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State Education Department
Westchester Community Opportunity Program, Inc.
Compliance With the Reimbursable Cost Manual

Issued: December 30, 2016
Link to full audit report 2016-S-33
Link to 90-day response

To determine whether the costs reported by Westchester Community Opportunity Program, Inc. (WestCOP) on its Consolidated Fiscal Report (CFR) were properly calculated, adequately documented, and allowable under the State Education Department’s (SED) guidelines, including the Reimbursable Cost Manual (RCM). The audit covered the year ended June 30, 2013.

WestCOP is an SED-approved, not-for-profit special education provider located in Westchester County, New York. WestCOP provides preschool special education services to children with disabilities who are between three and five years of age. WestCOP is reimbursed for preschool special education services through rates set by SED. The reimbursement rates are based on financial information, including costs, that WestCOP reports to SED on its annual CFR. To be eligible for reimbursement, reported costs must comply with RCM requirements. For the year ended June 30, 2013, WestCOP reported about $2.1 million in reimbursable costs on its CFR for the rate-based preschool special education programs (Programs) it operated.

Key Findings

For the year ended June 30, 2013, we identified $87,017 in ineligible costs that WestCOP reported on its CFR for the Programs. The ineligible costs included:

  • $74,714 in other than personal service costs, which consisted of $44,262 in lease expenses that were not properly allocated, $22,766 in non-Program-related expenses, $5,989 in inadequately documented expenses, $1,348 in non-reimbursable interest expense, and $349 in other ineligible expenses; and
  • $12,303 in personal service costs, which consisted of $10,525 for staff costs in excess of approved staffing ratios, $1,613 in undocumented staff time, and $165 in bonus compensation.

We also determined WestCOP did not disclose related-party transactions with three vendors on its CFR, as required.

Key Recommendations


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

To WestCOP:

  • Ensure that costs reported on annual CFRs fully comply with SED’s requirements, and communicate with SED to obtain clarification as needed.
  • Ensure related-party transactions are properly disclosed on the CFR.

Other Related Audits/Reports of Interest

The Alcott School: Compliance With the Reimbursable Cost Manual (2015-S-97)
Early Education Center, Inc.: Compliance With the Reimbursable Cost Manual (2015-S-96)

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