Audit 371900

FINDING REFERENCE NUMBER 2024-002 FEDERAL PROGRAMS (ALN – 84.027) SPECIAL EDUCATION – GRANTS TO STATES (IDEA, PART B) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.173) SPECIAL EDUCATION – PRESCHOOL GRANTS (IDEA PRESCHOOL) – SPECIAL EDUCATION CLUSTER (IDEA) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS H027A220003 – 22A (07/01/2022 – 09/30/2023); H027A230003 – 23A (07/01/2023 – 09/30/2024); H173A220002 (07/01/2022 – 09/30/2023); H173A230002 (07/01/2023 – 09/30/2024) COMPLIANCE REQUIREMENTS ACTIVITIES ALLOWED OR UNALLOWED // ALLOWABLE COSTS/COSTS PRINCIPLES TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 2 CFR Section 200.302 (a) establishes that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR Section 200.403 (b) establishes that except where otherwise authorized by statute, costs must be adequately documented in order to be allowable under Federal awards. STATEMENT OF CONDITION As part of our procedures over internal controls and compliance for the allowable activities’ requirement, we selected a sample of seventy-three (73) disbursements to suppliers made during the fiscal year under audit. We noted the following deficiencies: 1. In thirty-seven (37) disbursement receipts related to evaluation and therapy intervention services, service sheets with the signature or stamp of the institution that provided the services were not found. They were requested on several occasions and were not provided. 2. In nine (9) disbursement vouchers, the Excel master sheet and the adjustment report presented different amounts. No justification was provided for the differences in the reports. 3. In an evaluated disbursement voucher, a student was included who is billed $34,000 per month. In the student's file in MIPE, there is no breakdown of how the institution arrived at that amount in its service quote. The average monthly payments at that institution fluctuate between $9,300 and $20,800 per month. We were not provided with evidence of the educational cost analysis for this participant monthly cost. 4. In nine (9) disbursement vouchers, the payments to the suppliers for therapy services do not match the cost assigned by contract for these services. 5. In nine (9) disbursement voucher, the educational cost of a participant is not consistent with the proposal that the Institution includes in MIPE. 6. In four (4) disbursement vouchers evaluated, we were not provided with evidence of the supplier's proposals, nor was there evidence of receipt by the PRDE personnel demonstrating that the services were received as contracted. 7. In thirty-nine (39) vouchers evaluated, it was found that the invoiced expenses corresponded to both cluster programs (ALNs 84.027 and 84.173), and the invoices established this. However, the expenses in the system were recognized in grant ALN 84.027, not according to the participants attended and invoiced, according to their age. 8. In two (2) vouchers evaluated for training services, it was found that there were participants who were not employees of the IDEA program. 9. In a disbursement voucher, the cost per student could not be validated with the supplier's proposal per student, since it was not located in MIPE. QUESTIONED COSTS None. PERSPECTIVE INFORMATION This deficiency is a systemic problem that is related to lack of proper training and controls that require standard evaluation, approval, and reporting of expenditures incurred. STATEMENT OF CAUSE According to interviews carried out and documentation evaluated, some goods and services are received in the different Regional Offices (ORE), and each one carries out similar, but not standard, processes when certifying as received or pre-intervening invoices. Regarding the distribution of expenses, according to interviews and evaluated documentation, it was found that at the time of binding a contract, an analysis of the assigned participants is not made, in order to be able to make a distribution between the two programs of the cluster according to the age of the participant. In addition, according to interviews, although the contract budget is validated, they only limit themselves to verifying the amount available in general and there is no distribution of the expense according to the service provider's invoice. POSSIBLE ASSERTED EFFECT The PRDE is reporting expenses within the cluster that do not necessarily reflect the actual expenses incurred by each program in the cluster, this deficiency requires that when the period of availability of funds is ending, some adjustments be made to reclassify expenses, up to the amount of the award. In addition, the PRDE may have incurred payments for which the service or goods were not provided as contracted. