slide1 n.
Download
Skip this Video
Loading SlideShow in 5 Seconds..
Breakout Session # 1706 Patricia Downing, Senior Manager, Aronson & Company Tuesday, April 11, 2006 2:45 pm – 3:4 PowerPoint Presentation
Download Presentation
Breakout Session # 1706 Patricia Downing, Senior Manager, Aronson & Company Tuesday, April 11, 2006 2:45 pm – 3:4

Loading in 2 Seconds...

play fullscreen
1 / 73

Breakout Session # 1706 Patricia Downing, Senior Manager, Aronson & Company Tuesday, April 11, 2006 2:45 pm – 3:4 - PowerPoint PPT Presentation


  • 105 Views
  • Uploaded on

Understanding Small Business Subcontracting Compliance. Breakout Session # 1706 Patricia Downing, Senior Manager, Aronson & Company Tuesday, April 11, 2006 2:45 pm – 3:45 pm. Overview of Small Business Subcontracting.

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about 'Breakout Session # 1706 Patricia Downing, Senior Manager, Aronson & Company Tuesday, April 11, 2006 2:45 pm – 3:4' - gibson


An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
slide1
NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

slide2

Understanding Small Business Subcontracting Compliance

Breakout Session # 1706

Patricia Downing, Senior Manager, Aronson & Company

Tuesday, April 11, 2006

2:45 pm – 3:45 pm

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

overview of small business subcontracting
Overview of Small Business Subcontracting
  • FAR Part 19 and the Small Business Act, as amended contain regulations that require large business compliance
  • Federal Government procurements that exceed $500,000 ($1,000,000 for construction) require a small business subcontracting plan from large businesses

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

department of commerce
Department of Commerce
  • Established and maintains the North American Industrial Classification System (NAICS)
  • SBA sets size standards for each NAICS (pronounced NAKES) industry
  • Each industry size standard is based on either annual revenues or number of employees

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

small business categories
Small Business Categories
  • Small (SB)
  • Small Disadvantaged (SDB)
  • Woman Owned (WOSB)
  • Veteran Owned (VOSB)
  • Service Disabled Veteran Owned (SDVOSB)
  • HUBZone (HZB)

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

small business categories defined
Small Business Categories Defined

Small Business (SB)

A business concern, including its affiliates, that is independently owned and operated, and is not dominant in the field of operation in which it is bidding on government contracts.

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

small business categories defined1
Small Business Categories Defined

Small Disadvantaged (SDB)

A business of which at least 51% is owned by Small, Socially and Economically disadvantaged group members and whose management and daily business operations are controlled by one or more such individuals. Must be certified by SBA.

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

small business categories defined2
Small Business Categories Defined

Woman Owned (WOSB)

A business that is at least 51% owned and controlled by one or more women, and the management and daily operations of the business are controlled by one or more women.

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

small business categories defined3
Small Business Categories Defined

Veteran Owned (VOSB)

A business that is at least 51% owned and controlled by one or more veterans, and the management and daily operations of the business are controlled by one or more veterans.

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

small business categories defined4
Small Business Categories Defined

Service Disabled Veteran Owned (SDVOSB)

A small business concern where not less than 51% is owned and controlled by service-disabled veterans and the management and daily business operations of which are controlled by one or more service-disabled veterans or, in the case of a veteran with permanent and severe disability, the spouse or permanent caregiver of such veteran.

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

small business categories defined5
Small Business Categories Defined

HUBZone (HZB)

A business located in a Historically Under Utilized Business Zone that has been certified in writing by the SBA that it is a HUBZone small business concern, and that its principal office is located in a HUBZone and not fewer than 35 percent of its employees reside in a HUBZone.

