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NYS Comptroller


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State Education Department
Upstate Cerebral Palsy
Compliance With the Reimbursable Cost Manual

Issued: November 05, 2015
Link to full audit report 2014-S-71
Link to 90-day response

To determine whether the costs reported by Upstate Cerebral Palsy (UCP) on its Consolidated Fiscal Reports (CFRs) were properly calculated, adequately documented, and allowable under the State Education Department’s (SED) guidelines, including the Reimbursable Cost Manual (Manual). Our audit covered the year ended December 31, 2012.

UCP is an SED-approved not-for-profit special education provider located in Utica, New York. UCP provides preschool special education services to children with disabilities between the ages of three and five years. UCP is reimbursed for preschool special education program services through rates set by SED. These reimbursement rates are based on financial information, including costs, that UCP reports to SED on its annual CFR. To be eligible for reimbursement, reported costs must comply with Manual requirements. For the calendar year ended December 31, 2012, UCP reported about $7.9 million in reimbursable costs on its CFR for three preschool special education programs.

Key Findings

UCP claimed $97,781 in non-allowable costs for the year covered by our audit. These costs included:

  • $83,905 in personal service costs consisting of ineligible bonuses, executive compensation above the regional median allowable salary, and non-program-related costs; and
  • $13,876 in non-personal service costs that were either non-program related, not allowable, or unsupported by proper documentation.

Key Recommendations


  • Review the disallowances identified by our audit and, if warranted, make the necessary adjustments to UCP’s reimbursement rates.
  • Remind UCP officials of the pertinent SED guidelines that relate to the deficiencies we identified.


  • Ensure that costs reported on annual CFRs fully comply with SED’s requirements, and communicate with SED to obtain clarification as needed.

Other Related Audits/Reports of Interest

Dynamic Center Inc.: Compliance With the Reimbursable Cost Manual (2014-S-3)
La Salle School: Compliance With the Reimbursable Cost Manual (2012-S-68)

State Government Accountability Contact Information:
Audit Director: Andrea Inman
Phone: (518) 474-3271; Email:
Address: Office of the State Comptroller; Division of State Government Accountability; 110 State Street, 11th Floor; Albany, NY 12236