Direct Brown to strengthen its policies, procedures, and internal control processes for applying its federally negotiated indirect cost rates to NSF awards. These updated policies, procedures, and internal control processes should ensure Brown is: • Appropriately applying its indirect cost rates to all direct costs that should be included in its Modified Total Direct Cost base per its negotiated indirect cost rate agreements. • Accurately classifying all costs for accounts that are included within its Modified Total Direct Cost base per its negotiated indirect cost rate agreements.