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Contract Employee's Newsletter
Helping Contract Professionals
Manage Their Careers
October 01, 2001
Edited by James R. Ziegler
A Companion to:
The Contract
Employee's Handbook
www.cehandbook.com
Sponsored by:
P.A.C.E. - Professional
Association for Contract Employment
www.pacepros.com
About The Contract Employee's Newsletter
The Contract Employee's Newsletter is a free e-mail publication
for technical and professional contractors containing news, commentary,
tips, links to useful resources, nuggets of wisdom submitted by
readers, and anything else that seems appropriate at the time. The
CENewsletter is distributed bimonthly or whenever issues warrant.
The subscriber list is confidential and will not be disclosed outside
this organization.
In This Issue
Read recent
issues of The Contract Employee's Newsletter.
Suggest A
Topic For The Newsletter
Ideas Anyone?
I invite you to submit your ideas for newsletter topics.
Chances are, if a certain topic interests you as a Contract Professional
it will interest the majority of our readers.
Guest Appearances
Would you like to contribute a short piece to the Contract
Employee's Newsletter? Maybe a marketing tactic that works for you,
or a true story of agency madness? I'll cite your name, your e-mail
address, and a link to your website. I can't pay you, but I'll make
sure that everyone who reads the Contract Employee's Newsletter
knows who you are and what you do. It can't hurt, and, who knows,
it just might help your consulting career. Contributions should
be of general interest to all Contract Professionals.
Mail your suggestions to suggestion@pacepros.com.
Return to Table of Contents.
Marketing Tips
You Are A Vendor, So Market Yourself Like One
This marketing tip will vastly increase your chances of getting
through to the appropriate decision maker. It requires some simple
cold calling, but this is not a sales call. It is more like an informational
interview. Here is how it works.
Call companies that may require your skills and expertise. When
you reach the operator say the following:
"Hello, my name is [your name]. My company is a vendor of
technical consulting services to companies in your industry. My
division specializes in [two or three word description]. Who should
I contact regarding your company's requirements in this area?"
If the operator suggests HR, say something off the cuff like:
"Oh, you probably thought I was a headhunter or a job-seeker.
Actually, my company is a vendor of technical consulting services.
Who should I address our marketing materials to? Is there a specific
project manager or director in charge of [two or three word description]
that I should address this to?"
The operator may send you to the Purchasing Department. Great.
Ask the purchasing agent how you can qualify your company as a vendor
for [two or three word description], and ask who you should speak
with about upcoming projects in your company's area of expertise.
Note that you never indicate that you personally
are the one and only provider of this service. You are not wearing
your "out-of-work employee" hat. In fact, you already
threw it away. You are wearing your "company representative"
hat.
By taking this approach you present yourself as a vendor
as opposed to an out-of-work employee. Your search is now targeted
to those specific individuals who need the services provided by
your company.
If anyone asks what company you are with simply give the name of
your employer of record. For example, P.A.C.E. Division Managers
say "My company is P.A.C.E." If you are an independent
contractor give the name of your sole proprietorship or one-person
corporation, or give the name of your company's DBA.
This approach is not a ruse. The default business status of every
American citizen is sole proprietor, and you are a one-person business
whether you realize it or not.
P.A.C.E. Division Managers have reported good success with this
approach.
Let me know how this approach works for you. I would also like
to hear about successful variations on this theme. I'll publish
them in an upcoming issue.
Mail your suggestions to suggestion@pacepros.com.
Return to Table of Contents.
Ask Dungaree Dan
Recruiter Threatened By His Own Agency's Noncompete
Clause
Q: Dear Dan -- I am a VP of a temporary help company for
medical personnel in California. I have a noncompete & restrictive
covenant clause in my contract. I desperately want to go out on
my own. I've been with this company 15 years. Can you advise me
on my options. I heard that noncompete clauses in California do
not hold up in court. What direction can I go. By the way, I love
all of your valuable information. Thanks. -- Signed: Bound But
Determined
A: Dear Bound But Determined -- I am tempted to expand upon
the principal of what goes around comes around. Or wax poetic on
the idea that the taste of one's own medicine is by far the most
bitter. Oh, the irony of it all. A VP of a recruiting firm is asking
me of all people for advice on how to beat an agency noncompete
clause. Geesh.
