Direct UPenn to strengthen the administrative and management procedures over allocating travel expenses to sponsored awards. Procedures could include: a. reviewing all foreign airfare purchases for compliance with the Fly America Act before charging the expenses to federally sponsored awards; b. performing periodic reviews of transactions involving airfare to ensure that PIs do not inappropriately charge sponsored awards for business-class or premium economy fares; and, c. reviewing reimbursement requests to ensure that UPenn can support the business purpose for all travel days for which UPenn reimbursed expenses.