OFFICE OF THE NEW YORK STATE COMPTROLLER

D IVISION OF LOCAL GOVERNMENT

& SCHOOL ACCOUNTABILITY

School Districts’
Procurement of Special
Education Professional
Services

2010-MS-8

Thomas P. DiNapoli
 Table of Contents

Page

AUTHORITY LETTER 2

EXECUTIVE SUMMARY 3

INTRODUCTION 5
Background 5
Objective 6
Scope and Methodology 6
Comments of District Officials 6

PROCUREMENT OF SPECIAL EDUCATION PROFESSIONAL SERVICES 7

Recommendations 12

APPENDIX A Potential Cost Savings – Onondaga County Districts 13

APPENDIX B Potential Cost Savings – Westchester and Rockland County Districts 14
APPENDIX C Potential Cost Savings – Nassau County Districts 15
APPENDIX D Responses From District Officials 16
APPENDIX E Audit Methodology and Standards 18
APPENDIX F How to Obtain Additional Copies of the Report 19
APPENDIX G Local Regional Office Listing 20

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 1

 State of New York
Office of the State Comptroller

Division of Local Government

and School Accountability

December 2010

Dear School District Officials:

A top priority of the Office of the State Comptroller is to help District officials manage District
resources efficiently and effectively and, by so doing, provide accountability for tax dollars spent
to support District operations. The Comptroller oversees the fiscal affairs of Districts statewide, as
well as compliance with relevant statutes and observance of good business practices. This fiscal
oversight is accomplished, in part, through our audits, which identify opportunities for improving
operations and Board of Education governance. Audits also can identify strategies to reduce
District costs and to strengthen controls intended to safeguard District assets.

Following is a report of our audit titled School Districts’ Procurement of Special Education
Professional Services. This audit was conducted pursuant to Article V, Section 1 of the State
Constitution and the State Comptroller’s authority as set forth in Article 3 of the General Municipal
Law.

This audit’s results and recommendations are resources for District officials to use in effectively
managing operations and in meeting the expectations of their constituents. If you have questions
about this report, please feel free to contact the local regional office for your county, as listed at
the end of this report.

Respectfully submitted,

Office of the State Comptroller

Division of Local Government
and School Accountability

2 OFFICE OF THE NEW YORK STATE COMPTROLLER

 State of New York
Office of the State Comptroller
EXECUTIVE SUMMARY

Education Law requires that each public school child who receives special education and related
services must have an Individualized Education Program (IEP). IEPs include the various related
services1 that a student requires to achieve the goals contained in the IEP. Many special education
services are provided by independent contractors selected by school districts. Such professional
providers deliver a wide range of services, including occupational therapy, physical therapy, auditory
services, nursing services, speech therapy, and vision services. These services are generally paid
for from the district’s general fund.

Scope and Objective

The objective of our audit was to determine whether school districts are procuring special education
professional services for the best value for the period July 1, 2008 through August 31, 2009. Our
audit addressed the following related question:

• Could school districts reduce special education costs by using a request for proposals
process for the procurement of special education professional services?

Audit Results

We found that the nine districts we audited in Nassau, Onondaga, Rockland and Westchester
Counties did not obtain special education professional services at the most economical cost. These
nine districts failed to realize a total of $574,000 in potential cost savings in 2008-09 either because
they used requests for proposals (RFPs), but did not select providers with the lowest proposed
rates, or did not use RFPs at all. Of the $3,777,000 these nine districts paid to 110 special education
professional providers in 2008-09, $3,213,000 (85 percent) was paid to 84 providers who were
not selected through a competitive process, or who did not propose the lowest rates. None of the
districts documented the reasons for their selections. As a result, district taxpayers paid more than
necessary for these professional services, and also lack assurance that the contract awards were
free of favoritism.

