Direct NCCU to strengthen its policies and procedures and internal controls for allocating expenses, and for supporting the allocation of expenses, charged to sponsored projects. Updated processes could include: • Requiring Principal Investigators to review and certify the allowability and allocability of all payments made to or on behalf of NSF award participants. • Documenting how airfare and other travel expenses benefit a sponsored award prior to allocating reimbursed travel costs to NSF awards. • Requiring departmental personnel or other designated invoice approvers to confirm that invoiced consultant services align to the objectives of the award(s) the consultant costs are being charged to prior to charging consultant costs to NSF awards. • Updating NSF award close-out procedures to require a review of all material and supply purchases made within the final 90 days of a grant award’s period of performance and requiring that all costs associated with materials received after an NSF award’s expiration date be removed from the NSF award.