government ends up paying: the same guide notes schedule prices are ceilings set “anticipating the opportunity to discount prices at the order level.” The arithmetic down to salary is in our piece on the wrap rate.

Source: GSA CALC+ Labor Ceiling Rates, index dated 21 July 2026; clearance levels and quoted requirements from the vendor’s published price list. Fully burdened customer-facility ceilings, not salaries. gTANGIBLE prices are contract-year-one; Ruchman (from 2015) and Strategic Operational Solutions (from 2018) carry years of escalation.

Two lines are not a market. On 21 July 2026 the keyword “Intelligence Research Analyst” returned exactly one record in CALC+, the gTANGIBLE row above, and GSA’s guide says that where a search “yields fewer than three results, then the acquisition professional should use alternate criteria to conduct another search.” Widen it and the pessimism drains. Across all 561 records “Intelligence Analyst” returned that day, clearance-flagged rates ran a median $118.27 against $133.71 unflagged, roughly 13 percent apart, not 2.24x. Narrow to the 281 customer-facility records whose title contains “Intelligence Analyst” and the median is $125.13, the minimum $49.26. Nothing there sits below $46.51. Read that line as one small business’s first-year price on a two-month-old award, not as what cleared analytic work is worth.

Treat the clearance column carefully too, because here it does not vary inside a contract. All 94 gTANGIBLE records are flagged, including the warehouseman at $28.79 whose published requirement is a NACI, a suitability investigation rather than a clearance. All 60 records on the 2018 contract are unflagged, and of the 141 contracts behind those 561 records, 140 carry one uniform flag on every line. The column mostly tells you whose price sheet a row came from. Correct a caveat we have run before: the level is not unknowable. The vendor’s price list, the template GSA builds CALC+ from, carries a Minimum Security Clearance Level column. On 47QSMS26D0052 it reads T5 on 38 lines and T1, T2 or T3 on the other 56; every cleared row above is T5, its description naming Top Secret/SCI, Special Access Program eligibility and a counterintelligence polygraph.

That check breaks a comparison we would otherwise have made. The 2018 contract prices an Intelligence Analyst III at $104.37, master’s plus six years, unflagged. Its published description is program-analyst language applied to “the administration of Intelligence programs”, and its price-list fields read Security Clearance Required = No, no minimum level. That is not the same work as a TS/SCI intelligence producer, and pairing the two would be the failure GSA warns about when it says a title search “could return unrelated results such as Warehouse Supervisor, Data Entry Supervisor.” The clearance-flagged $104.40 line makes the point without that confound. The labour market’s view is what a clearance is actually worth.

Does a wage determination set the floor under a cleared analyst req?

Short answer: Often not, but the test is the job’s duties, never its title or badge. The Act does not cover bona fide executive, administrative or professional employees, and DOL says highly paid skilled staff stay covered when they fail the 29 CFR 541 tests.

FAR 22.1101 says the Act protects “blue-collar service workers and some white-collar service workers” but “does not cover bona fide executive, administrative, or professional employees.” Read it with 29 CFR 4.156, which most employer summaries drop: such employees “are not excluded from coverage, however, even though they are highly paid, if they fail to meet the tests set forth in 29 CFR part 541,” and DOL’s examples of covered skilled staff include laboratory technicians and draftsmen. 29 CFR 541.301 confines the learned-professional exemption to “professions where specialized academic training is a standard prerequisite for entrance,” and withholds it from “occupations that customarily may be performed with only the general knowledge acquired by an academic degree in any field.” Its listed fields are law, medicine, engineering, accounting, teaching and the physical and biological sciences. Intelligence analysis is not among them; software and systems staff have a separate test at 29 CFR 541.400.

Our own dataset cuts against the easy assumption. On that fully cleared contract the Activity Security Representative gate is a high-school equivalent plus one year, the ISSO I gate a degree in any field plus one year, and 18 of the 94 published lines are typed as Service Contract Labor Standards positions carrying a DOL occupation code and a named wage determination. A TS/SCI badge exempted none of them. Run the duties test on the actual position, and where it is close, put it to your contracting officer and labour counsel before setting the rate.

Where the Act does apply, the mapping duty is literal and starts earlier than most employers think. Under 29 CFR 4.6(b)(2) an unlisted class must be conformed, and the “conforming procedure shall be initiated by the contractor prior to the performance of contract work by such unlisted class of employee.” The written report to the contracting officer is due no later than 30 days after that class performs any work, a backstop rather than the trigger. The Wage and Hour Division then rules within 30 days of receipt or “will notify the contracting officer within 30 days of receipt that additional time is necessary,” so do not plan around that second clock. And the rate finally determined “shall be paid to all employees performing in the classification from the first day on which contract work is performed by them,” with failure to pay retroactively a “violation of the Act and this contract.” That side is our piece on SCA wage determinations.

A correction to ourselves. The SCA Directory of Occupations, Fifth Edition runs 139 pages across 25 categories with zero hits for “Intelligence,” “Cyber,” “Information Assurance” or “Security Analyst.” We previously printed no publication year for it. There is one: DOL’s release announcing the Fifth Edition is dated 20 April 2006, and that vintage explains most of the zero. The catalogue predates ordinary federal use of “cyber” as a job title, so its silence is evidence about a 2006 document, not about the work today.

