In criticizing the New York City Comptroller's Report on selected school systems in the United States, this analysis cites methodological errors in the design and execution of that work which, it is indicated here, invalidate many of the conclusions reached therein. According to this critique, the Comptroller's Report possessed a conceptually weak analytical framework, was flawed in its sample survey, was inconsistent in reporting and processing data, and made invalid comparisons of the data supplied by the different school districts. Tables are included. (Author/WP)