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Direct UM to provide documentation supporting that it has repaid or otherwise credited the $11,499 of questioned participant support costs for which it has agreed to reimburse NSF.

Direct UM to establish clear guidance regarding the rebudgeting of participant support cost funding. This guidance should address when and how to request approval to rebudget participant support cost funding, as well as how to document the approval.

Direct UM to update its current award set-up practices to require that, when setting up accounts established for NSF awards and/or funding supplements, personnel ensure that the accounts apply indirect costs using the rate(s) that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF award, rather than using the rate(s) included in the original Notice of Award.