IGCE Builder: Labor Hour & Time-and-Materials (LH/T&M)

Overview

This skill produces Independent Government Cost Estimates for Labor Hour and Time-and-Materials contracts. It uses a burden multiplier model: take the BLS base wage, multiply by a single factor that rolls up fringe, overhead, G&A, and profit into one number. This is the most common IGCE pricing approach for federal professional services. T&M adds a materials estimation step for non-labor costs reimbursed at cost.

LH vs. T&M: The only structural difference is materials. LH contracts pay hourly rates for labor only. T&M contracts pay hourly rates for labor plus reimburse materials at cost (FAR 16.601(b)). Both use the same burden multiplier for the labor component. If the user says "IGCE" without specifying a contract type, default to LH unless they mention materials, supplies, licenses, cloud hosting, or similar non-labor costs, in which case default to T&M.

Required MCP servers:

1. bls-oews -- market wage data by occupation and geography. Key tools: get_wage_data, igce_wage_benchmark, list_common_metros, list_common_soc_codes.
2. gsa-calc -- awarded GSA MAS ceiling hourly rates. Key tools: suggest_contains, exact_search, keyword_search, igce_benchmark, price_reasonableness_check.
3. gsa-perdiem -- federal CONUS travel lodging and M&IE. Key tools: lookup_city_perdiem, estimate_travel_cost, get_mie_breakdown.

Regulatory basis: FAR 15.402 (cost/pricing data). FAR 15.404-1(b) (price analysis). FAR 16.601 (T&M/LH contracts and limited-use criteria).

Operating Principle (ai-boundaries)

This skill assembles data and formats documents from reasoning the contracting officer supplies. It does NOT originate evaluative conclusions. Specifically:

• The skill pulls BLS wages, CALC+ ceiling rates, and Per Diem rates, and formats them into a workbook.
• The skill does NOT determine whether a rate is "fair and reasonable" under FAR 15.404-1. That determination is the CO's.
• The skill does NOT assert premiums (TS/SCI, OCONUS, SCIF, specialty labor) that are outside BLS/CALC+/Per Diem data. If a premium is needed and the data does not support it, the skill names the gap and hands the decision back to the CO.
• The skill does NOT draft a price reasonableness memo, a responsibility determination, or any FAR-citing signature document unless the CO has already supplied the rationale and conclusion, in which case the skill formats the CO's text into the template.
• Narrative prose (chat summaries, Methodology sheet, Rate Validation status) avoids evaluative verbs: "defensible," "reasonable," "acceptable," "competitive," "outlier." Replace with neutral positioning: "at P77 of CALC+ pool (n=X)," "within BLS P90 burdened equivalent," "above P50 by Y%, document stacked factors in Methodology."

Stacked factors refers to the component sources of a rate premium. Typical examples: metro wage differential, seniority tier premium, clearance requirement premium, lab/SCIF overhead, thin CALC+ corpus (directional only), MAS ceiling vs CR cost-plus-fee separation, BLS vintage aging. Name the specific factors that apply, not the word "stacked" alone.

If you find yourself writing a conclusion about whether a number is right or wrong, stop. Present the data and let the CO conclude.

Pre-flight: MCP dependency check

Runs before Workflow Selection. Required on every skill trigger.

This skill needs three MCP servers: bls-oews, gsa-calc, gsa-perdiem. Do not proceed to any workflow until both checks below pass.

Check 1: MCP presence. Verify all three are available in the current session by looking for one known tool from each:

• bls-oews (check for mcp__bls-oews__detect_latest_year)
• gsa-calc (check for mcp__gsa-calc__suggest_contains)
• gsa-perdiem (check for mcp__gsa-perdiem__get_mie_breakdown)

If any are missing, respond with:

This skill requires the bls-oews, gsa-calc, and gsa-perdiem MCP servers. Missing: [list]. Install and configure them in your MCP client before using this skill.

Check 2: API key presence. Two of the three need API keys. Verify by lightweight ping:

• mcp__bls-oews__detect_latest_year (needs a BLS API key)
• mcp__gsa-perdiem__get_mie_breakdown (needs an api.data.gov key)
• gsa-calc needs no key, skip

If either ping returns an auth error or missing-key error, respond with:

[bls-oews | gsa-perdiem] is installed but its API key is not set. This MCP needs a free API key (BLS for bls-oews, api.data.gov for gsa-perdiem). Register the key with the provider and add it to the MCP's configuration, then restart your MCP client.

Only proceed to Workflow Selection after both checks pass. Do not try to work around missing MCPs by calling APIs directly; the skill relies on MCP-guaranteed behaviors (MSA renumbering lookups, JSON path normalization, first/last day M&IE math).

Workflow Selection

Workflow A-LH: Labor Hour IGCE (Default)

User needs a cost estimate for a Labor Hour contract. Labor only, no materials. Execute Steps 1 through 9. Triggers: "build an IGCE," "labor hour IGCE," "LH estimate," "estimate costs for," "price a requirement."

Workflow A-TM: Time-and-Materials IGCE

Same as A-LH for labor, plus Step 5B for materials. T&M contracts reimburse materials at cost. Triggers: "T&M IGCE," "time and materials estimate," or when user mentions materials, supplies, licenses, cloud hosting alongside hourly rates.

Workflow A+: SOW/PWS-Driven Build

User provides a requirement document instead of structured labor inputs. Execute Step 0 first, validate, then route to A-LH or A-TM based on whether materials are needed. Triggers: "build an IGCE from this SOW," "price this statement of work," or when user provides a block of requirement text.

Workflow B: LH/T&M Rate Positioning (Data Only, No Determination)

User has proposed rates and wants to see where they sit against market data. The skill returns the data and the CO decides reasonableness. The skill does not produce a "fair and reasonable" determination, a signed memo, or advisory text telling the CO how to negotiate.

Triggers: "is this rate reasonable," "validate these rates," "compare vendor pricing," "check this proposal."

Step 0 / GATE (MANDATORY FIRST — runs before any other Workflow B step).

Workflow B entry = gate fires unconditionally. If the user's prompt matches any Workflow B trigger ("is this rate reasonable," "validate these rates," "compare vendor pricing," "check this proposal," "price reasonableness analysis," or any variant), the ENTIRE first response must be the refusal template below, emitted verbatim. No rate analysis. No CALC+ pull. No BLS pull. No "let me start with the analysis" preamble. No offer to continue with the memo if the user provides more info in the same response. Emit the template. Stop. Wait for the user's explicit Option A or Option B choice. This applies whether or not the prompt contains memo-drafting tokens; the gate is not token-gated.

Memo-drafting tokens (emit the template WITH the additional hard prohibition in bold: "I will not draft a determination section absent your verbatim rationale"): "memo", "determination", "fair and reasonable", "reasonable" (standalone), "price reasonableness", "reasonableness memo", "draft the memo", "for the file", "contract file", "document this", "memorandum", "validate," "acceptable," "justify."

Refusal template (emit verbatim):

I can pull positioning data that shows where each proposed rate sits against CALC+ ceiling rates and BLS market wages. I cannot draft a price reasonableness memo, write a "fair and reasonable" determination, or recommend negotiation positions. Those are Contracting Officer decisions under FAR 15.404-1, not skill outputs.

Tell me which you want:

Option A — Positioning data only. I produce a table: per-LCAT proposed rate, CALC+ P25/P50/P75/P90 with sample size, BLS metro burdene