BSE Contract Monitoring.ppt · –Electronic/Paper 44 Time Bound •Set forth time frames •Right...
Transcript of BSE Contract Monitoring.ppt · –Electronic/Paper 44 Time Bound •Set forth time frames •Right...
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CONTRACT MONITORING
Jennifer Berrios, Luke Madonna, Stephan Ramcharran,
& Mike Wood
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Why are we here?
We are here because we have a duty and mission to carry out.
Today’s duty and mission:
– Learn about monitoring
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Roadmap
• Monitoring necessity
• Challenges and concerns
• Impact
• Seven‐step process
• Fraud
• Field visits
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Monitoring Necessity
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Why Monitoring is Necessary
• Agency missions
• Billions in State spending
• Risks
– Health & Safety
– Goal Achievement
– Dollars
– Reputation
• Fraud
• Errors
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Challenges and Concerns
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Brainstorming Session
Agency Concerns When Trying to Monitor
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Common Concerns
• Lack of resources (time, funding, staff)
• Staff turnover/Lack of training
• Lack of communication between program and fiscal departments
• Vendor compliance (Reports, timeliness of filings)
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Impact
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Impact
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7 Step Process
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7-Step Process
1. Identify risky contracts
2. Understand requirements
3. Identify risks
4. Prioritize risks
5. Determine risk response
6. Design/execute monitoring activities
7. Follow up
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Step 1:Identify Risky Contracts
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Step 1.Identify Risky Contracts
• What data do you have available?
• How can it help you identify risky contracts?
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Risks
• Health & Safety
• Goal Achievement
• Dollars
• Reputation
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Identify Risky Contracts
Sort contracts by:
• Contract Types
• Contract Amount
• Vendor Name & Contract Count
• Vendor Name & Spending to Date
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Identify Risky Contracts (cont.)
Sort contracts by:
• Contract Start Date
• Contract Description & Contract Count
• Contract Description & Contract Amount
• % Expended ‐ % Life of the contract
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Common Concerns
• Risk basis
• Other factors
– Quality of products and services
– Problems with vendors
– Current events
– Locations
– Etc.
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Filter By ‘Contract End Date” to Eliminate Expired Contracts
Filter By ‘Contract End Date” to Eliminate Expired Contracts
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Consider Eliminating Fully Expended
Contracts
Consider Eliminating Fully Expended
Contracts
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Common Concerns
Contract Type Sum of Current Contract Amount Sum of Spending to Date Count of Contract Type
Commodity 555,001,257.01$ 172,310,150.97$ 99
Community Projects Fund (Member Initiative) 13,156,897.00$ 10,662,947.32$ 509
Consultant 7,305,957,655.67$ 5,043,101,076.48$ 534
Contracts Not Subject to OSC Pre‐Audit 505,364,519.96$ 405,947,165.41$ 1,767
Equipment 46,320,955.22$ 40,967,498.77$ 38
Grant 14,225,068,221.14$ 9,538,591,439.48$ 7,412
Inter‐government ‐ Other 71,797,233.54$ 33,596,984.98$ 4
Land Purchase 30,000.00$ 30,000.00$ 1
Lease 438,011,159.03$ 305,212,152.89$ 80
Printing 273,464,215.00$ 219,468,473.12$ 9
Repayment to State 990,969,897.00$ ‐$ 5
Revenue Generating 1,263,254,569.75$ ‐$ 898
Service 309,972,036,478.61$ 12,791,498,708.82$ 521
Grand Total 335,660,433,058.93$ 28,561,386,598.24$ 11,877
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Filter on Risky Contract Type and Current Contract Amount
Filter on Risky Contract Type and Current Contract Amount
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Payment SizePayee/Vendor Total Amount Payments Average Payment
CENTERS FOR MEDICARE & MEDICAID SERVICES 264,471,731.40$ 2 132,235,865.70$
EXCELLUS ‐ DSH‐ BLUE CROSS BLUE SHIELD 86,947,204.78$ 1 86,947,204.78$
NEW YORK QUALITY HEALTHCARE CORPORATION 23,704,473.69$ 1 23,704,473.69$
DS600 OFFICE OF MENTAL HEALTH 45,237,119.08$ 3 15,079,039.69$
NEW YORK EHEALTH COLLABORATIVE INC 12,515,947.64$ 1 12,515,947.64$
MONTEFIORE HEALTH SYSTEM INC 23,887,296.00$ 2 11,943,648.00$
MAXIMUS INC 21,212,748.10$ 2 10,606,374.05$
HEALTHPLUS HP LLC 10,123,589.20$ 1 10,123,589.20$
ONE BROOKLYN HEALTH SYSTEM INC 10,000,000.00$ 1 10,000,000.00$
UNITEDHEALTHCARE OF NEW YORK INC 9,871,323.37$ 1 9,871,323.37$
HEALTH FIRST PHSP INC 16,997,203.77$ 2 8,498,601.89$
EXCELLUS ‐PGP‐ BLUE CROSS BLUE SHIELD 30,177,188.27$ 4 7,544,297.07$
ROSWELL PARK CANCER INSTITUTE 88,856,488.69$ 17 5,226,852.28$
