This study examined the role of subcontractors and consultants in California's Employment Training Panel (ETP) program. Methods included interviews, focus groups, a phone survey, and a survey of projects without subcontractors. Results indicated that the market in which administrative and training consultants sell their services to employers is inefficient, with prices ranging significantly above the competitive and low product quality. Over the last 2 fiscal years, the total market for ETP subcontractors and consultants was $31-35 million or 36-40 percent of all money spent on ETP training. ETP subcontractors and consultants were categorized into seven subgroups based on company size and services provided: full-service companies; public or nonprofit agencies; hollow companies; niche trainers; freelance project administrators; freelance packager; and project doctor. Subcontractors and consultants offered benefits and risks to ETP. They played a major role in marketing but were aggressive. Many had expertise in developing projects, but some driven by profit incentives tried to shape projects most profitable to them. They could provide high quality state-of-the-art training but had an incentive to reduce the quality and hence its costs. They understood policy but tended to manipulate the process for gain. Recommendations were made to align the incentives that drive subcontractors and consultants with ETP's larger objectives and to transform the market into an orderly efficient one. (A report on market estimates is appended.) (YLB)