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2023-003). RECOMMENDATIONS We recommend that the PRDE establish standardized written guidelines and train the staff of the Regions to carry out and document the reviews and approvals of services, and ascertain that this information is uploaded in the accounting system of SIFDE. In addition, the personnel must be instructed to account for the budget and expense of therapy and related services, according to the enrollment of students who will attend, in accordance with the program that applies within the cluster. VIEWS OF RESPONSIBLE OFFICIALS The PRDE acknowledges the auditor’s finding. Management clarifies that all requested information was available and existed within the PRDE systems; however, it was not provided in a timely manner due to circumstances beyond the Department’s control, including competing deliverables required from the same operational areas. Regarding the disbursement vouchers referenced by the auditors, including the Excel Master and Adjustment Reports, the program area reviewed the documents and confirmed that they reconciled accurately. The timing differences were due to automatic and manual adjustments. All supporting information was available in PRDE’s databases, including SIFDE and MIPE, and has been included as part of this response for further reference. For the student billed for $34,000, all supporting documentation—such as the proposal, approval of payment, and related evidence—was and remains available in MIPE. As part of PRDE’s internal controls, all necessary documentation must be uploaded into the system before any transaction can proceed. It is also important to note that auditors were granted full access to both MIPE and SIFDE at the beginning of their audit procedures. In relation to Findings 4 and 5, documentation was available in MIPE. Management notes that certain contracts and proposals may have amendments, and it appears the auditors may have reviewed an incorrect version of the file. Similarly, for Finding 6, the area revalidated the information during the preparation of this response and confirmed that the documentation cited as missing was, in fact, available in the MIPE portal. Additionally, management evaluated the matter related to expense recognition. In accordance with federal regulations and to ensure compliance with IDEA requirements, PRDE is authorized to cover certain expenses of the Preschool Grant (84.173) using IDEA Part B (84.027) funds. As detailed in the prior Single Audit report: “IDEA Part B, Section 611 funds can be used for students ages 3 to 21. According to the description provided by OSEP, the Grants to States program assists states in meeting the excess costs of providing special education and related services to children with disabilities. States must serve all children with disabilities between the ages of 3 through 21, unless inconsistent with State law or court orders. Under 34 CFR § 300.202(a), the LEA must use IDEA Part B funds to pay the excess costs of providing special education and related services to children with disabilities.” Regarding the vouchers related to training services, PRDE does not concur with that portion of the finding, as the contract does not stipulate that the teachers must be an IDEA employee. This contract was previously evaluated as part of the auditors’ procedures. The PRDE accepts the auditors’ recommendations and will implement corrective actions to improve the timely submission of documentation and strengthen internal coordination among areas involved in responding to audit requests Auditor Comment on Management Response for Finding No. 2024-002 In response of the second paragraph, our Auditors held three (3) meetings with PRDE’s personnel and the amounts were not reconciled. For the third response, no justification exists in MIPE or SIFDE that the amount paid is reasonable and in accordance with the contract. In fact, if all costs disclosed in the contract were applied to that student, the amount is less than the $34,000 paid monthly. For the fourth response related to Conditions 4 and 5, our Auditors requested all information to be available. We held three (3) meetings, and the information did not reconcile and was not available for our evaluation. In addition, we understand and acknowledge that contracts have amendments; however, these amendments relate to increases in the total amount because an original contract is based on a certain quantity, and amendments are made as funds are received. The cost per student established in the contract or proposals remained unchanged in these amendments. The lack of verification between the supplier's cost as stated in the contract and the cost invoiced by the supplier is a significant problem because the supplier is billing for a cost that was not part of the original agreement or proposal. For the fifth through seven responses, the Uniform Guidance requires that financial management system record the expenditures in the program that benefited from the services; no in the program with more budget.. IMPLEMENTATION DATE None RESPONSIBLE PERSON Enid Díaz Executive Director Alayra Figueroa Associate Secretary of Special Education