LONG ISLAND JEWISH MEDICAL CENTER 7,358,670.59$ 2 3,679,335.30$
MVP HEALTH PLAN 5,024,512.42$ 2 2,512,256.21$
EXCELLUS HEALTH PLAN INC 7,370,331.88$ 3 2,456,777.29$
ST JOSEPHS HOSPITAL 4,616,442.00$ 2 2,308,221.00$
NEW YORK CITY SCHOOL DISTRICT 5,570,959.47$ 3 1,856,986.49$
ST JAMES MERCY HOSPITAL 3,406,746.12$ 2 1,703,373.06$
CENTERS PLAN FOR HEALTHY LIVING LLC 1,608,694.46$ 1 1,608,694.46$
HEALTH INSURANCE PLAN OF GREATER NEW 3,108,638.32$ 2 1,554,319.16$
MAXIMUS HEALTH SERVICES INC 9,226,155.40$ 6 1,537,692.57$
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Monitoring
• You’ve selected a contract, now what?
• MONITOR!
• (Yeah, but what is that, really?!)
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Monitoring
Ongoing activities, special evaluations or a combination of both used to ensure that controls are operating as intended.
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Controls Purpose
• Compliance with laws, rules, and regulations
• Accomplish goals and objectives
• Relevant and reliable data
• Efficient and effective operations
• Safeguarding assets
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Internal Controls Pyramid
Control Environment
Risk Assessment
Control Activities
Monitoring
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Monitoring
Ongoing activities, special evaluations or a combination of both used to ensure that contractors are operating as intended.
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Operating as Intended
How do agency employees and contractors know what’s intended?
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Step 2:Understand
Contract Terms
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Step 2. Understand Contract Terms
• Intuition
• Conversation
• Purchase order details
• Contract specifications
• Laws, rules & regulations
• Guidelines
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Requirements
• Understand
• Assess quality
• Ask this:
– How can I verify whether something has occurred, based on how the contract specification is written?
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Specifications
• Specific
• Measurable
• Achievable
• Relevant
• Time‐Bound
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Specific
• Clear, detailed, easily understood
• Deliverables
– Description
– Benchmarks
• Location
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Measurable
Performance measures
• Quantities
• Timing
• Expertise
– Licenses
– Degrees
– Certifications
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Achievable
Payment provisions
• Payment triggers
• Invoice formats
– Description of deliverables
– Services
• Names of workers
• Hours for each worker
• Client names (SSN and/or address)
• Dates of service
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Relevant
• Requirements
– Is the vendor able to meet specific terms set forth?
• Reasonableness
– Producing Records
– Reports
– Electronic/Paper
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Time Bound
• Set forth time frames
• Right to audit
– Specify monitoring in contract language
– Consequences for non‐compliance
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Specification Example
The vendor shall submit a properly executed application for payment, together with appropriate backup supporting the amount billed.
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Specification Example
The vendor shall submit a properly executed application for payment, together with appropriate backup supporting the amount billed.
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Specification Example
The vendor shall submit a properly executed application for payment, together with appropriate backup supporting the amount billed.
Improved Specification????
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SpecificationAdminister the pre‐tax transportation program for eligible employees.
Auto‐answer customer service calls within 7 seconds (99% annual compliance), with a representative on the line within 2 minutes (90% annual compliance).
Fares mailed to recipients to use by the first of the month.
Monthly billing rate on a sliding scale based on the number of enrollees.
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Step 3:Identify Risks
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Step 3. Identify Risks:What can go wrong?
• Programmatic
–What can prevent the goal accomplishment?
• Fiscal
– How can the contractor get money they didn’t earn?
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What is Fraud?
• Misstatement
–Mistake vs. Fraud
• Knowledge of falsehood/intent
• Reliance by victim
• Damage
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What is Fraud?
Fraud is any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain.
Source: “Managing the Business Risk of Fraud: A Practical Guide” ‐ IIA, AICPA, ACFE
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What is Occupational Fraud?
The use of one’s occupation for personal enrichment through the deliberate misuse or misapplication of the employing organization’sresources or assets.
