SCA wage determination lists a health and welfare fringe. Do we have to put that into a benefits plan?

Yes, you can pay the health and welfare fringe in cash. Section 2(a)(2) of the SCA lets you meet the fringe obligation with a bona fide plan, an equivalent mix of benefits, or cash, and 29 CFR 4.177(c)(1) spells out the cash route: pay it on the regular payday, on top of the wage determination rate, in an amount equal to the fringe.

A few things trip people up:

• Your stipend only counts if it's paid in addition to the Guard I rate. 29 CFR 4.170(a) says wages above the WD rate can't be used to cover the fringe. If the stipend comes in under the health and welfare amount, you owe the difference (4.172).
• The fringe is owed on every hour paid, including holiday and vacation hours, up to 40 hours a week and 2,080 a year on each contract (4.172 and 4.175(a)). We missed the holiday hours on our first SCA staffing contract and had to make it up.
• Cash paid in lieu of the fringe stays out of the regular rate for overtime (4.177(e)), so leave it out of your OT math.

Certified payroll is a Davis-Bacon thing; the SCA has no such form. What you owe are the 29 CFR 4.6(g) records: classification, wage rate, fringe provided or cash paid in lieu, and hours, with wages and fringe shown separately, kept for 3 years after the work ends.

On the invoice, the agency pays your contract price by CLIN. Build the health and welfare cost into your hourly rate and keep the backup.