Three of the nine districts used RFPs to obtain all their special education professional services,
but they did not select the lowest-cost vendor for 23 contracted services in the 2008-09 fiscal
year. These districts could have saved a total of $388,000 in 2008-09 by selecting the lowest-cost

____________________
1
Related services may include developmental, corrective, and/or other supportive services to assist a student who has
a disability.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 3

vendors. The remaining six districts, which used RFPs inconsistently (one district) or not at all
(five districts), could have achieved potential cost savings of $186,000 in 2008-09 by using an
RFP process to identify and select vendors with the most economical rates. None of the districts
documented the basis for their selection decisions, or explained why they selected other than the
lowest cost vendor.

Comments of District Officials

The results of our audit have been discussed with school district officials and their comments,
which appear in Appendix D, have been considered in preparing this report.

4 OFFICE OF THE NEW YORK STATE COMPTROLLER

 Introduction

Background Education Law requires that each public school child who receives
special education and related services must have an Individualized
Education Program (IEP). Each IEP must be designed for one
student and must be a truly individualized document. The IEP
creates an opportunity for teachers, parents, school administrators,
related services personnel, and students (when appropriate) to
work together to improve educational results for children with
disabilities. IEPs include the various related services2 that a
student requires to achieve the goals contained in the IEP. Some
special education services, such as services for a student who
requires a modified learning environment, would be provided
to the student at a State-approved educational facility. The rates
for such services are negotiated and set by the New York State
Education Department, and the costs of the services are generally
accounted for in the district’s special aid fund.

However, many special education services are provided

by independent contractors selected by the districts. These
professional providers deliver a wide range of services, including
occupational therapy, physical therapy, auditory services, nursing
services, speech therapy, and vision services.

The following chart shows the nine school districts we audited

and their 2008-09 expenditures for contracted special education
services:

____________________
2
Related services may include developmental, corrective, and/or other
supportive services to assist a student who has a disability.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 5

 Expenditures for Number of
Contracted Special Contracted
School District
Education Professional Special Education
Services Professionals
Onondaga County
Skaneateles Central School District $159,000 7
Solvay Union Free School District $107,000 3
West Genesee Central School District $395,000 10
Westchester, Rockland Counties
Ardsley Union Free School District $342,000 12
East Ramapo Central School District $206,000 7
White Plains City School District $470,000 5
Nassau County
Farmingdale Union Free School District $1,308,000 26
Jericho Union Free School District $667,000 31
Oyster Bay-East Norwich Central
School District $123,000 9
Total $3,777,000 110

Objective The objective of our audit was to determine whether school

districts are procuring special education professional services for
the best value. Our audit addressed the following related question:

• Could school districts reduce special education costs by

using a request for proposals process for the procurement
of special education professional services?

Scope and Methodology
We interviewed various district officials and examined policies
and procedures, accounting records, and other relevant
documentation at nine school districts in Nassau, Onondaga,
Rockland and Westchester Counties for the period July 1, 2008
to August 31, 2009.

We conducted our audit in accordance with generally accepted

government auditing standards (GAGAS). More information on
such standards and the methodology used in performing this audit
is included in Appendix E of this report.

Comments of District The results of our audit have been discussed with school district
Officials officials and their comments, which appear in Appendix D, have
been considered in preparing this report.