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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How Much Is Lost?
• 5% of annual revenues
• Median loss of $130,000
– $200,000 for small businesses
– $75,000 for not for profit
– $118,000 for government
• 22% had losses of at least $1 million
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Frequency and Median Loss Based On Duration of Fraud
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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How Is It Committed?
CorruptionAsset
MisappropriationFinancial Statement
Fraud
Bribery• Bid Rigging• Invoice Kickbacks
Fraudulent Disbursements• Check & Payment Tampering• Billing
Asset/Revenue Over‐ and Understatements• Improper Disclosures
Conflict of Interest• Purchasing Schemes
Noncash•Larceny
Most Common
Least Common
Most $$$ Least $$$
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
5757
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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5858
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Where Does It Happen?
More than 77% of the frauds in the study were committed by individuals in 1 of 8 departments, including:
• Accounting – check tampering, billing
• Operations – corruption, noncash theft
• Executive/upper management – corruption, billing, financial statement fraud, expense reimbursement
• Sales – corruption, noncash theft
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Internal Control Weaknesses Contribute to Fraud
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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How Does Fraud Happen?
Rationalization
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How Does Fraud Happen?
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Motive Flags
High debt
Significant financial losses
Excessive alcohol, drugs or gambling
Extramarital affair
Perceived organizational inequities
Job frustration or resentment
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How Does Fraud Happen?
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Opportunity Flags
Familiarity with operations
Ability to override controls
No periodic rotation of key employees
No uniform personnel policies
Lack of strong internal controls
Management does not prosecute or punish fraud perpetrators
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How Does Fraud Happen?
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Rationalization Flags
They owe me
I’m overworked
I do the work of two people
They’ll never miss it
I’ll just borrow it; I’ll pay it back
I’m not really hurting anyone
Everyone is a little dishonest
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How Does Fraud Happen?
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Capability Flags
Position/function
Brains
Confidence/ego
Coercion skills
Effective lying
Immunity to stress
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How Does Fraud Happen?
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Profile of the Worst Occupational Fraudster
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Age
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Education
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Criminal History
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Occupation
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Tenure
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Gender
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
World Middle Eastand North Africa
United StatesMale Female
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Profile of the Occupational Fraudster?
Typical Worst
Age 31‐50 56+
Education University Degree Postgraduate Degree
Criminal History None None
Occupation Employee/Manager Owner/Executive
Tenure 1‐5 years 6+ years
Gender Male Male
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12% 24% 33% 52% 68%77% 84% 93% 99%
Fraudster Details
In ___ percent of profiles, the perpetrators did not leave it at one single fraudulent act, but committed repeated acts of fraud.
Source: KPMG Global Profile of the Fraudster Survey 2013
93%
Source: KPMG Global Profile of the Fraudster Survey 2013
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Fraudster’s Motivation
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How Long Does Fraud Go Undetected?
A one‐year study conducted by the Association of Certified Fraud Examiners (ACFE) consisting of 2,690 cases world‐wide of occupational fraud found the typical fraud continued for __ months before being detected.
Source: KPMG Global Profile of the Fraudster Survey 2013
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6 months 10 months 12 months 16 months 18 months 22 months 24 months
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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How Long Does Fraud Go Undetected?
Source: 2018 Report to the Nation on Occupational Fraud & Abuse
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Fraud Detected By:
Source: 2018 & 2016 Report to the Nation on Occupational Fraud & Abuse
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Source of Tips:
Source: 2018 & 2016 Report to the Nation on Occupational Fraud & Abuse
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Red Flags
A warning or sense that something isn’t right
Should lead you to take a closer look at the transaction
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Document Flags
Inadequate, copied or apparently altered documents
Invoice figures do not add up
No letterhead
Misspellings on document
Vague information
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Document Flags
Hand written endorsement
No phone number or fake phone number
Altered payee name
PO Box, suite number, mail drop address
Company name includes initials or personal name
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Document Flags
Round amounts or amounts under approval levels Large dollar payments made with cash Vendor address is not local, but check is cashed locally
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Bid Rigging Flags - Vendors
Fake Vendors
Agency staff created bids in some cases
Real Vendors
No knowledge of bid submission
Shared owner with favorable vendor
Rescind bid
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Contracting Flags
Restrictive or vague specifications
Bids/quotes received from the same fax
Similar letterheads of bidders
Unreasonable bid amounts (prevailing wage)
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Contracting Flags (cont)
Unable to confirm bids with losing vendors
Lowest bidder does not receive award
Lack of vendor contact information on bids
Signature on bid is the company name
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Conflict of Interest Flags
Relationships between awardee and agency staff
Address or identification number match
Unexplained or unusual favoritism of a particular vendor
Close socialization with or acceptance of gifts from the awardee
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Bribes and Kickbacks Flags
Unjustified favoritism of a certain vendor
Unexplained increase in wealth of employee
Close socialization with or acceptance of inappropriate gifts from a vendor
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Additional Red Flags
Billed for services – more difficult to verify
No supporting documentation submitted with payment request
Relationships between the sponsoring legislator and NFP Executive(s)
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Finding Relationships• Check the Financials
– NFP’s 990 ‐www.guidestar.org
– For Profit – Published
• Google Maps
• White pages
• SeeThroughNY
– www.seethroughny.net
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Why Don’t People Report Their Suspicions?
