Direct BSCS to strengthen its policies and procedures for creating and retaining documentation, including introducing additional controls to help ensure that it appropriately creates and maintains all documentation necessary to support the allowability of expenses charged to sponsored programs. Updated procedures could include: • Requiring confirmation that an active consultant service agreement is in place before paying a consultant service invoice. • Establishing tracking documentation for gift cards charged as participant support costs. This documentation would include the information necessary to identify who received the gift cards and when.