FINDING REFERENCE NUMBER 2024-003 FEDERAL PROGRAM (ALN – 84.938A) HURRICANE EDUCATION RECOVERY – INMMEDIATE AID TO RESTART SCHOOL OPERATIONS (RESTART) U.S. DEPARTMENT OF EDUCATION AWARD NUMBER S938A180002 (04/26/2018 – 09/30/2025) COMPLIANCE REQUIREMENTS ACTIVITIES ALLOWED OR UNALLOWED // ALLOWABLE COSTS/COSTS PRINCIPLES // EQUIPMENT AND REAL PROPERTY MANAGEMENT TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 2 CFR §200.302(b)(3)(4) establishes that the recipient's and subrecipient's financial management system must provide for the following: maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Effective control over and accountability for all funds, property, and assets. The recipient or subrecipient must safeguard all assets and ensure they are used solely for authorized purposes. 2 CFR §200.403 establishes that costs must meet the following criteria to be allowable under Federal awards: (g) be adequately documented. The Fiscal Process Guide – Program Funds Restart designed by the PRDE establishes that all movable and immovable property with a unit cost of five hundred dollars ($500.00) or more and a useful life of more than two (2) years will be capitalized. Both conditions must exist. These will be classified in the E5000 expense accounts, as appropriate. Also, indicate that capitalizable equipment (E5000) and non-capitalizable equipment (E4414) purchased with program funds will be labeled with the number assigned by the Property Registry System, as established in Section X of the "Procedure for the Control and Accounting of the Property of the Department of Education”. Also as stated in the Section 102(h)(3) of the 2018 Hurricane Relief Act, states that public control of funds and property for services provided to non-public schools must remain with a public agency, which also administers the funds and resources or contracts for services with public or private entities. STATEMENT OF CONDITION As part of our audit procedures over internal controls and compliance with the allowable activities requirement, we selected a sample of forty (40) disbursements from a population of six hundred eighty-three (683) disbursements to suppliers made during the fiscal year 2023-2024. During our testing, the following deficiencies were noted: 1. For two (2) reimbursement payments issued by the PRDE to private schools, we found that they were made based on a quotation instead of the invoice, which should have been submitted by the private school. 2. We noted three (3) reimbursement payments made by the PRDE to private schools due to equipment purchases performed that did not have the receiving reports issued by the private schools for properly validating that the equipment was incorporated as part of the private school records and its regular operations. Furthermore, the Restart Fiscal Process Guide does not contain a control that mandates the submission of a private school receiving report as part of the reimbursement process for equipment-related expenses. 3. For five (5) reimbursement payments for purchase of equipment were incorrectly recorded in account E6170 (Donations and Contributions to Private Entities) rather than in one of the E5000-series accounts designated for equipment. Also, these equipment’s were not included in the property & equipment register of the PRDE. According to the Restart Fiscal Process Guide, all the equipment purchased or reimbursed to the private schools should be recorded as part of the property list that belongs to the PRDE. In other words, PRDE must maintain ownership over the property bought with the Restart funds. QUESTIONED COSTS None. PERSPECTIVE INFORMATION During the evaluation of the supporting documents for the voucher, we observed that the invoice and receiving report were not available in SIFDE, considering that it is the accounting system designated for the evaluation of supporting documentation before the approval of any disbursement of funds. Also the codifications of these transactions were not properly reviewed in order to avoid missed codification, considering that the PRDE has the Third-Party Fiduciary Agent that had reviewed them and did not detect the missing codification and the missing documentation for the proper accounting and authorization process. STATEMENT OF CAUSE 1. The PRDE did not perform an effective review procedure over the reimbursement supporting documentation before the authorization of the payment. 2. Before reimbursements are processed, the PRDE has no established internal control or procedure requiring the private schools to submit receiving report for equipment purchases. 3. The PRDE lack of training or oversight on proper accounting practices, which leads to equipment expenses being coded incorrectly in account E6170 rather than the proper E5000 series. POSSIBLE ASSERTED EFFECT 1. If the PRDE issue reimbursement payment without the invoice, this could lead the PRDE to incur improper payments. 