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

slide12
Considerations When Preparing Plans for Inclusion in Proposals

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

determining if plan is required
Determining If Plan Is Required
  • Check total contract value
  • Check NAICS code assigned to RFP
  • Check SBA size status thresholds for assigned NAICS code

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

plan timeline
Plan Timeline
  • Proposal Stage – Write the Plan
  • Award Stage:
    • Track
    • Report
    • Demonstrate Good Faith Efforts
  • Closeout Stage – Submit Final Reports

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

minimum plan requirements
Minimum Plan Requirements
  • The Plan must demonstrate the contractor’s commitment to utilize small businesses of all types
    • Small
    • Small Disadvantaged
    • Small Woman-owned
    • Small Veteran-owned
    • Service Disabled Veteran-owned
    • HUBZone

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

minimum plan requirements1
Minimum Plan Requirements

Must demonstrate:

  • The contractor’s willingness to provide opportunities for the specific small businesses targeted in the plan
  • Detail the contractor’s interpretation of good faith efforts

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

writing the plan
Writing the Plan
  • Use Plan Model – varies by agency
  • Generally includes the following:
    • Type of plan
      • Commercial, Individual or Master
    • Plan Period
      • Base, Option or Life of Contract
    • Goals
      • Dollars and Percentages of Total Subcontracted Value

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

writing the plan1
Writing the Plan
  • Primary NAICS codes
    • Identified in the RFP for Prime Contractor
    • Prime Contractor identifies the NAICS codes for each subcontracting entity in the Plan Matrix

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

writing the plan2
Writing the Plan
  • Matrix
    • Lists each subcontracting entity
    • Shows each small business category and/or categories under which the entity is qualified
    • May list services or products when specific subcontractor is unknown
  • Indirect costs
    • included or excluded from plan dollars

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

writing the plan3
Writing the Plan
  • Identification of Program Administrator
    • Duties of Program Administrator
    • Reporting Requirements
    • Record Keeping

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

writing the plan4
Writing the Plan
  • Good Faith Efforts
    • List activities to demonstrate efforts
    • References Liquidated Damages Clause invoked when goals are not met and a good faith effort is not evident

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

slide22
Developing Goals

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

fy 2005 average government wide goals applicable to federal buyers
FY 2005 Average Government-wide Goals Applicable to Federal Buyers
  • SB – 23%
  • SDB – 5%
  • WOSB – 5%
  • HZB – 3%
  • SDVOSB – 3%

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

fy 2005 average government wide goals applicable to large prime contractors
FY 2005 Average Government-wide Goals Applicable to Large Prime Contractors
  • SB – 40%
  • SDB – 7%
  • WOSB – 6%
  • HZB – 3%
  • SDVOSB – 3%

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

fy 2005 goals applicable to dod large prime contractors
FY 2005 Goals Applicable to DoD Large Prime Contractors
  • SB – 42%
  • SDB – 5%
  • WOSB – 5%
  • HZB – 3%
  • SDVOSB – 3%

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

identifying opportunities
Identifying Opportunities
  • Contract Administrators work with Project Managers to identify opportunities
  • May include:
    • Consultants & Independent Contractors
    • Other Direct Costs (ODCs)
    • Subcontractors

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

identifying sources
Identifying Sources
  • Bidders lists
  • Corporate database
  • Other internally developed mechanisms
  • External source lists

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

using historical data
Using Historical Data
  • Information tracked in corporate database
  • Plans and semi-annual reports for similar projects
  • Past Performance reports

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

what to do when no opportunities exist
What to Do When No Opportunities Exist
  • Include indirect costs
  • Consider subcontracting a portion of the work your firm would normally perform
  • Look for opportunities in purchasing ODCs

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

incorporating a master plan
Incorporating a Master Plan
  • Still Requires Individual Plan
  • Follow Policies established in Master Plan
  • Complete Attachment A and include Master Plan

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

other considerations
Other Considerations
  • Plan submitted with proposal
  • Plan may be an evaluation factor
  • Plan must be approved prior to award
  • Plan is open to negotiation prior to award
  • Contract will not be awarded if plan is unacceptable

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage tracking and reporting
Award Stage: Tracking and Reporting
  • Understand what is to be reported
  • Know how it is to be reported
  • Determine how to track
    • Dependent upon tracking mechanisms available
      • Electronic
      • manual

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage
Award Stage

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage what to report
Award Stage – What to Report
  • Semi-annually report on achievement of individual plan goals to include:
    • Dollars expended during the specified 6 month period
    • Cumulative dollars expended over the life of the contract including the current reporting period
    • Percentages of total dollars for each category

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage what to report1
Award Stage – What to Report
  • Annually report on overall goal achievement:
    • A cumulative report of all subcontracted dollars
    • One report per agency
    • Agency is highest level of agency for example:
      • NIH, CDC, NCI should all roll up into one report for DHHS