You say you are an agency VP, and have been with the company for
15 years. Undoubtedly, you have given lots of attention to enforcing
noncompete clauses. Should I be surprised that in 15 years you have
not learned how to avoid getting burned by one yourself?
Oh well, I'll cut you some slack this time. After all, you did
say you love all of my valuable information. I'll pretend you want
to come over from the dark side to become a P.A.C.E.
Certified Marketing Agent, who works exclusively for talented
Contract Professionals, and who has zero conflict of interest with
the Contract Professionals you represent.
In return for my help I want you to vow that you will never use
overly broad and intimidating contract language in your new recruiting
practice, and that you will freely and openly disclose the agency
billing rate to your temporary employees and independent contractors.
Caveat: I am reasonably certain that the following information
is a fair discussion of noncompete clauses as they might apply to
your situation. However, I am NOT authorized to give legal advice.
Therefore, before you do anything rash I recommend that you take
a copy of your employment agreement to an employment law attorney
for review and proper legal advice.
Companies use different types of contract language in an attempt
to keep their employees from going to work for the competition.
The contract clauses fall into three categories:
- Nondisclosure
- Nonsolicitation
- Noncompetition
Nondisclosure clauses protect the employer from a former
employee disclosing proprietary and confidential information to
a competitor. Examples are "trade secrets", customer lists,
internal reports and documentation, computer code, design specifications,
and the like.
Nonsolicitation clauses protect the employer from a former
employee actively recruiting existing employees and clients of the
employer for the employee's new company.
Both nondisclosure and nonsolicitation clauses offer reasonable
protections against unfair competition. Employees should have no
difficulty abiding by such provisions so long as the language is
not overly broad and the employee behaves ethically.
Noncompetition clauses are troublesome because they prohibit
an employee from working for the competition or for a client or
vendor of the competition within an arbitrary radius and time limit.
Such clauses are frequently seen in the employment agreements of
professionals such as beauticians, accountants, attorneys, and physicians,
where one individual may have a dedicated clientele.
For example, it is common in most states, with the notable exception
of California, for medical practices to require that member physicians
agree not to work within 100 or 200 miles of the original practice
for a duration of one or two years. This is because physicians generally
have a dedicated clientele, which the practice has developed at
great expense. These patients would undoubtedly follow a physician
to a new practice resulting in significant loss of income to the
original practice.
Temp agencies are notorious in their use of intimidating and overly
broad "covenants not to compete". Aggressive covenants
not to compete are routinely included in vendor agreements with
subcontracting agencies and independent contractors, and in the
employment agreements of staff employees, temporary employees, recruiters,
and executive personnel.
Properly worded, narrowly defined nondisclosure and nonsolicitation
clauses are perfectly legal in all states. Noncompetition clauses,
if not abusive and overly broad, are enforceable in virtually every
state except California and New Hampshire. The prohibition against
blanket noncompetition clauses for agency temps was discussed in
the September
15, 2001 issue of The Contract Employee's Newsletter.
In California, by statute, noncompetition agreements are void as
a restraint of trade, so if you have signed a blanket noncompete
clause with a California employer you are generally free to change
employers at will. Blanket noncompete clauses are not enforced by
California courts or by the California Department of Industrial
Relations.
See: California
Business and Professions Code:
"16600. Except as provided in this chapter, every
contract by which anyone is restrained from engaging in a lawful
profession, trade, or business of any kind is to that extent void."
In the last issue of of The Contract Employee's Newsletter I cited
a decision in Federal District Court:
CASE: Robert
Half International v. Gregory J. Stenz
COURT: Federal District Court, Eastern District
SUMMARY: Applying Delaware law, as specified in the contract
between the parties, Court found that former employer of staffing
manager for Accountemps office could not enforce clause in employment
agreement which prohibited former employee from working for competing
staffing firm, but could enforce clause prohibiting solicitation
of former employer's clients or employees.
Specifically, the order reads:
- the Defendant IS enjoined from directly or indirectly
soliciting any of the Plaintiff's clients or candidates for whom
the Plaintiff has performed services in the course of its business
within the twelve months preceding March 24, 2000;
- the Defendant IS enjoined from soliciting, inducing,
or attempting to induce any other of the Plaintiff's employees
to leave the Plaintiff and become connected with the Defendant
at any other executive recruiting firm, employment agency or temporary
personnel services business;
- the Defendant IS enjoined from disclosing, furnishing,
or making accessible to any person, firm, corporation, or other
entity, or making use of, any confidential information obtained
while he or she was in the employ of the Plaintiff including information
obtained through the client and candidate databases of the Plaintiff;
and
- the Defendant IS NOT enjoined from owning, managing,
operating, controlling, being employed by, participating in or
being connected in any manner with the ownership, management,
operation or control of any competing executive recruiting firm,
employment agency or temporary personnel service business.