6 OFFICE OF THE NEW YORK STATE COMPTROLLER

Procurement of Special Education Professional Services

It is essential that school boards and school district officials

manage district operations, including contracting for special
education services, as efficiently and economically as possible.
The appropriate use of a competitive process, such as requests
for proposals (RFPs), can help ensure that districts procure
special education services on the most favorable terms in the
best interests of taxpayers. We found that the nine districts we
audited did not obtain special education professional services at
the most economical cost. As shown in the following table, these
nine districts failed to realize a total of $574,000 in potential cost
savings in 2008-09 because they used RFPs but did not select
providers with the lowest proposed rates, or because they did not
use RFPs at all. Of the $3,777,468 these nine districts paid to 110
special education professional providers in 2008-09, $3,212,788
(85 percent) was paid to 84 providers who were not selected
through a competitive process, or who did not propose the lowest
rates. None of the districts documented the reasons for their
selections. As a result, district taxpayers may have paid more than
necessary for these professional services, and lack assurance that
contract awards were free of favoritism.
Potential Cost
School District
Savings
Nassau County
Farmingdale Union Free School District $208,000
Jericho Union Free School District $154,000
Oyster Bay-East Norwich Central School District $26,000
Onondaga County
Skaneateles Central School District $60,000
Solvay Union Free School District $03
West Genesee Central School District $34,000
Westchester, Rockland Counties
Ardsley Union Free School District $49,000
East Ramapo Central School District $13,000
White Plains City School District $30,000
Total Potential Cost Savings $574,000
____________________
3
We did not calculate a cost savings for Solvay because Solvay paid the lowest
rate for services among the districts audited in Onondaga County. However,
Solvay did not solicit RFPs for services, and therefore may not have obtained
those services at the lowest rates available. For details on rates paid for such
services, refer to Appendix A.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 7

 To calculate these potential cost savings, we compared the lowest
rates available4 for each service to the rates actually paid for the
service. More detailed information about the professional services
we included and the rates we used is in Appendices A, B, and C.

General Municipal Law (GML) does not require competitive

bidding for professional services that involve specialized skill,
training and expertise, use of professional judgment or discretion,
and/or a high degree of creativity. However, GML does require
a district’s board of education to adopt, by resolution, policies
and procedures governing the procurement of goods and services,
such as contracted professional services, that are not subject to
competitive bidding requirements. GML requires district officials
to establish procedures for:

• Determining whether a procurement is subject to

competitive bidding, and requiring documentation to
support a determination that an item is not subject to
competitive bidding

• Obtaining alternative proposals or quotations using

requests for proposals, written or verbal quotations, or any
other method of procurement that ensures competition is
sought

• Determining when each method of procurement will be

used and requiring adequate documentation of actions
taken

• Justifying and documenting awards made to other than the

lowest responsible dollar offer

• Indicating circumstances or types of procurement for

which, at the board’s discretion, the solicitation of
alternative proposals or quotations would not be in the
best interest of the municipality.

The use of a competitive procurement process, such as RFPs,

is intended to help district officials identify the largest pool of

____________________
4
Available rates include rates actually paid by a district in a particular region, or
rates proposed by a provider for a particular district. Where a district requested
proposals for services, we used the lowest proposed rate in comparison to
the actual rate paid by that district to calculate potential cost savings. Where
requests for proposals were not issued, we used the lowest rate paid by service
among districts in the same region as the basis for our calculations.

8 OFFICE OF THE NEW YORK STATE COMPTROLLER

 available service providers from which to choose a vendor. In
addition, using such a process creates an environment in which
providers must vie for recognition and selection by district
officials based on the vendor’s proposed rate, availability, and
qualifications. District officials must document their use of the
process to select one special education provider over another. By
documenting how they followed the process, district officials can
support their selection decisions and can provide assurance that
they procured services at the best value without the influence of
favoritism.

We found that only three of the nine districts used RFPs to obtain
all their special education professional services. These districts
could have saved a total of $388,000 in 2008-09 by contracting
with the lowest cost provider for these services. The remaining
six districts, which used RFPs inconsistently (one district) or not
at all (five districts), could have achieved potential cost savings
of $186,000. None of the districts documented the basis for their
selection decisions, or explained why they selected other than the
lowest cost vendor.