• Fear of repercussion
• Feel like nothing will be done
• Inconvenience
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Civil Service Law §75-b –“Whistleblower Law”
Prohibits a public employer from taking disciplinary action against a public employee because that employee reveals information to a governmental body regarding a violation of a law, rule or regulation which presents a substantial and specific danger to public health and safety or reveals information which the employee reasonably believes is an impropergovernmental action (i.e., violation of Federal, State or Local laws, rules or regulations).
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Civil Service Law §75-b –“Whistleblower Law”
To be protected by this law, you must make a good faith effort to inform your employer and give them reasonable time to take appropriate action.
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Specification What can go wrong?Administer the pre‐tax transportation program for eligible employees.
Program services provided to ineligible employees.
Auto‐answer customer service calls within 7 seconds (99% annual compliance), with a representative on the line within 2 minutes (90% annual compliance).
Calls answered outside these time periods on average, with some exceeding the 2 percent penalty variance in the contract.
Fares mailed to recipients to use by the first of the month.
Employees don’t receive their fares –have to pay retail.
Monthly billing rate on a sliding scale based on the number of enrollees.
Vendor bills at a higher rate than entitled to, either by inflating the rate or by charging a rate for a higher strata of number of enrollees.
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Step 4:Prioritize Risks
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Step 4. Prioritize Risks: So What’s The Big Deal?
IVArea of
Most Concern
IIArea of
Minimal Concern
IIIArea of
Moderate Concern
IArea of
Least Concern
HIGH
LOW
Impact
Likelihood
LOW HIGH
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Step 4. Prioritize Risks: So What’s The Big Deal?
IVArea of
Most Concern
IIArea of
Minimal Concern
IIIArea of
Moderate Concern
IArea of
Least Concern
HIGH
LOW
Impact
Likelihood
LOW HIGH
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Step 5:Determine Risk
Response
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Step 5. Determine Risk Response
IIArea of
Minimal Concern
IIIArea of
Moderate Concern
IVArea of
Most Concern
IArea of
Least Concern
HIGH
LOW
Impact
Likelihood
LOW HIGH
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Determine Agency’s Response To The Risks
• Mitigate
– Revise administrative procedures
– Improve control systems
– Increase auditing
– Other
• Accept
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Step 6:Design/Execute
Monitoring Activities
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Step 6. Design and Implement Monitoring Activities
Design steps to mitigate risks
• Who is going to do it?
• How are they going to document it?
• Whom are they going to give the documentation to?
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Monitoring
Objective
• Gather information to determine whether or not things are happening the way they are supposed to be.
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Evidence
• Enough information (Sufficient)
• The “right” information (Appropriate)
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Evidence
• Three types of evidence:
• Thomas P. DiNapoli
– Testimonial
– Physical
– Documentary
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EvidenceDegree of Reliability
Evidence Type
More reliable Less reliable
More reliable
Physical
• Evidence obtained through direct physical examination, observation, computation and inspection
• Evidence obtained through indirect means
Less Reliable
Documentary
• Original documentation received from independent parties
• Photocopies of documents• Documents received from
the contractor
Testimonial
• Statements obtained from unbiased persons with direct knowledge under conditions in which the persons may speak freely
• Statements obtained from persons who• Are biased or have
only indirect knowledge
• May feel intimidated
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Specification What can go wrong? How agency can monitor?Administer the pre‐tax transportation program for eligible employees.
Program services provided to ineligible employees.
Compare vendor’s monthly employee registry to OSC report of eligible employees. Review all variances with vendor.
Auto‐answer customer service calls within 7 seconds (99% annual compliance), with a representative on the line within 2 minutes (90% annual compliance).
Calls answered outside these time periods on average, with some exceeding the 2 percent penalty variance in the contract.
Review monthly and annual reports of system performance to identify anomalies. Based on variances, determine the need to assess penalties.