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage how to report esrs
Award Stage – How to Report - eSRS
  • As of November 1, 2005, eSRS is the new government-wide reporting mechanism for CIVILIAN agencies
  • DoD reports are scheduled to switch to eSRS mid 2006
  • What is eSRS?
    • Electronic Subcontracting Reporting System

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage how to report
Award Stage – How to Report
  • Report electronically-online
  • Website: http://esrs.gov
  • All CIVILIAN reports must be completed online at this website
  • Paper reports will no longer be accepted

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

esrs what s different
eSRS - What’s Different?
  • Requires registration of contractor
  • Some CCR info linked to eSRS
  • Requires individual input of each contract requiring a plan
  • SF294 now called ISR
  • SF295 now called SSR

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

esrs what s different1
eSRS - What’s Different?
  • ISR-Individual Subcontracting Report (old SF294)
  • New info needed for reporting
    • DUNS as it appears on individual contract award
    • Product and Service Codes
    • NAICS

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

esrs what s different2
eSRS - What’s Different?
  • Lower Tier Subcontractors use eSRS
  • Info needed:
    • Prime contract number
    • Subcontract number
    • DUNS of prime contractor
    • Product and service codes
    • NAICS

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

esrs what s different3
eSRS - What’s Different?
  • SSR – Summary Subcontracting Report (old SF295)
  • New info needed for reporting:
    • DUNS number as it appears on individual contract award
    • Product and Service Codes
    • Make sure copy signed by CEO is on file

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

additional esrs info
Additional eSRS Info
  • Contractor Guide available
  • Due dates are still the same
    • Due 30 days after the end of the reporting period
    • ISR: April 30 and October 30
    • SSR: October 30 for CIVILIAN agencies

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage reporting
Award Stage – Reporting
  • OF 312 - Optional Form 312
      • If listed as a contract requirement…..
      • It is NOT optional!
    • Due upon Contract completion
    • Reports Goal Achievements by NAICS over life of contract
  • Closeout
    • Final reports should be submitted for the ISR, SSR and OF 312 (if required) as soon as the contract ends

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage tracking
Award Stage – Tracking
  • In order to report – you must track
  • Tracking begins at the Proposal Stage by capturing size status information
  • All proposed subcontractors shall self-certify their size status during the proposal stage
  • All business that state they are either a HUBZone or SDB must be certified by SBA
  • Self-certification is not acceptable for these two small business categories

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage tracking1
Award Stage – Tracking
  • Re-certification of each business’s size classification should be done as often as the contract or regulations require
  • This can be as often as annually
  • Business size certification can be as complicated as officially signed Representations and Certifications or as simple as a signed statement on company letterhead

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage tracking2
Award Stage – Tracking
  • The mechanism chosen for businesses to self certify should contain the following:
    • Small business types that must be reported
    • Penalty clause for providing false information
    • Point of contact
    • Signature of party providing information

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage tracking3
Award Stage – Tracking
  • Certification documents should be updated at regular intervals
  • Certification documents should be retained in a central location in either hard copy form or electronically
  • Documents should be readily available for audit by SBA and/or other agencies

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage tracking4
Award Stage – Tracking
  • Documents will be checked by SBA for:
    • Consistency of data collection
    • Data reporting across all vendors
  • The information collected by these documents should be entered either into a database or the accounting system for ease of reporting

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

award stage tracking reporting tips
Award Stage – Tracking/Reporting Tips
  • Any vendor used on a contract can be reported on the ISR and SSR whether or not they were included in the original plan
  • Each vendor/subcontractor’s dollars may be reported multiple times
    • If a business qualifies as a SDB & WOSB their dollars will be reported under each category

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good faith efforts
Good Faith Efforts

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good faith efforts1
Good Faith Efforts
  • Protect yourself and your company:

DOCUMENT! DOCUMENT! DOCUMENT!

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good faith efforts2
Good Faith Efforts
  • Paper your files with documentation on the following:
    • Basis of subcontract awards:
      • Competitive bids, sole source, etc.
      • Justifications for sole source awards
      • Justifications for not awarding to small businesses
    • Resources used to locate a business
    • Reasons for not using a small business that appears to meet the requirements

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good faith efforts3
Good Faith Efforts
  • Other necessary documentation includes:
    • Completing the “Remarks” section of the ISR each reporting period with notes on progress or lack of progress in meeting goals - important when faced with failure to meet the established goals.
    • Any contact with the various resources available, i.e. CMR, SBA, OSDBU, etc.

