Money Out of Our Pockets?

Is the cost of servicing military moves about to get more expensive? We’re not completely sure, and that’s concerning. But we do have a line of questioning that hopefully has some pleasant answers – or some thoughtful, carefully considered answers that indicate this issue has been at least somewhat vetted.

Since business conducted under the GHC is subject to the Service Contract Act – which TRANSCOM has acknowledged it will be – and if the SCA requires independent contractors to serve as “service employees” for military shipments, what does that mean for business costs? And who pays for what?

Many independent contractors cover a lot of business costs themselves. So if independent contractors will be required to conduct military business as employees, does this mean those costs will now shift to small business owners who will have to act as their employers? And if so, will independent contractors lose out on certain tax benefits for work they do while servicing military shipments? Some guidance would sure help.

Has TRANSCOM considered this rather lengthy list of business costs that could shift from independent contractors to agency owners under the GHC? And if so, how will they be addressed?

BUSINESS COSTS CURRENTLY COVERED BY INDEPENDENT CONTRACTORS:

Claims	Truck Licenses
Capacity	Local Labor Wage
Fuel	Local Workers Compensation Insurance
Tolls	Local Labor Overtime
Inside Equipment	Local Labor Benefits
Tires	Local Labor Training
Truck Maintenance and Repairs	Local Labor Non-Revenue Costs: Travel time Obtaining weight scales Truck breakdown Weather delays Customer Delays
Truck Inspections	Local Labor Per Diem
Truck Insurance	Background Checks, Drug Tests
Truck Rentals	Increased Admin Costs to track, report, and audit SCA compliance
Recruiting and replacing labor	Increased insurance exposure and risk

If these costs have been considered … please, TRANSCOM, fill us in.

---

ATA: To Effectively Serve Our Military, Movers Need Clear Guidance from USDOL

Like us, ATA is calling for more clarity and guidance from TRANSCOM and the Department of Labor about what contract compliance looks like for small businesses and independent contractors. ATA hits the nail on the head: “The transition to this new series of requirements would be much easier if moving companies were receiving consistent guidance from the Department of Labor (DOL) – the government agency tasked with enforcing SCA compliance.” Read more

---

Reach Out to Your U.S. Elected Officials

As Congress continues its work on the current U.S. National Defense Authorization Act legislation, it’s important that the bill includes language requiring the Government Accountability Office (GAO) to conduct an evaluation of the GHC, and that TRANSCOM General Van Ovost provides a transparent briefing to congressional leaders. One version of the bill includes this language – let’s get it over the finish line.

We need YOU to reach out to your elected officials and urge them to evaluate the impacts of the GHC. Specifically, ask your representatives to request a strategic pause on the implementation until the GAO report is complete and the Department of Labor provides guidance on how the Service Contract Act will apply under the new program.

If you wish to get involved, click this LINK to find your member of the House of Representatives and click this LINK to find your Senators – and then email them. Below is a sample email for your reference. Please feel free to personalize your email based on your own experiences and perspectives.

Sample Email to Representatives

Subject: Support for the Household Goods Industry in the NDAA Bill

Dear Senator/Congressman/Congresswoman [Name],

As a constituent and stakeholder in the household goods industry, I write to you today to encourage your support by ensuring that requirements are maintained as set forth in the House NDAA Bill, H.Rept 118-529 “Report of the Committee on Armed Services, House of Representatives on H.R. 8070, together with Additional Views.” The specific language is found under:

• DIVISION A—DEPARTMENT OF DEFENSE AUTHORIZATIONS
  • TITLE III—OPERATION AND MAINTENANCE
    • ITEMS OF SPECIAL INTEREST
      • Other Matters
        • Comptroller General Review on Military Moves
          • Transition of Global Household Goods Contract Services

As an interested party, I have serious concerns that the Global Household Goods Contract (GHC) lacks the details necessary to successfully move our nation’s military heroes and their families. I believe a strategic pause on contract implementation is essential until an evaluation of the GHC is completed. You can visit moversforamerica.com to learn more about what the industry is advocating for.

Thank you for your support.

Sincerely,

[Your Name]
[Your Address]
[Your E-Mail]