On Revision 37 of wage determination 2015-4281, the line for Computer Systems Analyst II carries no wage. In its place the schedule prints “(see 1)” and routes you to a footnote. The same blank runs across Computer Programmer I-IV and Computer Systems Analyst I-III. What the schedule does reach, it reaches hard: guard forces, help desk, technical writing, engineering technicians and administrative staff all carry published minimums and real headcount.

What does a wage determination actually obligate you to pay?

A minimum hourly wage per listed occupation code, plus a fringe package: health and welfare, vacation, named holidays. It binds nonexempt service employees on covered contracts, and it is a floor, not a market rate.

The Act attaches to any federal or District of Columbia contract involving an amount exceeding $2,500 whose principal purpose is “the furnishing of services in the United States through the use of service employees,” per 41 U.S.C. 6702(a). Subsection (b) then carves out seven categories, among them construction, alteration and repair of public buildings (Davis-Bacon territory), Walsh-Healey supply work, public utilities and carriage under published tariffs. Price a facility-alteration task off this schedule and you priced it off the wrong statute.

Coverage does not stop at the coastline either. 41 U.S.C. 6701(4) has two halves, and only (B) excludes anything: other US territories and “any United States base or possession within a foreign country.” Half (A) counts Puerto Rico, the Virgin Islands, Guam, American Samoa, Wake Island and the outer Continental Shelf as “United States,” so cleared support at Andersen AFB or Fort Buchanan carries a determination like any stateside job. Germany and Kuwait fall outside, which is why overseas security contractor pay bands behave nothing like the domestic guard schedule. And 41 U.S.C. 6703(5) makes the contract state the rates the agency would pay “if section 5332 or 5341 of title 5 were applicable”: General Schedule for white-collar classes, Federal Wage System for trades. One more difference between a contractor billet and a federal billet.

Where does the floor stop, and who falls outside it?

Bona fide executive, administrative and professional employees are excluded by statute. Here that shows up as blank space: whole IT job families listed with a footnote instead of a rate.

The floor does not sit under every cleared support salary, and the gap is where the expensive people are. 41 U.S.C. 6701(3)(C) excludes from “service employee” anyone “employed in a bona fide executive, administrative, or professional capacity, as those terms are defined in part 541 of title 29.” Footnote 1 explains the blanks: because most systems analysts and programmers paid at least $27.63 per hour (or at least $684 per week on a salary or fee basis) likely qualify as exempt computer professionals, the determination “may not include wage rates for all occupations within those job families.”

Read those two numbers correctly. They are FLSA part-541 exemption tests describing who falls outside the floor, not SCA wage rates, and they entitle nobody to $27.63 an hour. The $684 test survived a challenge: the 2024 rule that would have raised it was vacated nationwide and DOL restored the 2019 figure by technical amendment effective 15 May 2026. Price against $684.

Now the column that cuts the other way, because contractors read the exemption more broadly than DOL wrote it. 29 CFR 4.156 says 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.” Footnote 1 adds that job titles “are not determinative,” and that a conformance becomes necessary if nonexempt employees work those families. A blank line is not a ruling that a family is exempt, and no salary figure settles the question. Where the call is close, take it to your contracting officer, the Wage and Hour Division or counsel.

What do the actual rates look like on a real determination?

Revision 37 of WD 2015-4281 is the area-wide determination most likely to ride on a National Capital Region cleared solicitation. Every figure is regional.

These rates come from wage determination 2015-4281, Revision 37, last revised 14 May 2026, covering DC, two Maryland counties and eleven Virginia jurisdictions. Colorado Springs, Huntsville and San Antonio carry different determinations with different numbers. Do not quote any of it as national or permanent.

Source: WD 2015-4281, Revision 37 (SAM.gov), read 21 July 2026. National Capital Region only.

Notice what is missing from every row: clearance. No code for a cleared anything, no TS/SCI differential, no polygraph adder. A cleared guard outside a SCIF is Guard I or Guard II at the same rate as an uncleared guard at a suburban federal building, unless a union contract says so. Nor can you conform your way to a “Cleared Guard” rung: both guard classes are listed, conformance reaches only work outside the scope of any listed class, and a clearance is not a duty. Read as what cleared people earn, these numbers are wrong. The clearance premium lives in the market, and no primary-source market figure was verified here, so none is printed.