The FAR polices professional pay at the proposal stage, not the hiring stage. FAR 22.1103, current as of FAC 2026-01, requires provision 52.222-46 when a negotiated service contract “is expected to exceed $900,000” and needs “meaningful numbers of professional employees.” Check the live FAR, not a printed CFR: the 2024 annual edition still carries the superseded $750,000. The clause demands a total compensation plan, and paragraph (d) runs: “Failure to comply with these provisions may constitute sufficient cause to justify rejection of a proposal.” Bidding the badges down on a recompete is an evaluated risk, covered in re-badging 60 cleared people.

What can you change when the category will not move?

Short answer: The category you slot the person into, an order-level negotiation, a modification, the employment vehicle, the sourcing channel, sometimes the SIN. Most need your contracting officer’s agreement, so treat them as proposals, not switches.

Start with the SIN, because almost nobody checks it. On 47QRAA19D000U, “Program Analyst I, bachelor’s, 3 years” is awarded at $54.99 an hour under SIN 541611 and $57.31 under SIN 54151S. Identical title, identical gates, a 4.2 percent spread. The condition nobody states: which SIN an order rides is a scope determination the ordering contracting officer makes against the services being bought. You can show the mapping and argue it. You cannot pick the pricier SIN because it funds a better offer, and an order outside a SIN’s scope can be challenged later.

Paying a candidate above your own internal scale is narrower than usually described. FAR 31.205-6(a) makes compensation “allowable subject to” criteria including conformity with “the contractor’s established compensation plan.” That is a test of whether a cost is allowable, not a rule forbidding the payment, and FAR 31.000 limits Part 31 to pricing “whenever cost analysis is performed” and to determining costs “when required by a contract clause.” On a schedule order billed at a published ceiling rate, neither hook governs your employee’s salary. Two things get run together: billing above the not-to-exceed rate is a contract term you genuinely cannot breach, while paying someone off your internal scale is a cost-allowability and internal-equity question that may not be in play at all. FAR 31.203(d) governs the indirect cost base, not a salary. Ask your contracts lead which of these binds your vehicle before concluding you are stuck. The last lever is how the person is engaged, which is why identical work prices differently as W-2, 1099 or corp-to-corp.

Read that as our inference, not a finding. A published ceiling proves what a contract may bill, not what a company chooses to pay. Four things would falsify the pessimistic reading: a modification adding a better-paid category, an order-level negotiation, a different category mapping, or a hire off the vehicle.

If nobody measures cleared pay, what is “market” anyway?

Short answer: No federal statistical series we could find measures what clearance holders are paid. No BLS survey, no OPM table, no ODNI release.

Contract data measures ceilings. Aggregators measure whoever answered, so if you cite one, say it is self-reported and give its sample size; our honest version for one role is what cleared intelligence analysts earn, and the agency-versus-contractor basis trap is in contract jobs versus federal jobs. So when the category will not move, widen the funnel instead of raising the number.

Here is the unflattering half of our own position. A specialist cleared board reaches people who already identify as clearance holders and are actively looking, which for a mid-level CONUS req at Secret or TS is usually the highest-yield channel per dollar. It is the weaker choice in three cases. If the req is genuinely uncleared, a general board reaches a far larger pool and you pay a niche premium for nothing. If you want a passive candidate with a rare polygraph-gated skill set, a retained search beats any posting. And if the req is underpriced against competitors, no channel repairs that. The comparison, including where we lose, is where to post cleared jobs; the cost of the open req is what a cleared hire really costs.

That $46.51 ceiling is already published at $47.91 for next contract year, on an award whose current option period runs to May 2031. Pull the contract, find the category your req maps to, read the published description rather than the title, and check whether the gate written in at bid time still describes the person you want. That is an hour of work, and the only lever here you control alone.

Frequently Asked Questions

Does a security clearance raise the ceiling rate on a GSA schedule contract?

Not reliably, and CALC+ cannot answer it cleanly. Its clearance field is a yes/no flag set once per contract in practice: on 21 July 2026, 140 of the 141 contracts behind the 561 “Intelligence Analyst” records carried one uniform value on every line. Across that population, flagged rates ran a median $118.27 against $133.71 unflagged. Two clearance-flagged intelligence-research categories on the same SIN priced at $46.51 and $104.40. Category spread swamps clearance.

Can a contractor pay above the labor category rate for a candidate it really wants?

Two questions hide in that one. Billing the government above the contract’s not-to-exceed ceiling is a contract term, and no, you cannot. Paying an individual above your own internal scale is a cost-allowability question under FAR 31.205-6, which makes compensation “allowable subject to” conformity with your established plan rather than forbidding the payment, and FAR 31.000 limits those cost principles to cost analysis and to clauses requiring cost determination. Ask your contracts lead.

Does a Service Contract Act wage determination set the floor for a cleared analyst?

Often not, but never assume it from the title or the badge. FAR 22.1101 excludes bona fide executive, administrative and professional employees, while 29 CFR 4.156 keeps skilled, highly paid staff covered when they fail the 29 CFR 541 tests, and 541.301 withholds the learned-professional exemption from work doable with a degree in any field. On the cleared contract used here, 18 of 94 lines are mapped to wage determinations. Run the duties test per position, with counsel where it is close.

How do I look up the published ceiling rate for a labor category?

GSA’s CALC+ Quick Rate tool is public and needs no login. Search by title, contract number or SIN, then filter by education, experience, worksite and contract year. Three cautions. Use the graph’s “Median and Percentiles” view, which GSA added in January 2026 and calls “most representative of the central point and dispersion.” Treat any result under three records as a prompt to search again, per GSA’s own best practice. And read the vendor’s price-list duty description before treating two same-titled rows as comparable.