EIN: 131624158
UEI: LHGDNJMZ64Y1
Audited by: KPMG LLP
Cognizant agency: 93 [Department of Health and Human Services]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 26, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 26, 2026 (14 days from today).
What is a management decision? →FAC accepted this audit on March 7, 2025 — management decision was due September 7, 2025.
2024-001 Activities Allowed or Unallowed and Allowable Costs / Cost Principles Research and Development Cluster: National Institutes of Health: Institutional Career Development Costs (ALN 93.350, grant number 5 UL1 TR001866) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance Criteria: Non-federal entities should ensure that costs are reasonable and necessary for the performance of the Research and Development effort identified in the applicable award. In accordance with the documentation standards of 2 CFR section s200.430(i), costs of compensation for personal services are allowable to the extent total compensation for individual employees: a. Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; b. Follows an appointment made in accordance with a non-federal entity’s rules or written policies and meets the requirements of federal statute, where applicable; and c. Is determined and supported as provided in 2 CFR section 200.430(i), including the charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: In April 2024, University management became aware that a full-time employee of the University was concurrently employed by Duke-NUS Medical School in Singapore since early 2021. The employee had not previously disclosed to the University his affiliation with, and income from, Duke-NUS Medical School, including on his financial conflict of interest in research disclosure forms that the University requires all researchers to complete and in various documents and certifications in connection with several National Institutes of Health (NIH) grants, which supported a portion of his salary. The University retained external legal counsel to conduct an investigation. After this investigation by external counsel, several actions were taken. First, the University stopped drawing NIH grant funds to support this employee’s salary. The employee’s employment ended. The University conducted a financial conflict of interest in research review as to the employee’s previously undisclosed significant financial interests for the period 2021 to 2024, and other payments from Duke-NUS Medical School, dating back to 2019 and found no evidence that the design, conduct, or reporting of the employee’s NIH-funded work at the University had been adversely affected. Lastly, the University informed NIH of the matter and offered to repay half of the employee’s salary, fringe benefits, and indirect cost recovery charges that had been charged to NIH grants during the time period from January 2021 through May 2024. The proposed repayment amounts to $299,805. The amount charged to NIH grants during fiscal year 2024 was $178,084. Cause: The employee failed to disclose to the University that he was concurrently employed by Duke-NUS Medical School including on his financial conflict of interest in research forms that he was required to complete and in documents and certifications in connection with various NIH grants that supported his salary. Effect: Because the University assumed when calculating the employee’s salary that he was a full-time employee of the University and drew from NIH grants on that basis, but in reality, he was also working at Duke-NUS Medical School, some of the employee’s salary, related fringe benefits and indirect cost charges likely were unallowable under federal grant principles. Questioned Costs: The likely questioned costs are $178,084. Known questioned costs are indeterminable. Recommendation: The University should continue to communicate to University investigators the importance of accurately completing the financial conflicts of interest in research disclosure forms pursuant to applicable, long-standing University policies. Views of Responsible Officials: The University recognizes the seriousness of this matter, involving a former employee who accepted employment and worked at Duke-NUS Medical School in Singapore, without disclosing to the University this concurrent position. Under the University’s Code of Conduct, all members of the University community should conduct themselves ethically, honestly, and with integrity in all dealings and should act with due recognition of their position of trust with respect to the University’s research sponsors. Upon discovering that the employee had a concurrent employment at Duke-NUS, the University acted responsibly in investigating the matter and taking appropriate action, including notifying NIH, offering repayment, and fully cooperating with NIH. No internal controls or protocols were compromised as a result of this matter.
Show full finding ▾Hide full finding ▴2024-001 Activities Allowed or Unallowed and Allowable Costs / Cost Principles Research and Development Cluster: National Institutes of Health: Institutional Career Development Costs (ALN 93.350, grant number 5 UL1 TR001866) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance Criteria: Non-federal entities should ensure that costs are reasonable and necessary for the performance of the Research and Development effort identified in the applicable award. In accordance with the documentation standards of 2 CFR section s200.430(i), costs of compensation for personal services are allowable to the extent total compensation for individual employees: a. Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; b. Follows an appointment made in accordance with a non-federal entity’s rules or written policies and meets the requirements of federal statute, where applicable; and c. Is determined and supported as provided in 2 CFR section 200.430(i), including the charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: In April 2024, University management became aware that a full-time employee of the University was concurrently employed by Duke-NUS Medical School in Singapore since early 2021. The employee had not previously disclosed to the University his affiliation with, and income from, Duke-NUS Medical School, including on his financial conflict of interest in research disclosure forms that the University requires all researchers to complete and in various documents and certifications in connection with several National Institutes of Health (NIH) grants, which supported a portion of his salary. The University retained external legal counsel to conduct an investigation. After this investigation by external counsel, several actions were taken. First, the University stopped drawing NIH grant funds to support this employee’s salary. The employee’s employment ended. The University conducted a financial conflict