So, you can feel free to open your own agency provided that you
start from scratch, and you do not take with you any trade secrets
or proprietary information, and you do not attempt to solicit clients
or employees of your former agency.
In a recent and particularly insidious development the U.S. Court
of Appeals, 7th Circuit, (1995,
Pepsico Inc. v. Redmond) validated something called the Inevitable
Disclosure Doctrine (IDD). The IDD gives an employer the right to
prevent a former employee from working for a competitor if the employee
had access to the company's trade secrets and if their misappropriation
and disclosure to the competition is deemed to be inevitable.
Agency contracts often contain language that attempts to define
as trade secrets the names of your client contacts. Don't be surprised
if your agency tries to use the IDD to keep you from working for
a competing agency on the basis that you have learned agency trade
secrets that could help your new agency compete against your former
agency. The IDD has been upheld by courts
in California where you plan to set up shop.
I doubt seriously if an agency could successfully enjoin a contract
employee from jumping to a competing agency on the basis of "trade
secrets" and "proprietary information" since contract
employees scarcely have access to anything but the name of their
current client. However, a recruiter has access to virtually all
of an agency's higher level proprietary information, including client
lists, client contact information, internal policies and procedures,
and good will developed at the agency's expense.
OK, I did my part. Now, what about your vow that you will never
use overly broad and intimidating contract language in your new
recruiting practice, and that you will freely and openly disclose
the agency billing rate to your temporary employees and independent
contractors? -- Signed: Dungaree Dan
Questions for Dungaree Dan
Send your questions about contract employment to Ask
Dungaree Dan. We will try to answer all of your questions, and
we will publish the most interesting ones in The Contract Employee's
Newsletter.
Return to Table of Contents.
Survival Tactics
Identifying The Greed In Agency Subcontracts
The following is excerpted from an article called Inefficiency
and Greed.
Consider this scenario. You ask a third-party recruiting firm to
introduce you to prospective clients. You interview with one or
more companies, you select a client, and the agency quotes a W-2
wage as the amount they will pay you.
You would like to sign directly with the client as an independent
contractor but the agency explains in no uncertain terms that because
the agency found the contract assignment they own the
contract.
Agencies seek control of the contract because they perceive themselves
as working for the client, and because they perceive you
as their direct competitor (which, of course, you are).
Either you must work as the agencys employee or you must
work as the agencys subcontractor. But in either case it is
the agency that will sign a contract with the client.
As a subcontractor you have two options:
- Sign a subcontractor agreement with the agency as an independent
contractor.
- Select an employer of record that will sign a subcontractor
agreement with the agency as an independent contractor.
You may not need an employer of record if you qualify as a 1099-compliant
independent contractor. 1099-compliant means that you satisfy the
common law factors that define an independent contractor relationship.
In other words, you are able to satisfy the powers that be that
there is little chance that the IRS or another government agency
might reclassify you as an employee of the client.
Of course, you may not qualify as a 1099-compliant independent
contractor, or the agency may have a blanket fear of reclassification,
or you simply dont want the hassle of running your own consulting
business. In these cases you will have to become the employee of
a third-party employer of record.
If you convert to independent contractor status the agency will
save on payroll taxes, payroll processing costs, insurance costs,
and the cost of money for payrolling you before they receive payment
from the client. Instead, these costs will be passed on to you or
your employer of record.
How much will the agency save because they are now paying you or
your employer of record as an independent contractor?
If the agency does not pass the entire savings on in their pay
rate they will realize a significant windfall, and you will end
up earning significantly less than if you had agreed to be the agencys
employee.
Assume for the sake of argument that the agency had originally
offered you a W-2 wage of $100 per hour. What must the agency pay
to you as an independent contractor so that both the agency and
you break even on the deal?
Below is a brief discussion of the payroll-related costs that no
longer apply when the agency contracts with an independent contractor.
