Direct NCCU 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 expenses charged to NSF awards. Updated procedures could include requiring the following: • Departmental personnel to track the purchase and distribution of all gift cards charged to NSF awards through the use of a gift-card log, or other appropriate documentation. • Principal Investigators or other appropriate personnel to justify the amount of all NSF stipend payments that are provided at an amount not consistent with the NSF award budget. • Temporary employees to complete timesheets and/or effort certifications consistent with the requirements for full-time employees.