Fares mailed to recipients to use by the first of the month.
Employees don’t receive their fares – have to pay retail.
Obtain database of vendor incoming calls to identify complaints of not receiving fares timely.
Monthly billing rate on a sliding scale based on the number of enrollees.
Vendor bills at a higher rate than entitled to, either by inflating the rate or by charging a rate for a higher strata of number of enrollees.
Verify number of enrollees based on item 1 above, compare rate charged to the rate in the contract based on the appropriate volume strata.
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Brainstorming Session
Contractor Concerns
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O
Who Should Monitor?
• Program staff
• Finance staff
• Consultants
• Agency auditors
• OSC auditors
PP PP PP
FF
PP
FF
FF
CC
FF
AA
OO
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Monitoring Process
• Timing
• Extent
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Human Communication
• ___ % communicated through words
• ___ % communicated in hidden messages
• ___ % communicated through nonverbal behavior
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Human Communication
• 3.5 % communicated through words
• 3.5 % communicated in hidden messages
• 93 % communicated through nonverbal behavior
– 55% body language/facial expressions
– 38% tone/voice
Source: Mehrabian, Albert (1971). Silent Messages (1st ed.)
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Facial Expressions
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Before You Go…….
• What do you already know?
• What do you still need to know?
• What do you need to see?
• Who can tell you?
• Who can show you?
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At the Contractor
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Professional Skepticism
An attitude that includes a questioning mind and critical assessment of information.An attitude that includes a questioning mind and critical assessment of information.
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Questioning Mind
• Why?
• Show me!
• Does this make sense?
• How can I verify it?
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• Prepare
• Rapport
• Use open‐ended questions
• Use list?
• Leave business card
The Interview
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Desk Audit
• Phone calls
• Documentation
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After the Road Trip or Desk Audit
• What did you learn?
• Was everything “O.K.”?
• Were there any red flags?
• Who needs to know?
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Brainstorming Session
Qualities of an Effective Monitor
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Step 7:Follow‐Up
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Step 7. Follow UpDegree of Compliance
Agency Response
High • Re‐evaluate and possibly reduce monitoring frequency
Moderate
• Direct the contractor to correct identified deficiencies
• Facilitate development of a corrective action plan
• Advise accounts payable employees
• Identify and recover any overpayments
• Increase scrutiny of contractor reports and invoices
• Increase frequency of follow‐up monitoring activities
Low
• Facilitate development of a corrective action plan (where practical) and increase the frequency of follow‐up monitoring activities
• Increase scrutiny of contractor reports and invoices
• Terminate contract where corrective action is not practical
• Advise accounts payable employees
• Identify and recover any overpayments
• Consider referral for prosecution
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Review
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Review:
The 7 Step Process
7
6
5
4
3
2
1
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Step 1. Identify Risky Contracts
• What data do you have available?
• How can it help you identify risky contracts?
134
Step 2. Understand Contract Terms
• Intuition
• Conversation
• Purchase order details
• Contract specifications
• Laws, rules & regulations
• Guidelines
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Step 3. Identify Risks:What can go wrong?
• Programmatic
–What can prevent the goal accomplishment?
• Fiscal
– How can the contractor get money they didn’t earn?
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Step 4. Prioritize Risks: So What’s The Big Deal?
IIArea of
Minimal Concern
IIIArea of
Moderate Concern
IVArea of
Most Concern
IArea of
Least Concern
HIGH
LOW
Impact
Likelihood
LOW HIGH
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Step 5. Determine Risk Response
• Mitigate
– Revise administrative procedures
– Improve control systems
– Increase auditing
– Other
• Accept
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Step 6. Design and Implement Monitoring Activities
Design steps to mitigate risks
• Who is going to do it?
• How are they going to document it?
• Whom are they going to give the documentation to?
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Step 7. Follow UpDegree of Compliance
Agency Response
High • Re‐evaluate and possibly reduce monitoring frequency
Moderate
• Direct the contractor to correct identified deficiencies
• Facilitate development of a corrective action plan
• Advise accounts payable employees
• Identify and recover any overpayments
• Increase scrutiny of contractor reports and invoices
• Increase frequency of follow‐up monitoring activities
Low
• Facilitate development of a corrective action plan (where practical) and increase the frequency of follow‐up monitoring activities
• Increase scrutiny of contractor reports and invoices
• Terminate contract where corrective action is not practical
• Advise accounts payable employees
• Identify and recover any overpayments
• Consider referral for prosecution
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For Future Reference
Guide to Financial Operations
‐ XI.11.F Contract Monitoring
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Final Thought
Margaret Mead