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State Education Department
Behavior Analysts of New York, LLC
Compliance With the Reimbursable Cost Manual

Issued: January 31, 2020
Link to full audit report 2019-S-35

To determine whether reported costs submitted by Behavior Analysts of New York, LLC (BANY) on its Consolidated Fiscal Report (CFR) were allowable, properly calculated, and adequately documented in accordance with applicable State Education Department (SED) requirements. The audit covered costs reported on BANY’s CFR for the reporting year ended June 30, 2015.

About the Program
BANY is an SED-approved, for-profit provider of preschool special education services to children with disabilities who are between three and five years of age. BANY is reimbursed for these services through rates set by SED, which are based on financial information, including costs, that BANY reports to SED on its annual CFR. To be eligible for reimbursement, reported costs must comply with SED’s Reimbursable Cost Manual (RCM) requirements. For the reporting year ended June 30, 2015, BANY reported $245,613 in reimbursable costs for its Special Education Itinerant Teacher Program (Program), and provided these services to 18 children from 12 school districts in Westchester County.

Key Findings
For the reporting period ended June 30, 2015, we identified $2,082 in reported costs that did not comply with SED requirements and are therefore not eligible for reimbursement. The $2,082 included $1,134 in personal service costs that either exceeded documented costs or that BANY could not provide supporting documentation for, and $948 in other than personal service costs, such as vehicle insurance, that either did not relate to the Program they were reported under or did not meet one or more SED requirements related to documentation.  

Key Recommendations

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


  • Ensure that all costs reported on annual CFRs fully comply with SED requirements, and communicate with SED to obtain clarification as needed.
  • Take steps to improve record keeping and documentation to support related costs reported on annual CFRs.

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