Districts Using a Competitive Process — We found that three of

the nine districts used an RFP process to procure all their special
education professional services. Farmingdale, Jericho, and
Oyster Bay — three districts in Nassau County — were the only
districts that requested proposals for all of their special education
professional services. Farmingdale requested proposals on its
own, and Jericho and Oyster Bay5 participated in a cooperative
RFP process with other local school districts. Each of these
processes included requesting proposals from specific providers
and advertising the RFP in the local newspapers; the result was
a list of vendors from which the districts could select providers
throughout the year. While we commend these three districts
for participating in an RFP process, we determined that they do
not derive the full cost savings benefit the process can provide
because they do not always select the lowest cost vendor. Further,
the districts lacked documentation to justify why they selected
one vendor over another and, specifically, why they selected
23 service providers (see Appendix C) who did not submit the
lowest proposed rate for services. Had these districts selected the

____________________
5
Jericho issued RFPs with Locust Valley and North Shore School Districts;
Oyster Bay-East Norwich participated in a consortium that included six other
school districts: Carle Place, Manhasset, East Williston, Herricks, Great Neck
and Glen Cove School Districts.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 9

 lowest cost provider in each case, we estimate that they could
have achieved potential cost savings totaling $388,000 in 2008-
09.

Districts Not Using a Competitive Process — The remaining

six districts were not using a competitive procurement process
to obtain all their special education professional services; White
Plains used RFPs inconsistently, and Ardsley, East Ramapo,
Solvay, Skaneateles and West Genesee did not use RFPs at all.

White Plains used RFPs for two of its five outsourced special
education professional services. However, while the District’s
RFP process obtained proposed rates for occupational therapy
that were lower than the rates paid by two nearby districts, White
Plains officials did not always contract with the lowest cost
provider. District officials could not provide documentation to
support their decision to use providers who proposed a higher
rate. If White Plains had selected the lowest cost provider for
all its occupational therapy services during 2008-09, the District
may have saved $30,000 (see Appendix B).

Officials at these six districts gave a variety of reasons why they

do not consistently use RFPs or another competitive process to
procure these services. For example, district officials told us that:

• They see no need to seek proposals for services if the

district and the students/parents receiving the services are
satisfied with the existing provider.

• Parents and/or the district prefer to have the same vendor

provide services to the students year after year.

• Using RFPs would make it difficult to obtain appropriate

services within the short timeframe provided for by
regulations,6 which require that districts start providing
IEP-related services within 30 days of a student’s
qualifying to receive special education.

• The district’s policy precluded these services from

competitive pricing due to confidentiality.

However, the fact that other school districts, dealing with the
same constraints as the schools included in this audit, were able to
consistently use a competitive process to obtain special education
____________________
6
Regulations of the Commissioner of Education

10 OFFICE OF THE NEW YORK STATE COMPTROLLER

 services is a clear indicator that the concerns raised are not valid.
For example, while it might be difficult to seek proposals for
unique or unusual services within the timeframe provided for in
regulations, districts can request proposals for frequently needed
services (e.g., speech, physical therapy) annually so that providers
for those services are available when needed. Also, using a
competitive process does not jeopardize the confidentiality of
students’ records; the three districts that did request proposals for
services did not need to disclose confidential information to do
so. Finally, district officials should document the basis for their
decisions in procuring special education professional services.
If districts fail to seek competitive proposals for these services,
they should provide the details of their reasons for not using
competitive processes that consistently result in cost savings for
taxpayers.

We compared the rates paid for special education professional

services that were outsourced by more than one district in the
region where these districts were located and found that district
officials may have been able to obtain services at lower rates if
they had advertised and requested proposals. For example, among
the districts that we audited in Onondaga County, the rates paid
for both occupational therapy and physical therapy in 2008-09
ranged from $52 to $95 per hour. Skaneateles paid the top rate
($95) for both services, while West Genesee paid $57. Had these
districts used RFPs and selected vendors with proposed rates
of $52 for these services, they could have saved $59,000 and
$32,000, respectively, during 2008-09.