- Employers share of payroll taxes 12.45% of Gross
Wage
Companies pay out-of-pocket for payroll taxes on employees
gross wage. They do not pay taxes on what they pay to independent
contractors. Payroll taxes include:
- Workers Compensation 0.5%
Rates vary by region, industry, and experience level, but
they average about 0.5% of GW for white collar professions.
- FICA Social Security 6.2%
Employer pays 6.2% of GW out of pocket (and employee pays
6.2% of GW out of payroll). In 2001 the wage cap for FICA
SS, above which neither employer nor employee pays, is $80,400.
- FICA Medicare 1.45%
Employer pays 1.45% of GW out of pocket (and employee pays
1.45% of GW out of payroll). There is no wage cap for FICA
Medicare.
- FUTA Federal Unemployment Insurance 0.8%
The wage cap for FUTA is $7000.
- State Unemployment Insurance 3.5%
Rates vary among states and with the companys experience
level. The UI wage cap also varies among states. Owing to
their high number of UI claims temp agencies and contractor
recruiting firms have relatively high UI rates.
- Additional costs associated with payrolling an employee
2.35% of Gross Wage
Agencies incur additional costs associated with computing, processing,
and paying regular payrolls that they do not incur when paying
independent contractors.
- Cost of processing payroll 0.5%
This item includes the cost of a payroll service such as ADP,
plus associated administrative labor costs to compute and
process payroll.
- Cost for General liability and errors & omissions
insurance 0.15%
Agencies pay for GL and E&O insurance to cover their own
employees. They do not provide these insurance coverages for
independent contractors. Independent contractors must pay
for their own insurance coverage.
- Cost of benefits administration 0.55%
This item includes the setup and maintenance costs for retirement
plan and health insurance, plus associated administrative
labor costs.
- Cost to pay wages in advance of clients payment
Minimum of 1.00%
Temp agencies and recruiting firms must pay their contract
employees on regular paydays. The cost of money to advance
payroll on regular paydays is about 1% of wages, assuming
an average float of 30 days. Small firms that cannot qualify
for a sufficiently high line of credit must sell their receivables
to a factoring company. Factoring companies charge between
3% and 7% depending on volume.
- Bad debt 0.15%
The cost of bad debt can vary widely depending on the state
of the economy and on how well the agency qualifies its clients.
Agencies must pay their hourly-paid temporary employees regardless
of whether the client ever pays the agency. On the other hand,
agencies pay their subcontractors only if and when the client
pays the agency. When you operate as an independent contractor
your agency passes on the risk of bad debt to you or to your
employer of record.
Naturally, the overhead costs associated with payrolling agency
employees will vary from agency to agency. However, these figures
show that on average an agency will save about 15% of gross wage
when it converts from an employer-employee relationship to a client-vendor
relationship.
If you change your status from W-2 employee to independent contractor
your agency should increase your wage by at least 15%. Anything
less and the agency makes a windfall profit on the difference .
. . at your expense.
Most agencies will adjust up their W-2 pay rate by 5% or 10% at
the most. Dont let them get away with it. Use this analysis
to negotiate an independent contractor pay rate that is at least
15% higher than the agencys previously quoted W-2 rate.
The table below shows some equivalent independent contractor pay
rates based on a payroll overhead cost of 15%.
Table: W-2 Wage and Equivalent IC Pay Rate
|
Agencys Offer
of W-2 Wage
|
Equivalent
IC Pay Rate
|
| $35.00 per hour |
$40.25 per hour |
| $50.00 per hour |
$57.50 per hour |
| $75.00 per hour |
$86.25 per hour |
| $100.00 per hour |
$115.00 per hour |
Return to Table of Contents.
Resources
Online Glossaries and Dictionaries
Use these online resources to decipher employment and staffing
industry terminology.
Everybody's
Legal Dictionary
Alphabetical lists of legal terms with a search function on the
Nolo.com website.
Of interest to Contract Professionals are specialized lists for
Small Business, Employment Law, and Independent Contractors.
The
Staffing Industry Glossary of Terms
This glossary of staffing industry terms is a set of working
definitions for staffing industry professionals. Although
it is not a definitive list, it is useful nonetheless in deciphering
staffing industry lingo.
