More Than 1,000-Strong
Movers for America has surpassed 1,000 members! The MFA coalition is composed of moving and storage professionals and independent contractors dedicated to delivering our best to America’s military families and raising legitimate concerns with GHC implementation. As our numbers grow, so does our voice and our influence!
Some of our members attended the recent IAM Conference, hoping to gain new insights, especially into SCA compliance. Unfortunately, the GHC Listening Session didn’t shed new light on much of anything. Instead, some attendees described it as “opaque,” “a whole lot of prescreened questions,” and “word salad” from GHC leadership.
We still have yet to see a compliance guide or real-life examples of how the SCA works for complex interstate moves, such as shipments hauled across several states by independent contractors. So, we decided to conduct our own fact-finding mission about SCA compliance and enforcement.
We’ve been told that TRANSCOM has allegedly been working with the Department of Labor on a guide for professional movers that haul military shipments, but we’ve also heard that DOL is waiting on a plan from TRANSCOM. Things continue to be murky.
What the Department of Labor Says About SCA Compliance
After reviewing some Department of Labor videos, we found clear rules but serious challenges when applying them to military shipments. Here’s what this means in practice:
- Service Employee Designation: Every hourly individual contributor engaged in moving or storage services under the GHC — whether office administration personnel, day laborers, local contractors, non-local contractors, etc. — must be classified as a “service employee.” This designation triggers fringe benefits, vacation pay, and other wage requirements for moving companies to provide and keep track of.
- Fringe Benefits and Overtime Obligations: Fringe benefits must be clearly communicated in writing and specified in payroll documentation. Also: overtime becomes the responsibility of the contracting employer, even if the employee worked for multiple contractors in the week. This means that when a contractor hires labor/helpers after they’ve worked 40 hours on a FAR-based Government work (whether GHC or other Government contracts) during the week, the contractor must pay overtime wages at 1.5 times the SCA prevailing wage for that job.
- Recordkeeping Requirements: Prime contractors and subcontractors must maintain extensive records for each Service Employee for at least three years after work completion. This includes tracking hours, wages, and work classifications.
- No Exclusions for Moving and Storage Services Under SCA: There are NO current FAR-based government contracts that exclude moving or storage of household goods and related services from the SCA. Although the U.S.P.S. contract excludes some services from the SCA, moving or storage of household goods and related services are specifically not excluded.
Since the GHC rollout so far hasn’t included a much-needed breakdown of what the SCA really means for moving companies and professionals, we did our best to summarize the videos the DOL made about the subject. It may be helpful to watch them for yourself since we’re still waiting on basic guidance specific to relocating American military families.
DEPARTMENT OF LABOR VIDEOS:
