Direct Dartmouth to strengthen its review procedures and internal controls over transferring significant parts of NSF-funded research to other organizations. Updated procedures could include: • Establishing procedures that require Dartmouth to verify that—for any subaward under an NSF grant awarded to Dartmouth—it specifically obtains approval from the NSF Grants Officer prior to issuing a subaward. This could be completed either as part of the NSF grant budget or through a formal research.gov request to transfer the research or effort. • Requiring periodic training for Principal Investigators or other personnel permitted to issue subaward agreements under NSF awards.