A recent search on Google.com
using the keywords <glossary or glossaries> returned over
50,000 listings. Narrow your search to identify specialized glossaries
by entering qualifying keywords, e.g. <insurance glossary>,
<retirement glossary>, <financial glossary>, <legal
glossary>, <legal dictionary>, etc.
Locate additional reference resources under the heading General
Reference in Appendix
A: Resources for Contract Workers in The
Contract Employee's Handbook.
Return to Table of Contents.
Contract Employee's
Glossary
Terminology For Contract Professionals
This issue focuses on terms beginning with the letter A.
Accountable plan
An accountable expense reimbursement plan is a written policy of
the employer governing the reimbursement of work-related expenses.
To be accountable the reimbursement policy must include all three
of the following rules.
- Expenses must have a business connection that is, you
must have paid or incurred reimbursable expenses while performing
services as an employee of your employer.
- You must adequately account to your employer for these expenses
within a reasonable period of time.
- You must return any excess reimbursement or allowance within
a reasonable period of time.
Expense reimbursements under an accountable plan are not part of
your income. They are paid with tax-free dollars, and they don't
appear on your Form W-2.
Umbrella services, such as the one provided by P.A.C.E.,
have accountable plans that are specifically designed to reimburse
Contract Professionals using tax-exempt dollars for all of their
work-related expenses. Ordinary employers of record such as recruiting
firms and temp agencies cannot do this.
Most contract employees incur significant expenses related to operating
their home office, keeping their skills up to date, and marketing
their services. A well crafted accountable plan lets your employer
of record offset these costs with tax-free reimbursements, potentially
saving you several thousand dollars a year.
All too often, Contract Professionals must convert to W-2 employment
status in order to satisfy the requirements of their IRS-wary clients.
In doing so, however, they give up the ability to write off most
of their out-of-pocket, business-related expenses. An accountable
plan lets W-2 employees "write off" their out-of-pocket
expenses just like a self-employed independent contractor.
Age Discrimination in Employment Act (ADEA)
ADEA is a federal law that prohibits arbitrary discrimination against
workers over the age of 40 in any employment decision, especially
firing. Companies must treat agency temps the same as their own
employees with respect to the provisions of ADEA.
Agency
A firm that functions as an agent or that employs agents. Frequently
used in place of the term contract employment agency. Examples are
recruiting firms, staffing firms, pass-through agencies, and umbrella
services.
Agency of record
Agency of record refers to an agency that has a direct contract
with a client to provide the technical or professional services
of a specified individual, in which that individual is operating
as an independent contractor. The term is used in the same context
as the term employer of record, in which case the agency provides
the technical or professional services of a contract employee.
Agent
An agent is an individual who facilitates a business relationship
in return for a fee. Examples are insurance agent, marketing agent,
talent agent, sports agent, and literary agent. Sometimes agents
are referred to as brokers.
Return to Table of Contents.
P.A.C.E. News
Free General Liability and Errors & Omissions
(E&O) Insurance
Contract Professionals with inadequate or no liability insurance
coverage pose a significant risk to their clients. There is the
risk that a contractor might damage a client's property or the property
of others, or injure someone while on the job. Or, a contractor
may damage the client's business through willful negligence or incompetence.
Many Contract Professionals do not carry liability insurance, so
the liability easily could pass to the client.
General Liability Insurance protects
both the contractor and the client from damage to persons or property.
Errors & Omissions (E&O) Insurance
(also known as Professional Liability Insurance) protects the contractor
and client from financial harm to the client's business caused by
the contract's actions.
Adequate individual coverage for both General Liability Insurance
and Errors & Omissions Insurance can cost several thousand dollars
per year.
All P.A.C.E. Division Managers are automatically covered for both
General Liability and Errors & Omissions Insurance up to $5,000,000
aggregate. This coverage is free to all P.A.C.E. Division Managers.
P.A.C.E. is a Win - Win - Win - Win Solution for Downsized Employees,
Contract Employees, Independent Contractors, and Client Companies.
Check out P.A.C.E.
for the best benefits package available to ANY employee in ANY company
in the USA.
Return to Table of Contents.
Contract Employee's
Handbook
IRS Recognizes Two Categories Of Individual Workers
The IRS recognizes two categories of individual workers.
- Independent Contractor
- Employee
Independent contractors may be sole proprietorships, partnerships,
limited liability companies, or corporations. Most technical and
professional consultants are either sole proprietorships or one-person
corporations. These are the two business forms that we usually associate
with individuals who operate as independent contractors.
