Direct NCCU to strengthen its monitoring procedures and internal control processes for applying indirect costs to federal awards. Updated procedures should ensure that NCCU only applies indirect costs to expenses that are allowable in its Modified Total Direct Cost base per federal and NCCU policies. These procedures could include: • Performing an annual review of costs incurred to benefit NSF award participants to ensure the participant support costs were charged to an account excluded from NCCU’s Modified Total Direct Cost base. • Verifying subaward costs in excess of $25,000 were charged to accounts that are excluded from NCCU’s Modified Total Direct Cost base. • Performing periodic reviews of expenses in excess of $5,000 that were charged to materials/supplies accounts to ensure any costs that should have been considered equipment are appropriately transferred to an equipment account that is excluded from NCCU’s Modified Total Direct Cost base. • Updating its indirect cost rate policies to note that costs to rent equipment are not allowable in NCCU’s Modified Total Direct Cost base, which is consistent with federal regulations.