Direct Caltech to strengthen its internal control processes and procedures surrounding the transfer of significant portions of NSF-funded research to other organizations. Updated processes could include: a. Establishing procedures to verify whether the scope of work for a proposed subcontract on an NSF award is programmatic in nature before issuing the subcontract. If the scope of work is programmatic in nature, Caltech should obtain the NSF Grants Officer’s approval before issuing the subcontract. Caltech could obtain this approval either as part of the initial NSF grant proposal/budget or through a formal request to transfer the research or effort, submitted through NSF’s FastLane system. b. Requiring periodic training for Caltech personnel that are permitted to subaward, issue, or subcontract out research under NSF awards, to ensure that they request the appropriate approvals. c. Establishing procedures to confirm that Caltech personnel perform pass-through entity risk assessments to identify the appropriate monitoring procedures when Caltech awards NSF research to a pass-through entity. d. Establishing periodic monitoring procedures to ensure that Caltech appropriately assesses indirect costs on the first $25,000 invoiced by each subawardee.