Direct UCM to strengthen its administrative and management procedures and internal controls for reviewing whether expenses are eligible for inclusion in the Modified Total Direct Cost base. Updated processes could include the following: • Requiring that personnel manually review purchases below UCM’s capitalization threshold to ensure UCM has appropriately expensed the purchases and included them in the Modified Total Direct Cost base. • Conducting annual training regarding the treatment of licenses under the equipment threshold, including how to determine when to treat costs as equipment.