Direct MSU to strengthen its policies and procedures surrounding the establishment of consulting agreements. Specifically, MSU should implement additional policies and procedures designed to ensure that it: • Does not charge NSF awards for costs incurred to obtain intra-Institute of Higher Education consulting services in those cases where MSU does not receive approval for such agreements and/or does not intend to use the funds to directly pay the MSU employees providing the services. • Formally documents and approves consulting agreements before employees or external consultants execute effort to support an NSF-sponsored project.