Similarly, we compared rates paid for a number of services

outsourced by more than one district in the Westchester County
region where Ardsley and East Ramapo are located. We found
that Ardsley paid rates for occupation therapy services that
ranged from $85 to $100 per hour in 2008-09. Had Ardsley
officials requested proposals for these services, and selected the
provider with the lowest proposed rate of $70 per hour, they may
have saved $23,000 in 2008-09. Overall, we estimate that these
six districts may have saved $186,000 if they used a competitive
process for procuring special education professional services. In
fact, the savings for these districts could be even greater since our
estimates are based on actual rates paid7 without a competitive
process.
____________________
7
The potential cost savings figure calculated for occupational therapy at White
Plains is based on the lowest RFP rate; all others are based on actual rates paid
without a competitive process.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 11

 Seeking competitive rates from professional service providers
is intended to provide assurance that such services are obtained
as efficiently and economically as possible, and in a manner
that guards against favoritism, fraud and corruption. District
officials should use all means available to identify capable
professional service providers. However, when districts use a
competitive process to select special education contractors, but
do not select the lowest-cost providers, they may be paying
more than necessary for these services. Further, unless districts
maintain documentation to support their selection decisions,
especially when they do no select the lowest cost provider, there
is no evidence that such selections were made in a prudent and
economical manner, in the best interests of the taxpayers, and
without favoritism.

Recommendations 1. District officials should request proposals for all special

education professional services.

2. District boards of education should develop policies and

procedures that adequately address the procurement of
special education professional services. Once implemented,
boards should ensure compliance with the policies, including
requiring documentation of actions taken.

12 OFFICE OF THE NEW YORK STATE COMPTROLLER

 APPENDIX A

POTENTIAL COST SAVINGS — ONONDAGA COUNTY DISTRICTS

2008 — 2009

Lowest Actual Potential

District Service8 Hourly Rates Cost
9
Rate Paid Savings
Skaneateles Audiology Services $80 $80 -
Skaneateles Occupational Therapist $52 $95 $42,000
Skaneateles Physical Therapist $52 $95 $17,000
10
Skaneateles Speech $57 $95 $1,000
Potential Cost Savings $60,000
Solvay Audiology Services $80 $125 -11
Solvay Occupational Therapist $52 $52 -
Solvay Physical Therapist $52 $52 -
Potential Cost Savings -
West Genesee Occupational Therapist $52 $57 $21,000
West Genesee Physical Therapist $52 $57 $11,000
12
West Genesee Speech $57 $57-$114 $2,000
Potential Cost Savings $34,000
Total Potential Cost Savings $94,000

____________________
8
The table includes only services for which comparable data was available among the districts in this region. If a
particular service was not outsourced by more than one of the districts, therefore eliminating the ability to compare
rates paid, we did not include that service in the table.
9
Lowest hourly rate is the lowest rate paid for a particular service among the three districts in the region.
10
West Genesee did not outsource speech services 2009-10. In 2008-09, West Genesee had the lowest hourly rate for
speech services.
11
Solvay paid $750 to one audiology service provider during the 2008-09 school year. Although they paid more than
the lowest rate attained in the region, the table is rounded to the nearest thousand and therefore indicates zero cost
savings for this service.
12
For 2008-09, West Genesee outsourced speech service, and did not do so in 2009-10. In 2008-09, West Genesee
had the lowest hourly rate of $57.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 13

 APPENDIX B

POTENTIAL COST SAVINGS — WESTCHESTER AND ROCKLAND

COUNTY DISTRICTS

2008 — 2009

Actual Potential
13, 14 Lowest
School Service Rates Cost
Hourly Rate
Paid Savings
Ardsley Occupational Therapist – Individual $70 $85-$100 $23,000
Ardsley Occupational Therapist – Group $85 $85-$100 $1,000
Ardsley Physical Therapist $65 $100 $2,000
Ardsley Speech $70 $90-$113 $23,000
Potential Cost Savings $49,000
East Ramapo Physical Therapist $65 $65-$140 $13,000
Potential Cost Savings $13,000
Occupational Therapist – Individual/
White Plains Group $7015 $70-$107 $30,000
White Plains Physical Therapist $7016 $70 -
Potential Cost Savings $30,000
Total Potential Cost Savings $92,000