2. The PRDE lack of obtaining the receiving report for equipment purchases could lead to the reimbursing unallowable costs under the Federal program. Without proper documentation, it becomes difficult to verify whether the equipment purchases were legitimate and necessary for the program. 3. The PRDE incorrect accounting of equipment expenses could result in inaccurate financial reporting and a potential noncompliance issue with Federal regulations that require proper codification of expenses. IDENTIFICATION OF REPEAT FINDING Not previously reported. RECOMMENDATIONS We recommend that the PRDE review the Restart Fiscal Process Guide in order to include a requirement for private schools to submit receiving reports or equivalent documentation to substantiate equipment purchases prior to reimbursement. Provide training to all relevant personnel on the importance of accurate accounting and documentation, particularly for equipment purchases, and ensure that such expenses are properly coded. Implement a review process to verify that equipment reimbursements are supported by the required receiving report, invoice and that disbursements are coded appropriately in the accounting system (SIFDE). VIEWS OF RESPONSIBLE OFFICIALS The PRDE does not agree with the recommendation to revise the Restart Fiscal Process Guide to require private schools to submit a receiving report or equivalent documentation to substantiate equipment purchases prior to reimbursement. These transactions correspond to reimbursements, not direct purchases made by PRDE; therefore, verification is performed through proof of payment submitted by the schools. When auditors requested confirmation of receipt, PRDE obtained photographs of the equipment from the schools to provide additional verification that the items were in the school. In addition, the PRDE wants to clarify that where quotations were used instead of invoices, the private schools provided valid proof of payment that matched the quotations submitted. This evidence demonstrated that the purchases were completed and consistent with the approved documentation, meeting the requirements for allowable and verifiable costs under Federal regulations. The PRDE does not agree with the recommendation to change the accounting classification or to implement additional review procedures related to the use of account E6170, “Donations and Contributions to Private Entities.” The use of account E6170 is appropriate given the nature of the transaction, which reflects a reimbursement to a private school rather than a direct purchase by PRDE that would otherwise be recorded under account E5500. The PRDE acknowledges the deficiencies noted during the audit regarding the omission of reimbursed equipment purchases from the PRDE Property and Equipment Register. To address this, the PRDE has prepared a list of reimbursed equipment purchased by private schools under the Restart Program. This list will be provided to the personnel responsible for maintaining the register to ensure the inclusion of these items in the Property and Equipment Register, in compliance with the capitalization and accountability requirements established in the Restart Fiscal Process Guide. The corrective action is scheduled for implementation on or before the end of the current fiscal year. Auditor Comment on Management Response for Finding No. 2024-003 In relation to situation #2 comments, the PRDE didn’t have evidence of the receiving report, which is required for all other purchases of equipment for which the PRDE is the owner. Internal controls over property and equipment should be the same for all equipment for which the PRDE is the owner. In relation to situation #3, all equipment purchased and registered in this account was not included in the inventory of the PRDE, because the general ledger account used is not recognized for purchase of property and equipment, instead is a general ledger account for donations. Further, in accordance with the “Guia de Procesos Fiscales – Fondos Programa Restart”, it is established that all reimbursement of equipment should be recorded in accounts E5000 or E4414. This is because the system recognizes that an addition of equipment was made and must be capitalized. IMPLEMENTATION DATE In process. RESPONSIBLE PERSON María de los A. Lizardi Valdés Office of Federal Affairs Director Edgar Delgado Serrano Office of Federal Affairs Associate Director Hamir M. Mojica Mojica Program Coordinator

