Direct MSU to strengthen its policies, procedures, and internal control processes for applying its federally negotiated indirect cost rate to NSF awards. Updated procedures could include: • Requiring that personnel manually review expenses invoiced by MSU’s Facilities Management Team to ensure that MSU appropriately capitalizes any rearrangement/alteration and fabricated equipment expenses. • Developing additional procedures that require personnel responsible for approving cost transfers to verify that MSU will appropriately apply indirect costs before the personnel approve the cost transfer requests. • Implementing an annual review process for costs charged to awards that include funding for participant support costs to ensure MSU is appropriately segregating participant support costs in accounts that it has excluded from its Modified Total Direct Cost base. • Conducting training for individuals responsible for charging indirect costs to sponsored accounts that incur indirect costs. We suggest that MSU conduct the training at least annually.