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Question
UrbanElectric, Inc. signs a 9-month contract with SkillSource Electrical, Inc. to provide 30 electricians for a citywide power distribution upgrade. SkillSource hires and pays its own workers, furnishes uniforms and PPE, and deploys its own on-site supervisor. UrbanElectric’s Project Management Office defines project milestones and approves electrical design plans, but does not issue day-to-day task assignments or discipline the workers. SkillSource invoices monthly and handles payroll taxes for its workers. The contract also includes a six-month extension option subject to funds. Are these arrangements permissible contracting, or Not Covered (labor-only contracting) under DOLE guidelines? Briefly explain the governing doctrine, distinguish the essential criteria, and apply to the facts.