Direct EDC 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 costs claimed by consultants. Updated procedures could include: • Requiring consultant agreements to specifically note whether the consultant is permitted to invoice EDC for travel costs incurred as a result of performing the requested consulting services. • Requiring invoice approvers to review consulting agreements to determine the allowability of travel expense reimbursement submitted by consultants prior to approving consultant travel expenses.