____________________
13
The table includes only services for which comparable data was available among the districts in this region. If a
particular service was not outsourced by more than one of the districts, therefore eliminating the ability to compare
rates paid, we did not include that service in the table.
14
White Plains provides services for speech to parent placed students, which we eliminated from the analysis; however,
we are using this rate as the lowest for speech services.
15
White Plains issued requests for proposals for this service but did not always use the lowest rate provider.
16
White Plains issued requests for proposals for this service and selected the lowest proposed rate; therefore, no cost
savings was calculated.

14 OFFICE OF THE NEW YORK STATE COMPTROLLER

 APPENDIX C
POTENTIAL COST SAVINGS — NASSAU COUNTY DISTRICTS
2008 — 2009
Lowest
Actual Rates Potential
Service17 Proposed
Paid Cost Savings
Rate18
Farmingdale
Parent Training $80 $80-$100 $6,000
Speech – Individual $78 $80 $1,000
Physical Therapist $78 $80-$100 $9,000
Physical Therapist – Out of District $90 $100-$160 $4,000
Occupational Therapist – Individual $78 $80-$100 $23,000
Occupational Therapist – Group $83 $83-$250 $32,000
ABA Home Services $50 $50-$100 $96,000
Nursing – LPN $45 $53-$54 $19,000
Nursing – RN $45 $59 $18,000
Potential Cost Savings $208,000
Jericho
Occupational Therapist – Individual $60 $75-$150 $67,000
Occupational Therapist – Group $100 $100-$150 $1,000
Physical Therapist – Individual $60 $80-$150 $14,000
Physical Therapist – Group $100 $112-$150 $2,000
Physical Therapist – Home $100 $100-$160 $5,000
Speech – Individual $55 $84-$150 $23,000
ABA – Aide $35 $35-$40 $15,000
Behavior Consultant $60 $60-$75 $15,000
Parent training $65 $80-$110 $6,000
Special Education Teacher – Individual $65 $80 $6,000
Potential Cost Savings $154,000
Oyster Bay-East Norwich
Occupational Therapist $76 $90-$93 $4,000
Physical Therapist $80 $90 $1,000
Speech – Individual $80 $100 $6,000
ABA – Home services $35 $35-$80 $15,000
Potential Cost Savings $26,000
Total Potential Cost Savings $388,000
____________________
17
The table includes only services for which each District did not select the provider that submitted the lowest
proposed rate to that particular District.
18
Represents an hourly rate

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 15

 APPENDIX D

RESPONSES FROM DISTRICT OFFICIALS

We provided a draft copy of this global report to each of the nine districts we audited and
requested responses from district officials. We received responses from all nine districts.

The following comments were excerpted from the responses we received. Comments or concerns
that were specific to findings at a particular district are not included here, but are instead addressed
in the district’s individual report. Each district’s individual report includes the district’s response to
our audit of the district, along with our comments on issues raised in the district’s response letter.

Six of the nine districts indicated that they have already taken steps to implement our
recommendations:

Ardsley: “We have taken steps in Ardsley to comply with your recommendations. To that
end, we now solicit multiple quotes from various providers and we publish the results of
those solicitations in our Board minutes when we make a contract recommendation and award.
Furthermore, we provide a rationale in the same minutes when we do not select the lowest cost
provider.”

East Ramapo: “For the 2010-2011 school year, the District has sent Requests for Proposals
(RFPs) for physical therapy services. As a result of the responses, the District has awarded the
provision of physical therapy services based on the lowest bids.”

Farmingdale: “Although the district has a rigorous process for determining an appropriate
provider for our students, which includes cost factors, the district will document the selection
process to ensure that an appropriate audit trail is created in the future.”

Jericho: “The District has implemented the suggestions of the audit with regard to policy and
procedure."

