25-01-005 - Recommendation 1.4

Direct Northeastern to strengthen its internal controls and processes for obtaining NSF approval for subawards. This could include:
• Requiring Sponsored Projects Administration to verify whether the entity explicitly identified all subawards within the approved award budget or obtained written approval from the NSF Grants Officer before establishing the subaward.
• Requiring periodic training for Principal Investigators and other personnel responsible for identifying subaward agreements under NSF awards.