of interest in research review as to the employee’s previously undisclosed significant financial interests for the period 2021 to 2024, and other payments from Duke-NUS Medical School, dating back to 2019 and found no evidence that the design, conduct, or reporting of the employee’s NIH-funded work at the University had been adversely affected. Lastly, the University informed NIH of the matter and offered to repay half of the employee’s salary, fringe benefits, and indirect cost recovery charges that had been charged to NIH grants during the time period from January 2021 through May 2024. The proposed repayment amounts to $299,805. The amount charged to NIH grants during fiscal year 2024 was $178,084. Cause: The employee failed to disclose to the University that he was concurrently employed by Duke-NUS Medical School including on his financial conflict of interest in research forms that he was required to complete and in documents and certifications in connection with various NIH grants that supported his salary. Effect: Because the University assumed when calculating the employee’s salary that he was a full-time employee of the University and drew from NIH grants on that basis, but in reality, he was also working at Duke-NUS Medical School, some of the employee’s salary, related fringe benefits and indirect cost charges likely were unallowable under federal grant principles. Questioned Costs: The likely questioned costs are $178,084. Known questioned costs are indeterminable. Recommendation: The University should continue to communicate to University investigators the importance of accurately completing the financial conflicts of interest in research disclosure forms pursuant to applicable, long-standing University policies. Views of Responsible Officials: The University recognizes the seriousness of this matter, involving a former employee who accepted employment and worked at Duke-NUS Medical School in Singapore, without disclosing to the University this concurrent position. Under the University’s Code of Conduct, all members of the University community should conduct themselves ethically, honestly, and with integrity in all dealings and should act with due recognition of their position of trust with respect to the University’s research sponsors. Upon discovering that the employee had a concurrent employment at Duke-NUS, the University acted responsibly in investigating the matter and taking appropriate action, including notifying NIH, offering repayment, and fully cooperating with NIH. No internal controls or protocols were compromised as a result of this matter.
2024-001 Allowable Costs Research and Development Cluster: National Institutes of Health: Institutional Career Development Costs (ALN 93.350, grant number 5 UL1 TR001866) Corrective Action Plan: In April 2024, University management became aware that a full-time employee of the University was concurrently employed at Duke-NUS Medical School in Singapore since early 2021. This former employee did not disclose his affiliation at Duke-NUS Medical School on his conflicts of interest forms that the University requires all researchers to complete annually. This former employee’s salary was covered by several National Institutes of Health (NIH) grants. An investigation was conducted by external legal counsel, during and after which the University took several actions. First, the employee’s employment ended. Second, the University stopped drawing the NIH grant funds for this employee’s salary soon after becoming aware of the situation. Third, the University conducted a financial conflict of interest review for the period 2019 through 2024 to determine if any conflicts beyond his employment at Duke-NUS Medical School existed. No further conflicts were identified. Fourth, the University informed NIH of the matter and recommended that the University repay half of the amount of this employee’s salary, fringe benefits and indirect cost recovery charges during the time period from January 2021 through May 21, 2024, which amounts to $299,805. After discovering the issue, we promptly initiated an investigation. Our findings confirmed that this employee was employed by our institution, and our institution including his supervisor was unaware that he was concurrently employed at Duke-NUS Medical School. As a result of these findings, we have taken decisive steps, as follows: 1. End of Employment: The employee’s employment was ended. 2. Investigation and Reporting: We investigated the matter and reported the findings to and have cooperated with NIH. 3. Enhanced Oversight: In response to this incident, we are enhancing our hiring practices and conducting more thorough background checks, especially for positions working on government grant awards. 4. Training and Education: We are implementing mandatory training sessions for all staff on ethical practices, compliance with Uniform Guidance, and the importance of reporting any suspicious activities. 5. Compliance Review: We are conducting a comprehensive review of our compliance with Uniform Guidance to identify any areas for improvement and ensure that our policies are robust and effectively communicated to all employees. 6. Conflict of Interest Disclosure Training and Education: At least annually and at the time of the just in time period (and if there is no just in time period, at the time of award), the University will continue to require University investigators through its certification and recertification process, to attest to the accuracy of their financial conflicts of interest in research disclosure forms pursuant to applicable, long-standing University policies. Contact Person: As to: #1, 3, 4, 5 above: Michael P. Vitale, CPA – Controller Email: vitalem@rockefeller.edu Phone: 212-327-8704 As to: #2 and 6 above: Deborah Y. Yeoh Email: yeohd@rockefeller.edu Phone: 212-327-8071 Anticipated Completion Date: June 30, 2025