Oyster Bay-East Norwich: “We agree with the recommendation and have already amended our
purchasing policies. We also agree that maintaining documentation for the vendors selected
when such vendors are not the lowest cost provider helps ensure that contracts are awarded on
a fair and unbiased bases. As such, we immediately implemented this practice.”

Solvay: “The District is in the process of developing policies and procedures for the procurement
of goods and services.”

The remaining three districts did not completely agree with our findings and recommendations.
These districts did not believe it was beneficial to seek competitive prices in obtaining professional
special education services, and offered the following statements to support their position:

16 OFFICE OF THE NEW YORK STATE COMPTROLLER

Skaneateles: “The Skaneateles Central School District wishes to avoid (providing) less than
effective services through low cost bids that could lead to lead parent dissatisfaction. Increased
service time and IEP meetings could lead to increased costs.”

West Genesee: “While the district understands the Comptroller’s position GML does not require
competitive bidding for professional services that involve specialized skill, training and expertise,
use of professional judgment or direction, and/or a high degree of creativity. While we also
understand that the RFP process would possibly ensure the District receives these services at the
best price without favoritism, it is not in the best interest of the students that are receiving these
services. We believe that the continuity of special education services and providers is crucial to the
development and success of the children that are receiving these services.”

White Plains: “It would be a great disservice to these children if we did not provide the necessary
services to provide quality support in their development process. In addition, selecting the lowest
cost provider, not qualified to provide the services, could result in some significant legal fees.”
“While cost is an important criterion in the selection process, the school district believes the quality
and availability of each provider to best meet the needs of each student must be considered as part
of the decision process.”

Comptroller’s Note

The process of seeking competitive prices for professional services through the use of RFPs or
price quotations is intended to help district officials obtain quality services for students at the best
value for taxpayers While our report illustrates opportunities for cost savings that a competitive
procurement process can provide, it does not state that cost is the only criterion to be used in
making such decisions. District officials are free to consider any other variables they believe are
relevant and necessary in selecting professional service providers for special education services.
However, it is essential that district officials maintain documentation to adequately support the
selections they make, and the basis for their selection decisions.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 17

 APPENDIX E

AUDIT METHODOLOGY AND STANDARDS

In order to determine if district officials are procuring special education professional services in
the most economical way, and in the best interests of district taxpayers, we interviewed various
district officials and examined policies and procedures, accounting records, and other relevant
documentation of districts for the period July 1, 2008 to August 31, 2009.

We selected nine school districts – Ardsley, East Ramapo, Farmingdale, Jericho, Oyster Bay-
East Norwich, Skaneateles, Solvay, West Genesee and White Plains – based on several factors
including special education expenditures, number of outsourced services, and proximity to other
districts selected for audit. We selected school districts in three regions – Nassau, Lower Hudson,
and Onondaga – as we wanted to include districts that were in close proximity to each other for
purposes of comparing rates paid for the same services.

We reviewed each district’s policies and procedures as they relate to procurement of special
education services. We interviewed various district officials, such as the Superintendents, Directors
of Special Education, and Assistant Superintendents of Business, to get an understanding of the
process at each district.

For vendors that District officials have the responsibility to identify and select to provide services,
we reviewed contracts, related invoices and other supporting documentation. We gained an
understanding of how the District procures special education professional services. If the District
used a competitive process, we obtained the RFP and/or quotes and compared to services rendered
and paid for by the district to determine if the vendor chosen was the provider that submitted the
lowest proposed rate. If no competitive process was used, we requested documentation to support
the decision in not going with the lowest proposal.

We conducted our performance audit in accordance with generally accepted government auditing
standards (GAGAS). Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our
audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.

