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The OSC Audit … The Initial Request List (Part 2)

23 Mar 2015

In the last issue of the Special Edition blog, we reviewed the first 12 items from the OSC’s request list. In this issue, we will review the remaining 11 items (13 through 23). As we have said, we encourage you to start putting all these items together for the 2011/2012, 2012/2013, and 2013/2014 years so you have a head start when you receive the e-mail request from the OSC.

  1. Names and addresses of any subsidiaries owned or other formally affiliated businesses

Provide a list of all related parties with their addresses. This includes for-profit and nonprofit affiliates. The OSC is interested to see if charges are limited to actual costs of the related party. In addition, if multiple entities have the same address, the OSC is looking to see if occupancy costs are being properly allocated between entities.

  1. Name and addresses of parent company

If your organization has a parent or management company, you need to provide the name and address of the entity. The focus here of the OSC is allocation of costs and duplicative services.

  1. Student data: number of students, programs assigned to, and the locations of service

You need to maintain a list of your students by program outlining which site you service them in. For NY City agencies, this is a little easier with the CMR. For agencies outside of NY City, it may take a little more time to produce. Also understand that at some point in time, the OSC is most likely going to want a schedule that shows, by classroom, the teacher, the teacher assistants, and the children in each room on a monthly basis.

  1. Names and titles of special education staff (Include CFR-4 details – breakdown of each

employee by title)

The OSC wants a salary schedule that shows each staff member that worked for your agency for the year, their position title code(s), the salary that they were paid, and the programs they were charged to. This should reconcile to the CFR. This schedule will be a key schedule utilized by the OSC to test salary, bonuses (if salary per the schedule does not match out to salary notices in the employee’s file), time sheets, etc.

  1. Names and titles of direct care consultants or contractors

Similar to number 16 above, the OSC wants a detailed schedule showing all direct care consultants/contractors utilized by your agency for the year. In putting the schedule together, you should show both the agency paid, and the direct care worker who provided the service (and will be whose name is on the student’s progress notes).

  1. Certificate of occupancy, address, county, hours of operation

For each site you operate (as outlined on your approval letter), you need to provide a copy of the Certificate of Occupancy, the address, the County in which the site is located, and the hours that the site operated.

  1. Contact person’s name, phone number, email address

Your agency will need to identify the main contact person that all questions/requests from the OSC will travel through. For stand-alone schools, this is often the Executive Director. For larger providers it may not be. Understand that whoever this person is, they should have an understanding of both the fiscal and programmatic aspects of your agency, and they will be the go to person for the OSC, so they will be asked many questions and what they say will impact your School.

  1. Service contract with local educational agency, county or the State Education Department

You will need to provide the OSC with a copy of your State and County contracts, as well as any contracts you have with school districts.

  1. Evidence of verification of staff credentials and licenses

You need to provide the OSC with the following:

  1. A list of all educational staff and contractors outlining the licenses that they hold (e.g. teacher, teacher assistant)
  2. A list of clinical staff and contractors outlining the licenses that they hold
  3. An outline of your verification process supporting background checks and review of exclusion lists
  4. Copies of all licenses, background checks, etc. Now this last one can be very time consuming. As an alternative, you can provide samples of a cross-section of the various documents notifying the OSC of such and letting them know that the complete package will be available upon audit.
  1. Your State Education Department contact’s name, phone number and email address

Provide the OSC with the name and contact information for your RA and your line accountant at RSU.

    1. Your county or regional representative’s name, phone number and email address

Provide the OSC with a list of your County/School District contacts

As you go through the 23 item request list, if you have any questions, or require any assistance, please don’t hesitate to call Ken Cerini, Partner, at 631-868-1103 or e-mail him at kcerini@ceriniandassociates.com.