2024-002 Subrecipient Monitoring Research and Development Cluster: National Institutes of Health: Allergy and Infectious Diseases Research (ALN 93.855) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: A pass-through entity is required to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the subrecipient’s prior experience with similar subawards, whether the subrecipient has new personnel or new or substantially changed systems and the extent and results of federal awarding agency monitoring. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a federal program. Condition and context: Prior to executing a subaward, the University performs a risk assessment over the potential subrecipient to evaluate the risk of noncompliance with federal statues, regulations, and the terms and conditions of the subaward by the subrecipient. This risk assessment includes the review of a commitment form. The commitment form is prepared by the subrecipient and reviewed by the Principal Investigator and includes an evaluation of the results of previous audits, whether the subrecipient has new personnel or new or substantially changed systems and the extent and results of federal awarding agency monitoring. We selected seven subrecipients out of a population of 50 subrecipients for test work who had subaward agreements with the University during the fiscal year 2024 and noted for two subrecipients, the commitment form was not received and reviewed prior to the University entering into the subawardee agreement. Cause: The Principal Investigators did not obtain the commitment forms from two subrecipients and therefore, could not provide evidence that a risk assessment was performed prior to the University entering into the subaward. Effect: The University could provide a subaward to a subrecipient that is considered to have a higher risk of noncompliance and require additional monitoring, and not perform that additional monitoring. Questioned Costs: None. Recommendation: The University should strengthen its policies and procedures over its subrecipient monitoring process over the Research and Development Cluster programs and provide training to the staff responsible for this federal requirement to ensure all necessary documentation is received and reviewed in accordance with the University's policies and procedures. Views of Responsible Officials: As of March 2021, Rockefeller University’s Office of Sponsored Programs Administration (OSPA) requires collection of the subrecipient commitment form for all applications including outgoing subawards, regardless of FDP Clearinghouse or membership status. All OSPA staff have been trained on this requirement, and we continue to emphasize this requirement in our team meetings. In addition, the requirements were sent to the university community in March 2021 and posted on the OSPA website. If a university applicant resists this requirement, all OSPA staff are required to forward that information to the Director, who communicates the requirement to the applicant. OSPA will be re-educating the laboratories on this requirement in the coming weeks via email and will repeat on a semi-annual basis.
Show full finding ▾Hide full finding ▴2024-002 Subrecipient Monitoring Research and Development Cluster: National Institutes of Health: Allergy and Infectious Diseases Research (ALN 93.855) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: A pass-through entity is required to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the subrecipient’s prior experience with similar subawards, whether the subrecipient has new personnel or new or substantially changed systems and the extent and results of federal awarding agency monitoring. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a federal program. Condition and context: Prior to executing a subaward, the University performs a risk assessment over the potential subrecipient to evaluate the risk of noncompliance with federal statues, regulations, and the terms and conditions of the subaward by the subrecipient. This risk assessment includes the review of a commitment form. The commitment form is prepared by the subrecipient and reviewed by the Principal Investigator and includes an evaluation of the results of previous audits, whether the subrecipient has new personnel or new or substantially changed systems and the extent and results of federal awarding agency monitoring. We selected seven subrecipients out of a population of 50 subrecipients for test work who had subaward agreements with the University during the fiscal year 2024 and noted for two subrecipients, the commitment form was not received and reviewed prior to the University entering into the subawardee agreement. Cause: The Principal Investigators did not obtain the commitment forms from two subrecipients and therefore, could not provide evidence that a risk assessment was performed prior to the University entering into the subaward. Effect: The University could provide a subaward to a subrecipient that is considered to have a higher risk of noncompliance and require additional monitoring, and not perform that additional monitoring. Questioned Costs: None. Recommendation: The University should strengthen its policies and procedures over its subrecipient monitoring process over the Research and Development Cluster programs and provide training to the staff responsible for this federal requirement to ensure all necessary documentation is received and reviewed in accordance with the University's policies and procedures. Views of Responsible Officials: As of March 2021, Rockefeller University’s Office of Sponsored Programs Administration (OSPA) requires collection of the subrecipient commitment form for all applications including outgoing subawards, regardless of FDP Clearinghouse or membership status. All OSPA staff have been trained on this requirement, and we continue to emphasize this requirement in our team meetings. In addition, the requirements were sent to the university community in March 2021 and posted on the OSPA website. If a university applicant resists this requirement, all OSPA staff are required to forward that information to the Director, who communicates the requirement to the applicant. OSPA will be re-educating the laboratories on this requirement in the coming weeks via email and will repeat on a semi-annual basis.
2024-002 Subrecipient Monitoring Research and Development Cluster: National Institutes of Health: Allergy and Infectious Diseases Research (ALN 93.855) Corrective Action Plan: All Office of Sponsored Programs Administration (OSPA) staff have been trained on the requirement to perform a risk assessment on subrecipients, and we continue to emphasize this requirement in our team meetings. In addition, the requirements were sent to the university community in March 2021 and posted on the OSPA website. OSPA will be re-educating the laboratories on this requirement in the coming weeks via email and will repeat on a semi-annual basis. Contact Person: Collette Ryder, Director of Sponsored Programs Administration Email: cryder@rockefeller.edu Phone: 212-327-8054 Anticipated Completion Date: June 30, 2025
FAC accepted this audit on December 21, 2023 — management decision was due June 21, 2024.
FAC accepted this audit on February 6, 2023 — management decision was due August 6, 2023.
FAC accepted this audit on January 13, 2022 — management decision was due July 13, 2022.
FAC accepted this audit on December 19, 2020 — management decision was due June 19, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FAC accepted this audit on January 14, 2019 — management decision was due July 14, 2019.
FAC accepted this audit on March 15, 2018 — management decision was due September 15, 2018.
FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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