18 OFFICE OF THE NEW YORK STATE COMPTROLLER

 APPENDIX F

HOW TO OBTAIN ADDITIONAL COPIES OF THE REPORT

To obtain copies of this report, write or visit our web page:

Office of the State Comptroller

Public Information Office
110 State Street, 15th Floor
Albany, New York 12236
(518) 474-4015
http://www.osc.state.ny.us/localgov/

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 19

 APPENDIX G
OFFICE OF THE STATE COMPTROLLER
DIVISION OF LOCAL GOVERNMENT
AND SCHOOL ACCOUNTABILITY
Steven J. Hancox, Deputy Comptroller
LOCAL REGIONAL OFFICE LISTING
ALBANY REGIONAL OFFICE
Kenneth Madej, Chief Examiner
Office of the State Comptroller
22 Computer Drive West
Albany, New York 12205-1695
(518) 438-0093 Fax (518) 438-0367
Email: Muni-Albany@osc.state.ny.us
Serving: Albany, Columbia, Dutchess, Greene,
Schenectady, Ulster counties
BINGHAMTON REGIONAL OFFICE
Office of the State Comptroller
State Office Building, Room 1702
44 Hawley Street
Binghamton, New York 13901-4417
(607) 721-8306 Fax (607) 721-8313
Email: Muni-Binghamton@osc.state.ny.us
Serving: Broome, Chenango, Cortland, Delaware,
Otsego, Schoharie, Sullivan, Tioga, Tompkins counties
BUFFALO REGIONAL OFFICE
Robert Meller, Chief Examiner
Office of the State Comptroller
295 Main Street, Room 1050
Buffalo, New York 14203-2510
(716) 847-3647 Fax (716) 847-3643
Email: Muni-Buffalo@osc.state.ny.us
Serving: Allegany, Cattaraugus, Chautauqua, Erie,
Genesee, Niagara, Orleans, Wyoming counties
GLENS FALLS REGIONAL OFFICE
Karl Smoczynski, Chief Examiner
Office of the State Comptroller
One Broad Street Plaza
Glens Falls, New York 12801-4396
(518) 793-0057 Fax (518) 793-5797
Email: Muni-GlensFalls@osc.state.ny.us
Serving: Clinton, Essex, Franklin, Fulton, Hamilton,
Montgomery, Rensselaer, Saratoga, Warren, Washington
counties
20 OFFICE OF THE NEW YORK STATE COMPTROLLER
HAUPPAUGE REGIONAL OFFICE
Ira McCracken, Chief Examiner
Office of the State Comptroller
NYS Office Building, Room 3A10
Veterans Memorial Highway
Hauppauge, New York 11788-5533
(631) 952-6534 Fax (631) 952-6530
Email: Muni-Hauppauge@osc.state.ny.us
Serving: Nassau, Suffolk counties
NEWBURGH REGIONAL OFFICE
Christopher Ellis, Chief Examiner
Office of the State Comptroller
33 Airport Center Drive, Suite 103
New Windsor, New York 12553-4725
(845) 567-0858 Fax (845) 567-0080
Email: Muni-Newburgh@osc.state.ny.us
Serving: Orange, Putnam, Rockland, Westchester
counties
ROCHESTER REGIONAL OFFICE
Edward V. Grant, Jr., Chief Examiner
Office of the State Comptroller
The Powers Building
16 West Main Street – Suite 522
Rochester, New York 14614-1608
(585) 454-2460 Fax (585) 454-3545
Email: Muni-Rochester@osc.state.ny.us
Serving: Cayuga, Chemung, Livingston, Monroe,
Ontario, Schuyler, Seneca, Steuben, Wayne, Yates counties
SYRACUSE REGIONAL OFFICE
Rebecca Wilcox, Chief Examiner
Office of the State Comptroller
State Office Building, Room 409
333 E. Washington Street
Syracuse, New York 13202-1428
(315) 428-4192 Fax (315) 426-2119
Email: Muni-Syracuse@osc.state.ny.us
Serving: Herkimer, Jefferson, Lewis, Madison,
Oneida, Onondaga, Oswego, St. Lawrence counties