There is some disagreement about the precise definition of an independent
contractor. Some authors restrict the term to individuals
working as an independent business. Others include all businesses
ranging in size from a one-person operation to the largest mega-corporation.
As far as most government agencies are concerned, an employee is
any individual worker who does not qualify as an independent contractor.
The Contract
Employee's Handbook has an excellent discussion about the factors
that distinguish an independent contractor from an employee. The
factors center around the issue of control. Employers control
the work of employees. They do not control the work of independent
contractors. When the IRS conducts an audit of employee status,
the auditors look for evidence of control. The IRS training manual
published in 1996 puts it this way:
Following the common law standard, the employment tax regulations
provide that an employer-employee relationship exists when the
business for which the services are performed has the right
to direct and control the worker who performs the services. This
control refers not only to the result to be accomplished by the
work, but also the means and details by which that result is accomplished.
In other words, a worker is subject to the will and control of
the business not only as to what work shall be done but
also how it shall be done. It is not necessary that the
business actually direct or control the manner in which the services
are performed; it is sufficient if the business has the right
to do so. Independent Contractor or Employee? IRS Training
Course 3320-102(10-96), pg. 2-3.
Click through to The
Contract Employee's Handbook. Chapter 1 discusses why it is
so very important that Contract Professionals thoroughly understand
the factors that distinguish an independent contractor from a regular
employee.
Return to Table of Contents.
Contract Employee's
Workshop
Have LCD Projector, Will Travel
I am developing an all-day Saturday Workshop for technical and
professional contractors. I call it The Contract Employee's Workshop.
(How original!)
During the initial shakedown period I will offer the workshop in
the San Francisco Bay Area. Cost of admission will be in the neighborhood
of $50, provided I can locate an inexpensive yet comfortable venue
large enough to hold at least 50 people. It would be nice to have
a corporate sponsor for the workshop, especially if I don't have
to sell my soul (and halo) to qualify for their support. Ideas anyone?
Participants will leave the workshop with a solid understanding
of how this crazy contracting industry works. Agency contractors
will learn how to increase their earnings by 30% to 50% on their
very next contract assignment. The handouts alone are worth the
cost of admission.
After the initial shakedown I'll take the workshop on the road
to those cities across the US that express the greatest interest
in The Contract Employee's Workshop.
I'm open to suggestions. E-mail your ideas and suggestions to Workshop@pacepros.com
Return to Table of Contents.
The Contract Employee's
Project
The Contract Employee's Project is the larger context under which
the following interrelated vehicles operate to promote and defend
the interests of Contract Professionals:
Copyright and
Publication Info
Copyright (c) 2001, James R. Ziegler. All rights reserved.
You may copy or forward this free publication provided it is left
intact with all links and this notice unchanged. Any unauthorized
duplication, including republication in part or in full for commercial
use, is an infringement of copyright.
Published by:
P.A.C.E. - Professional Association for Contract Employment
1355 Willow Way, Suite 244
Concord, CA 94520
U.S.A.
http://www.pacepros.com/
Editor:
James R. Ziegler, Ph.D.
Executive Director
P.A.C.E. -- Professional Association for Contract Employment
(925) 680-0200
ziegler@pacepros.com
Return to Table of Contents.
Disclaimer
The Contract Employee's Newsletter is designed to provide information
in regard to the subject matter covered. Use is granted with the
understanding that the publisher and authors are not engaged in
rendering legal or financial advice. If expert assistance is required
you should seek the services of a competent professional.
The purpose of this information is to educate and entertain. The
publisher and contributors shall have neither liability nor responsibility
to any person or entity with respect to any loss or damage caused,
or alleged to be caused, directly or indirectly, by the information
contained in this Newsletter or by information contained in any
web site or resource referenced by citation or hypertext link within
the pages of this Newsletter.
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Sign-off
I hope you have found the information in this newsletter to be
interesting, informative, and provocative. I encourage you to share
the CENewsletter with your friends, colleagues, coworkers, clients,
and agency recruiters.
Why clients? Because you need every ally you can get. Why agency
recruiters? Because they need to know the jig is up.
Wishing you success in your contracting career,
James R. Ziegler, Ph.D.
Executive Director
P.A.C.E. -- Professional Association for Contract Employment
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