For the statutory benchmark, OPM Salary Table 2026-DCB puts step-1 hourly basic pay at $22.33 for GS-5, $33.84 for GS-9 and $40.94 for GS-11, effective January 2026. Two catches: civil-service rates are not contractor pay and carry no wrap, and this is the Washington-Baltimore-Arlington locality table, 33.94% above base GS.

What does health and welfare really cost you?

$5.55 per hour, owed on all hours paid for, capped at 40 per week and 2,080 per year. Models built on hours worked under-accrue: vacation, sick and holiday hours all count.

Revision 37 states the obligation three ways: $5.55 per hour up to 40 hours per week, or $222.00 per week, or $962.00 per month. Three expressions of one obligation, not a menu. The rate comes from All Agency Memorandum No. 250, dated 7 July 2025, and as of 21 July 2026 no 2026 memorandum has replaced it. Treat $5.55 as carrying its own expiry label.

The accrual base is where money leaks. Under 29 CFR 4.175(a)(1), payments “are due for all hours paid for, including paid vacation, sick leave, and holiday hours, up to a maximum of 40 hours per week and 2,080 hours per year on each contract.” A model accruing only on productive hours is short by eleven holidays and two to four weeks of vacation per head. The obligation tracks the employer’s contribution: 4.175(a)(2) sets it “based on the monetary cost to the employer rather than on the level of benefits provided.” Contracts also carrying EO 13706 paid sick leave use $5.09.

The rest of the package is eleven named paid holidays and vacation of two weeks after one year, three after five, four after fifteen. The holiday list is not immovable: Revision 37 lets a contractor “substitute for any of the named holidays another day off with pay in accordance with a plan communicated to the employees involved,” which is how a 24/7 post covers Columbus Day. Vacation eligibility follows the seat, not the badge: length of service includes time with predecessor contractors doing similar work at the same facility. Fold it into the full cost of a cleared hire.

What happens when your labor category is not on the determination?

Usually you conform, and a missing classification never licenses you to set a rate unilaterally. The procedure starts before that class performs work, and the rate is retroactive to their first day.

29 CFR 4.6(b)(2) makes the sequence explicit: the procedure “shall be initiated by the contractor prior to the performance of contract work by such unlisted class of employee,” the written report goes to the contracting officer “no later than 30 days after such unlisted class of employees performs any contract work,” and WHD “will approve, modify, or disapprove the action … within 30 days of receipt.” Do not plan around that last clock as a deadline: the same sentence lets WHD “notify the contracting officer … that additional time is necessary,” with no stated limit.

The contractor proposes; WHD decides. Treating a conformance as internal pricing is the common failure mode, and the determination spells out the cost: WHD’s ruling applies “from the first day of work on which contract work is performed by them in the classification,” and failure to pay retroactively “shall be a violation of the Act and this contract.” Nor can conformance invent a cheaper rung. 29 CFR 4.152(c)(1) bars using it to “artificially split or subdivide classifications listed in the wage determination,” and Revision 37 restates that as “split, combine, or subdivide,” so a blended class merging two listed ones is out too.

One exception matters most on option years. Where the class was already conformed under a prior contract, modification or option, 29 CFR 4.6(b)(2)(iv)(B) lets you set the new rate by “indexing (i.e., adjusting) the previous conformed rate” by the mean percentage change across the listed classifications. Do that before the class performs work and you “shall advise the contracting officer of the action taken but the other procedures in paragraph (b)(2)(ii) … need not be followed.” No submission, no WHD ruling, no wait.

Note which half must precede performance: initiation, not filing. The report is due up to 30 days after that class starts work, so a cleared, badged employee need not sit idle while an SF-1444 clears. Put initiation on the clearance-and-badging timeline in time-to-billing planning.

Who absorbs a wage determination increase at the option year?

You do, partially. FAR 52.222-43 adjusts price for the delta the new determination forced, plus the payroll taxes riding on it. It excludes overhead, G&A and profit.

The clause’s own example is sharper than any paraphrase. The prior determination required $4.00 an hour and the contractor chose to pay $4.10; the new one raises the minimum to $4.50. Even if the contractor voluntarily goes to $4.75, FAR 52.222-43 holds that “the allowable price adjustment is $.40 per hour.” Paragraph (e) limits recovery to wages, fringes “and the accompanying increases or decreases in social security and unemployment taxes and workers’ compensation insurance,” but “shall not otherwise include any amount for general and administrative costs, overhead, or profit.” You eat the burden on the burden, which is why this belongs in the same model as your wrap rate.