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good faith efforts4
Good Faith Efforts
  • Why is it important to demonstrate “Good Faith Efforts”?
    • To avoid costly liquidated damages
    • To avoid negative past performance reports

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good faith efforts5
Good Faith Efforts
  • Failure to meet goals and failure to demonstrate “Good Faith Efforts” will result in the application of the Liquidated Damages clause.
  • “The amount of damages attributable to the contractor’s failure to comply shall be an amount equal to the actual dollar amount by which the contractor failed to achieve each subcontracting goal.” FAR 19.705-7(b)

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

slide56
Monitoring for Compliance

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

keys to compliance
Keys to Compliance
  • Establish written policies and procedures for:
    • Procurement
    • Training of purchasing personnel
    • Documentation
    • Tracking
    • Reporting

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

keys to compliance1
Keys to Compliance
  • Train your staff!
    • Educate them on:
      • Written company policies and procedures
      • Applicable FAR regulations
      • NAICS codes
      • SBA Size Status criteria
      • How to write a plan

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

slide59
Best Practices

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

policies
Policies
  • Establish written policies and procedures for:
    • Procurement
    • Training of purchasing personnel
    • Documentation
    • Tracking and reporting of Goal Achievement

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

maintain historical data
Maintain Historical Data
  • Database to include:
    • Current and past vendors
      • Detail products and services provided
      • NAICS codes and associated size status
      • Past performance
      • Capability statements

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

maintain lists databases
Maintain Lists & Databases
  • Bidders Lists
  • Internal Databases
  • External Databases
    • CCR’s Dynamic Small Business Search
    • NIH’s e-PIC (e-Portals In Commerce)

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

database of potential new subcontractors
Database of Potential New Subcontractors
  • Database to include:
    • New vendors
      • Contact Information
      • NAICS codes and associated size status
      • Capability statements
      • References

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

database of past performance
Database of Past Performance
  • Database to include:
    • General contract information
      • Goals established
      • Goals achieved
      • Problems encountered and solutions

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

maintaining vendor size status information
Maintaining Vendor Size Status Information

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

subcontractor size certification
Subcontractor Size Certification
  • Re-certification of each business’s size classification should be done as often as the contract or regulations require
  • This can be as often as annually
  • Business size certification can be as complicated as an officially signed Representations and Certifications document or as simple as a signed statement on company letterhead

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

subcontractor self certification
Subcontractor Self Certification
  • The mechanism chosen for businesses to self certify should contain the following:
    • Small business types that must be reported
    • Penalty clause for providing false information
    • Point of contact
    • Signature of party providing information

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

subcontractor self certification1
Subcontractor Self Certification
  • Certification documents should be updated at regular intervals
  • Certification documents should be retained in a central location in either hard copy form or electronically
  • Documents should be readily available for audit by SBA and/or other agencies

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

subcontractor data
Subcontractor Data
  • Documents will be checked by SBA for:
      • Consistency of data collection
      • Data reporting across all vendors
  • The information collected by these documents should be entered either into a database or the accounting system for ease of reporting

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good ideas
Good Ideas
  • Become active in Business Organizations such as:
    • Your local Chamber of Commerce
    • Professional Groups that share your businesses interests and goals
    • Local small business outreach centers

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

good ideas1
Good Ideas
  • Contact the SBA
  • Contact the OSDBU at each agency where you have a working relationship
  • Offer to help small business become subcontractors with your company or others
  • Participate in Mentor-Protégé programs
  • Establish Joint Ventures

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

slide72

A+

Follow these guidelines and your organization can make the grade in Small Business Subcontracting Compliance!

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management

resources
Resources
  • SBA website: http://www.sba.gov
  • AcqNet: http://www.arnet.gov
  • CCR: http://www.ccr.gov
  • eSRS: http://esrs.gov

Patricia Downing

Aronson & Company(301) 222-8227

NCMA World Congress 2006

:

Achieving High Performance in Global Business: Leadership, Outsourcing, & Risk Management