Direct UPenn to strengthen the administrative and management controls and processes over obtaining and maintaining sufficient supporting documentation. Processes could include: a. requiring subawardees to submit itemized receipts, as requested, to support how they expended funds received from UPenn; and, b. providing periodic training to all employees who incur or process expenses that may be charged to Federal awards, to provide the employees with guidance on how to provide, obtain, and maintain sufficient supporting documentation.