Objective

To determine whether the costs reported by Quality Services for the Autism Community (QSAC) on its Consolidated Fiscal Report (CFR) were reasonable, necessary, directly related to the special education program, and sufficiently documented pursuant to the State Education Department’s (SED) Reimbursable Cost Manual (RCM). The audit included expenses claimed on QSAC’s CFR for the fiscal year ended June 30, 2015.

About the Program

QSAC is a New York City- and Long Island-based non-profit organization that supports children and adults with autism. QSAC’s administrative office for all programs is located in Manhattan. QSAC was established in 1978 and is approved by SED to provide Preschool Special Education (SC) and Special Education Itinerant Teacher (SEIT) program services to children with autism between three and five years of age. Both the SC and SEIT programs are located in Douglaston, Queens. For the fiscal year ended June 30, 2015, QSAC served 164 students, which consisted of 140 in SC and 32 in SEIT, with 8 children enrolled in both Programs. QSAC has 13 SC classrooms attended by children from various school districts in New York City’s five boroughs and Long Island.

For the fiscal year ended June 30, 2015, QSAC received $3.7 million in State funding for the cost-based SC and SEIT programs. The cost for the Office for People With Developmental Disabilities was $49 million, or 85 percent of QSAC’s total cost of $57.6 million. The remaining $4.9 million is the cost of other fee-based programs such as Special Education Teacher Support Services and Early Intervention. SED has issued the RCM to provide guidance on the eligibility of costs and documentation requirements.

Key Findings

For the fiscal year ended June 30, 2015, we identified $128,294 in reported costs that did not comply with the RCM’s requirements for reimbursement. The ineligible costs included $111,791 in personal service costs for 107 direct care employees and 34 administration employees, and $16,503 in other than personal service (OTPS) costs (see Exhibit at the end of the report).

Personal Services

• We disallowed a total of $58,183, consisting of $52,016 for 15 employees because documentation to support their administrative functions was lacking, $4,419 for 4 employees because hours were not documented by attendance records, and $1,748 for 20 employees who are not qualified to work above 1.0 full-time equivalent (FTE) per RCM rules.
• We reviewed hours of employees who worked for the SC and the SEIT programs as well as other non-SED programs to determine the accuracy of the allocation of their salaries to the two SED programs. Based on our review of relevant time studies and documentation for the allocation of time for employees who worked on programs other than SC and SEIT, we disallowed a total of $41,180, which consisted of $15,230 for a Program Director, $10,603 for the time of the Director of Clinical Services, $5,054 for direct hours not documented, $3,232 for a direct maintenance employee, $2,640 for a social worker, $1,911 for non-documented hours, $1,302 for maintenance workers, $1,026 for the Director of Training, and $182 for an unsubstantiated increase in an employee’s salary.
• We disallowed a total of $12,428 in non-mandated fringe benefits because the benefits were not proportionately similar or available to all QSAC employees in compliance with RCM rules.

Other Than Personal Services

We disallowed a total of $16,503 in OTPS costs consisting of:

• $11,607 in rent, which consisted of $8,582 in direct rent and $3,025 in administration rent because QSAC did not claim the actual rent only; instead, it claimed actual rent and added deferred rent.
• $2,699, which consisted of $2,075 for depreciation charged to SC and $624 for administration depreciation expenses. QSAC did not provide sufficient documentation, such as invoices, bank statements, or canceled checks issued to vendors to support the cost and payment of the disallowed expenses.
• $510 in advertising expenses and $781 in direct expenses, for a total of $1,291, due to insufficient documentation and incorrect allocation to the two SED programs.
• We reviewed 64 expenses totaling $29,481 in administration dues and subscriptions and identified expenses totaling $7,677 that were not sufficiently documented to substantiate the expense related to the SED programs. We used the 6.575 percent ratio to allocate these expenses to the SC and SEIT programs and disallowed $505.
• According to the RCM, administration food expenses are not allowed. QSAC charged 70 administrative food transactions totaling $6,101. We disallowed $401 that related to the SED programs.

Key Recommendations

To SED:

• Review the recommended disallowances resulting from our audit and make the appropriate adjustments to QSAC’s CFR and reimbursement rates, as warranted.
• Work with QSAC officials to help ensure their compliance with the provisions in the RCM.

To QSAC:

• Ensure that costs reported on future CFRs comply with the requirements in the RCM.