Two dates decide whether you recover anything. Paragraph (c) applies the determination “current on the anniversary date of a multiple year contract or the beginning of each renewal option period,” so a revision or a new health and welfare memorandum published mid-period changes nothing you owe until the next anniversary. Pay it early and it is the voluntary increase the $4.75 example refuses. Paragraph (f) starts the notice clock on receipt of the new determination, not on the option-exercise date and not on the day payroll rises: notify “within 30 days after receiving a new wage determination unless this notification period is extended in writing by the Contracting Officer.” Past day 30, ask for that written extension rather than writing the claim off, and keep performing while it is argued.

One thing the Act does not do at a recompete: tell you whom to hire. Section 4(c) binds a successor to the predecessor union contract’s wages and fringes, but 29 CFR 4.163(a) says that duty “does not extend to other items such as seniority, grievance procedures, work rules, overtime, etc.” The re-badge-everyone claim in incumbent-capture planning is not an SCA claim.

Which executive-order minimums still apply, and what if you get it wrong?

For most contracts performing today, none. What remains is the wage determination and the FLSA. Getting it wrong runs to back wages and, at worst, the ineligible-bidder list.

Executive Order 14026, the $17.75 contractor minimum wage, was revoked by name in section 2(d) of Executive Order 14236, signed 14 March 2025 at 90 FR 13037. Revision 37 carries notes for EO 13706 and EO 13658, none for EO 14026. DOL’s rate-change notice at 91 FR 5783 sets the surviving EO 13658 rate at $13.65 per hour effective 11 May 2026. Its reach is the catch: EO 13658 applies only to contracts “awarded on or between January 1, 2015 and January 29, 2022, and that have not been renewed or extended on or after January 30, 2022.”

29 CFR 4.188 bars award of any federal or DC contract, “whether or not subject to the Act,” to a listed firm “or to any firm, corporation, partnership, or association in which such persons or firms have a substantial interest,” for three years, prime or sub. An owner’s debarment travels to every affiliate they hold a substantial stake in, and a repeat violation starts a fresh term from republication. Two qualifiers belong beside that, because the sanction is often called automatic and is not: a violator is ineligible “unless the Secretary recommends otherwise because of unusual circumstances,” and the Secretary cannot shorten the term “other than in situations involving mistake or legal error.” The burden of proving unusual circumstances sits on the violator. The Act sits in the same stack as the OFCCP obligations on every cleared requisition.

Frequently Asked Questions

Does a security clearance change the SCA wage rate?

No. Revision 37 has no code for a cleared position, no TS/SCI differential and no polygraph adder. A cleared Guard II and an uncleared Guard II carry the same $22.72 minimum. A clearance premium usually does exist in what you pay, but it comes from the market or a union contract.

Where do I look up the wage determination attached to my contract?

SAM.gov hosts the current text by number and revision. Pull the revision number and its date, not just the number: the history for 2015-4281 shows 36 published revisions numbered up to 37 (Revision 31 is absent), two a day apart in May 2026.

Is $13.65 per hour the federal contractor minimum wage in 2026?

Not generally. That EO 13658 rate reaches only the legacy band above: contracts awarded 1 January 2015 to 29 January 2022 and never renewed or extended on or after 30 January 2022. EO 14026 and its $17.75 rate were revoked on 14 March 2025, so most contracts performing today carry no executive-order minimum wage.

My engineer is not listed on the determination. Can I just set a rate?

No. Either the employee is genuinely exempt under 29 CFR part 541, so the determination does not apply, or the employee is nonexempt and you owe a conformance, initiated before that person performs contract work and reported within 30 days after. WHD sets the rate, not you, unless the class was already conformed on a prior contract or option: 29 CFR 4.6(b)(2)(iv)(B) then lets you index the old rate and advise the contracting officer.

DOL has published no 2026 health and welfare memorandum, and AAM 250 is a year old. When a successor lands it will not change what you owe mid-period: 52.222-43(c) binds you to the determination current at your anniversary or option start. It changes what you price into the next one. Put your WD’s SAM.gov revision page on a calendar reminder and log its revision number beside every direct-labor rate. The floor moves, it does not reach everyone you employ, and it never priced the clearance.