NSF places high priority on its stewardship responsibilities and is cognizant of the responsibilities imposed through its receipt of $3 billion in ARRA funding. The Foundation plans to fully use and, in places, enhance its comprehensive set of policies and procedures that currently guide program staff through business, financial, and award administration from pre-award through close-out. At the pre-award stage, NSF’s world-standard merit review system selects the highest-quality scientific research and education proposals for funding. Its comprehensive set of fully documented policies and procedures guide NSF staff and awardees alike through the business, financial, and award requirements that govern pre-award through close-out. Warranted contract and grant specialists make awards to institutions with the business capacity requisite to manage federal resources and specifically exclude those institutions debarred from receipt of funds by Federal government agencies. The Award and Administration Guide (AAG) (Part II of the NSF Proposal & Award Policies & Procedures Guide) http://www.nsf.gov/publications/pub_summ.jsp?ods_key=papp sets forth NSF policies for the award and administration of grants and cooperative agreements that ensure compliance with federal regulations. The AAG governs the setting of award terms and conditions, grant administration, financial requirements, grantee standards, cost allowability, and grant administration and misconduct. NSF’s comprehensive Award Monitoring and Business Assistance Program (AMBAP) provides advanced post award oversight for the universe of NSF’s high risk awards through a combination of desk reviews, site visits, and Federal Financial Report (FFR) transactional testing. Desk reviews and site visits provide oversight of critical policies and procedures that follow well-established protocols; they verify that financial information received provides reasonable assurance that awards are likely to be administered in accordance with NSF’s agreement provisions and other relevant administrative regulations. Transactions for low- and medium-risk awards are subject to verification through statistical sampling to ensure that funding is not used for expressly unallowable costs. NSF will leverage its current, comprehensive programs to ensure rigorous monitoring for Recovery Act funds. ARRA awards will carry additional weight in the annual risk assessment, ensuring that their coverage will be significant. Through this combined set of activities, on-site visits, desk review, and/or transactional testing, NSF will ensure that the entire high risk award universe receives post award review. We believe that the extraordinary measures NSF has taken to conceive and implement AMBAP are having a positive impact on awardee institutions and are mitigating the risk of potential misuse of funds. In designing this program, we have been very careful to complement, rather than supplant, the auditing responsibilities of the Office of the Inspector General (OIG). Should we, in the course of the Foundation’s post-award oversight activities, find issues that rise to the level of audit or investigative scrutiny, we will refer them to NSF OIG.