FINDING REFERENCE NUMBER 2024-004 FEDERAL PROGRAMS (ALN – 84.027) SPECIAL EDUCATION – GRANTS TO STATES (IDEA, PART B) (ALN – 84.196A) EDUCATION FOR HOMELESS CHILDREN AND YOUTH (ALN – 84.425D) COVID-19 EDUCATION STABILIZATION FUND: ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND (ALN – 84.425R) COVID-19 EDUCATION STABILIZATION FUND: CORONAVIRUS RESPONSE AND RELIEF SUPPLEMENTAL APPROPRIATIONS ACT, 2021 – EMERGENCY ASSISTANCE TO NON-PUBLIC SCHOOLS (CRRSA EANS) (ALN – 84.425U) COVID-19 EDUCATION STABILIZATION FUND: AMERICAN RESCUE PLAN – ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF (ARP ESSER) (ALN – 84.425V) COVID-19 EDUCATION STABILIZATION FUND: AMERICAN RESCUE PLAN – EMERGENCY ASSISTANCE FOR NON-PUBLIC SCHOOLS (ARP EANS) (ALN – 84.425W) COVID-19 EDUCATION STABILIZATION FUND: AMERICAN RESCUE PLAN – ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF – HOMELESS CHILDREN AND YOUTH (ARP HCY) (ALN – 84.938A) HURRICANE EDUCATION RECOVERY – INMMEDIATE AID TO RESTART SCHOOL OPERATIONS (RESTART) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS H027A220003 (0701/2022 – 09/30/2023); S196A220040 (0701/2022 – 09/30/2023); S196A230040 (0701/2023 – 09/30/2024); S425D210029 (01/05/2021 – 03/31/2025); S425R210053 (06/28/2021 – 03/31/2025); S425U210029 (03/24/2021 – 03/28/2026); S425V210053 (09/24/2021 – 03/28/2026); S425W210040 (04/23/2021 – 03/28/2026); S938A180002 (04/26/2018 – 09/30/2025); S938A180009 (09/29/2022 – 04/30/2026); CONSOLIDATED FUNDS COMPLIANCE REQUIREMENT ALLOWABLE COSTS/COSTS PRINCIPLES TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E establish the requirements for Cost Principles – Allowable Costs under Federal awards. This Section at § 200.403 discloses factors affecting allowability of costs – states that costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; and (g) Be adequately documented. Section § 200.404 Reasonable costs add: A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost including (c) Market prices for comparable goods or services for the geographic area. Also, § 200.405 Allocable Costs include that: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received; including (2) Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods. STATEMENT OF CONDITION During our internal control and compliance tests of disbursements for Federal programs, we selected four (4) payments of professional services of Third-Party Fiduciary Agent Services ("TPFA") as part of our samples of the different Federal major programs. During our tests, we noted the following conditions: 1. Reasonableness of costs: The payment made to the vendor is a "flat fee" monthly payment agreed to in the professional service contract. Although the vendor invoice includes a detail of hours of service and expense summary, this information is solely for "information purposes" and not to be taken into account for the actual invoice payment process. The monthly payment amount only consideration is the agreed upon "flat fee". In the invoices evaluated (see detail below), the vendor includes a total hours incurred for each invoice with a price per hour range from $195 to $695. Also, the invoices include an expense summary for the period. When we compared the actual payment to the hours incurred and related expenditures, we noted an unreasonable charge to the PRDE and its Federal funds based upon the payment being made versus the actual service hours/expenses included on the invoice; when it is compared to price estimates made during the RFP process when the per hour price ranges were from $65 to $352. VOUCHER NUMBER VOUCHER DATE VOUCHER AMOUNT INVOICE NUMBER INVOICE DATE SERVICE PERIOD TOTAL HOURS INVOICED INVOICE AMOUNT TOTAL RELATED EXPENSES AVERAGE HOURLY RATE CALCULATED 24AP7166 8/14/2023 $ 2,333,333.33 830311-2023-27 7/5/2023 June 2023 7,335.00 $ 2,333,333.33 $ 699,296.00 $ 222.77 01180123 9/6/2023 2,333,333.33 830311-2023-28 8/1/2023 July 2023 6,756.00 2,333,333.33 127,620.42 326.48 01184263 9/19/2023 2,333,333.33 830311-2023-29 9/1/2023 August 2023 7,633.30 2,333,333.33 104,084.01 292.04 01188131 10/19/2023 2,333,333.33 830311-2023-30 10/1/2023 September 2023 6,884.00 2,333,333.33 103,238.55 323.95 01195137 11/28/2023 2,333,333.33 830311-2023-31 11/1/2023 October 2023 6,929.00 2,333,333.33 137,665.35 316.88 01201906 1/10/2024 2,333,333.33 830311-2023-32 12/1/2023 November 2023 5,913.00 2,333,333.33 91,491.21 379.14 01210539 1/30/2024 476,208.71 830311-2023-33A 1/1/2024 December 2023 1,130.00 476,208.71 - 421.42 01210542 2/6/2024 1,857,124.62 830311-2023-33B 1/1/2024 December 2023 4,408.00 1,857,124.62 73,628.57 404.60 01221775 3/12/2024 2,333,333.33 830311-2024-34 2/1/2024 January 2024 6,018.00 2,333,333.33 86,982.26 373.27 01226705 4/9/2024 2,333,333.33 830311-2024-35 3/1/2024 February 2024 5,725.00 2,333,333.33 75,861.61 394.32 01235153 4/16/2024 2,333,333.33 830311-2024-36 4/1/2024 March 2024 6,200.00 2,333,333.33 109,583.33 358.67 01251041 5/23/2024 2,500,000.00 830311-2024-37 5/8/2024 April 2024 6,420.00 2,500,000.00 302,908.85 - 01261194 6/24/2024 53,700.00 830311-2024-38A 6/1/2024 May 2024 126.74 53,700.00 - 423.70 01261196 6/24/2024 1,678,208.00 830311-2024-38B 6/1/2024 May 2024 4,245.79 1,678,208.00 180,197.40 352.82 01261198 6/24/2024 768,092.00 830311-2024-38C 6/1/2024 May 2024 1,964.47 768,092.00 - 390.99 $ 28,333,333.30 $ 28,333,333.30 $ 2,092,557.56 2. Allocability – the payment made was distributed among several Federal programs and state funds as follows: CONSOLIDATED FUNDS (SEA/LEA) ALN 84.027 NON-MAJOR ALN 84.196A ALN 84.425D ALN 84.425R ALN 84.425U ALN 84.425V ALN 84.425W ALN 84.938A TOTAL ALLOCATED AMOUNT $ - $ 2,333,333.33 $ - $ - $ - $ - $ - $ - $ - $ - $ 2,333,333.33 - 2,333,333.33 - - - - - - - - 2,333,333.33 - 2,233,379.03 - 24,483.39 - - - - 75,470.91 - 2,333,333.33 2,333,333.33 - - - - - - - - - 2,333,333.33 2,333,333.33 - - - - - - - - - 2,333,333.33 - - 35,000.00 19,542.04 300,000.00 100,000.00 1,523,791.29 55,000.00 - 300,000.00 2,333,333.33 - - - - - - 476,208.71 - - - 476,208.71 1,857,124.62 - - - - - - - - - 1,857,124.62 2,333,333.33 - - - - - - - - - 2,333,333.33 2,333,333.33 - - - - - - - - - 2,333,333.33 2,333,333.33 - - - - - - - - - 2,333,333.33 2,500,000.00 - - - - - - - - - 2,500,000.00 53,700.00 - - - - - - - - - 53,700.00 1,678,208.00 - - - - - - - - - 1,678,208.00 - 65,031.74 - 63,309.25 - - 500,000.00 - 139,751.01 - 768,092.00 $ 17,755,699.27 $ 6,965,077.43 $ 35,000.00 $ 107,334.68 $ 300,000.00 $ 100,000.00 $ 2,500,000.00 $ 55,000.00 $ 215,221.92 $ 300,000.00 $ 28,333,333.30 62.67% 24.58% 0.12% 0.38% 1.06% 0.35% 8.82% 0.19% 0.76% 1.06% Based on the payment documentation of the evaluated invoices, the allocations were made based on available budget of administrative allocation of Federal awards, the invoices didn't include any basis for the allocation of costs between Federal and non-Federal funds. For example, on invoice number 830311-2023-32 the amount of $1,978,791 (85% of total invoice amount) was charged to several programs of ALN 84.425, although the services described in the invoice were not related only to these programs; therefore, the cost objective is not chargeable in accordance with the relative benefit received. In addition, several invoices for a total amount for the year of $6,965,077 or 24.58% of total payments were charged to Consolidated Funds which includes several Federal programs that could be incurred in unallowed costs. QUESTIONED COSTS Based on the Criterias established on Part II, § 200.403 and § 200.404 for Cost Principles – Allowable Costs under Federal awards, the based used for the costs distribution without specific services rendered to Federal Programs, as described in the Statement of Condition, we estimate as minimum the amount of $3,612,556.60 (including $107,334.68 on a Non-Major Program ALN 84.196A) as questioned costs for not supported documentation. This amount should increase if an evaluation of costs charged to Federal Programs included in Consolidated Funds. See also Perspective Information for more support. PERSPECTIVE INFORMATION The total contract amount awarded for the services over the two-year period is $79,675,000, with a flat fee of $3,143,750 for the first twelve months, and $3,495,833 for the next twelve months. In the fiscal year 2023 there were 3 amendments to the original contract where it was agreed to pay a total fee of $2,995,833 for the months of April and May 2023 and the total amount of $23,333,333 for 10 additional months or $2,333,333 monthly from June 2023 to March 2024. During fiscal year 2024 there were two (2) amendments to the original contract where it was agreed to pay a total monthly fee of $2,500,000 for the months of April 2024 to March 2025, and a total monthly fee of $2,375,000 for the months of April 2025 to October 2025. From the first year of the contract up to the last amendment the total contract amount is approximately $155,625,000. Based on the inconsistent cost allocation method and the lack of a requirement for the payments being made for actual works performed, we considered this a systematic problem in the contract management and payment. Based on the information provided and evaluated the allocation between Federal and non-Federal funds is not applied consistently, other eleven (11) invoices for a total amount of $17,755,699 were paid from non-Federal funds, during the fiscal year. In accordance with the documentation provided the allocation used is based on the budget amounts available from state and Federal funds; during this fiscal year the total amount paid to the supplier was $28,333,333. Of this amount 62.67% were covered with state funds, 24.58% with consolidated activities funds, and 12.75% with Federal programs funds. STATEMENT OF CAUSE The PRDE did not include on the RFP process and the contract negotiation a clause that requires that the payment of services will be made upon actual hours incurred or that a final reconciliation process will be made during the contract period of performance based on actual service hours and expense incurred. The PRDE agreed upon a "flat fee" contract based on an estimate / budget of hours presented by the vendor on its proposal without considering the requirement of adjusting the payment for actual workhours incurred as part of its contract negotiation. The PRDE staff could not provide the basis used to distribute the cost between the different programs and state funds in accordance with the benefit obtained from the costs incurred. There is no consistent treatment or basis for the allocation of the payment costs between Federal programs and state funds. The contract includes the accounting codes that can be charged for the contract costs; however, no amounts, limitations, or basis for the cost’s distributions were included on the contract or in the payment documentation. POSSIBLE ASSERTED EFFECT Unreasonable costs may be charged to the PRDE's Federal programs that may result in questionable or unallowable costs by the Federal grantors. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Numbers 2021-006; 2022-008; and 2023-004). RECOMMENDATIONS We recommend to the PRDE to establish an adequate and consistent allocation method of each invoice amount that reflects the relative benefits that the Federal program received from the services provided by the supplier during the invoice period, so the Federal program can be charged for the costs of that period. In addition, we recommend that the PRDE revised the contract terms to include a reconciliation of total hours and rates to adjust the payments made to the vendor before the contract expiration. Also, we recommend that the PRDE should request that adequate supporting evidence from the vendors be presented for any expenses to be reimbursed by the PRDE. VIEWS OF RESPONSIBLE OFFICIALS The PRDE does not agree with the Recommendation to establish an allocation method for TPFA invoices because TPFA services are overhead costs paid from administrative funds and are not tied to any specific federal grant. In addition, the PRDE does not agree that contract terms should be revised before the contract expiration to require a reconciliation of total hours and rates because again, payments to the TPFA are overhead costs not directly tied to any specific program. Finally, the PRDE does not agree with the recommendation that the TPFA submit supporting evidence for the reimbursement of expenses because (i) the TPFA contract is a fixed fee that is inclusive of all professional service fees and expenses and (ii) the TPFA provides an explanation of major expenses incurred within each monthly invoice. Auditor Comment on Management Response for Finding No. 2024-004 As stated in CONDITION 2., “…on invoice 830311-2023-32 the amount of $1,978,791 (85% of total invoice amount) was charged to several programs of ALN 84.425, although the services described in the invoice were not related only to these programs; therefore, the cost objective is not chargeable in accordance with the relative benefit received.” Further, the 2 CFR 200.1, establishes that: “Indirect [facilities & administrative (F&A)] costs mean those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools must be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.” This information was not provided for our evaluation. Also, we made reference to the Program Determination Email for ALNs. 84.938 and 84.425 dated September 18, 2024 (Audit Control Number 02-21-39634), received from Ms. Catherine Miers of the Office of Elementary and Secondary Education of the US Department of Education (USDE), in which they required that the PRDE provide documentation for the following corrective actions: “revised the contract terms to include a reconciliation of total hours and rates to adjust the payments made to the vendor before the contract expiration; requested that adequate supporting evidence from the vendors be presented for any expenses to be reimbursed by the PRDE; and develop an adequate review of the vendors invoice to properly identify the actual hours of services that benefited the Federal programs so a correct allocation of the costs incurred can be made within Federal programs and state funds”. IMPLEMENTATION DATE None RESPONSIBLE PERSON Jullymar Octtaviani Vega Sub-Secretary of Administration María de los Angeles Lizardi Valdés Office of Federal Affairs Director

FINDING REFERENCE NUMBER 2024-005 FEDERAL PROGRAMS (ALN – 10.553) SCHOOL BREAKFAST PROGRAM (SBP) – CHILD NUTRITION CLUSTER (ALN – 10.555) NATIONAL SCHOOL LUNCH PROGRAM (NSLP) – CHILD NUTRITION CLUSTER (ALN – 10.559) SUMMER FOOD SERVICE PROGRAM FOR CHILDREN (SFSP) – CHILD NUTRITION CLUSTER (ALN – 10.582) FRESH FRUIT AND VEGETABLE PROGRAM (FFVP) – CHILD NUTRITION CLUSTER (ALN – 10.558) CHILD AND ADULT CARE FOOD PROGRAM (CACFP) U.S. DEPARTMENT OF AGRICULTURE (ALN – 84.010A) TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES (TITLE I, PART A OF THE ESSEA) (ALN – 84.027) SPECIAL EDUCATION – GRANTS TO STATES (IDEA, PART B) (ALN – 84.048A) CAREER AND TECHNICAL EDUCATION – BASIC GRANTS TO STATES (PERKINS V) (ALN – 84.367A) SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (formerly IMPROVING TEACHER QUALITY STATE GRANTS) (ALN – 84.425D) COVID-19 EDUCATION STABILIZATION FUND: ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND (ALN – 84.425U) COVID-19 EDUCATION STABILIZATION FUND: AMERICAN RESCUE PLAN – ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF (ARP ESSER) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS 1PRAEA18SCESUBA (10/01/2018 – 09/30/2019); 1PRAEA19SCESUBA (10/01/2019 – 09/30/2020); 1PRAEA20SCESUBA (10/01/2020 – 09/30/2021); 1PRAEA21SCESUBA (10/01/2021 – 09/30/2022); 1PRAEA22SCESUBA (10/01/2022 – 09/30/2023); 221PR300336E_A (10/01/2022 – 10/30/2024); S010A130052 (07/01/2013 – 09/30/2014); S010A140052 (07/01/2014 – 09/30/2015); S010A160052 (07/01/2015 – 09/30/2016); S010A160052 (07/01/2016 – 09/30/2017); H027A12003 (07/01/2012 – 09/30/2013); H027A14003 (07/01/2014 – 09/30/2015); H027A15003 (07/01/2015 – 09/30/2016); H027A18003 (07/01/2018 – 09/30/2019); H027A19003 (07/01/2019 – 09/30/2020); H027A20003 (07/01/2020 – 09/30/2021); H027A21003 (07/01/2021 – 09/30/2022); V048A180052 (07/01/2018 – 09/30/2019); S367A160052E (07/01/2016 – 09/30/2017); S425D200029 (06/16/2020 – 09/30/2021); S425D210029 (01/05/2021 – 03/31/2025); S425U210029 (03/24/2021 – 03/28/2026) COMPLIANCE REQUIREMENT ALLOWABLE COSTS/COSTS PRINCIPLES TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 2 CFR Section 200.403 (g) establishes that except where otherwise authorized by statute, costs must be adequately documented in order to be allowable under Federal awards. In addition 2 CFR Section 200.1, defines improper payments as a payment that should not have been made or that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements. The term improper payment includes any payment to an ineligible recipient, any payment for ineligible goods or service, any duplicate payment, any payment for a good or service not received (except for those payments where authorized by law), any payment that is not authorized by law, and any payment that does not account for credit for applicable discounts. STATEMENT OF CONDITION As part of our audit procedures and interviews over financial reporting, we obtained a detail of accounts receivable related to duplicate or incorrect payments made for payroll transactions in the amount of $4,659,739. Invoices issued during the fiscal year ended June 30, 2024, balance, were distributed as federal and state, as follows: ALN Number Transaction Balance 10.553/ 10.555/ 10.559/ 10.582 $ 167,694 10.558 1,240 84.010A 64,517 84.027A 228,284 84.041 546 84.048A 4,802 84.367A 1,027 84.425D 35,165 84.425U 27,501 Not Determined 2,357,671 Not Determined 25,907 Not Applicable 1,745,385 $ 4,659,739 Title I Grants to Local Educational Agencies (Title I, Part A of the ESEA) Special Education - Grants to States (IDEA, Part B) Impact Aid (Title VII of ESEA) Program Description Child Nutrition Cluster Child and Adult Care Food Program (CACFP) Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) COVID-19 Education Stabilizatiopn Fund: Elementary and Secondary School Emergency Relief Fund (ESSER) Total Invoices Issued Balance at 06/30/2024 Career and Technical Education - Basic Grants to States (Perkins V) Schoolwide Program (State and Federal Funds) Consolidated Funds (State and Federal Funds) State Funds COVID-19 Education Stabilizatiopn Fund: American Rescue Plan – Elementary and Secondary School Emergency (ARP ESSER) QUESTIONED COSTS Identified questioned costs are $530,776, which were identified as employees that didn't work for the Federal program. Other amount may be unallowed, if the PRDE can identify the portion of Federal funding incurred in Schoolwide and Consolidated activities. PERSPECTIVE INFORMATION The amount of $4,659,739, corresponds to incorrect payroll payments made from current and prior years, for which during fiscal year 2023-2024, the PRDE determined that an invoice for excess payroll payments proceeds. The PRDE was unable to indicate which amount of Schoolwide or Consolidated funds corresponds to Federal funding, because these funds close at year end. STATEMENT OF CAUSE The PRDE sends the Treasury Department of Puerto Rico a balance of the payroll, before the end of the fortnight, to speed up the payment process. By sending this information without balancing the hours worked, it causes errors in the payroll computations. POSSIBLE ASSERTED EFFECT The PRDE incurred payments to employees for hours not worked, and for which specific grants were received. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2023-005). RECOMMENDATIONS We recommend PRDE design and implement adequate internal controls and payroll processes that will identify in real – time or sooner any incorrect payroll payment made. FINDING REFERENCE NUMBER 2024-005 – continuation VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding and has implemented a comprehensive corrective action plan to address payroll processing errors, strengthen internal controls, and ensure accurate and timely payments. As part of PRDE’s Fiscal Plan of 2020–2021, the Department launched the official integration project between the Time, Attendance, and Leave (TAL) system and the Payroll (RHUM) system. This integration ensures that payroll disbursements are made only after the employee’s attendance has been validated through the TAL system. Employees are required to record their attendance using biometric verification or have an authorized leave properly documented and approved by their supervisor before receiving payment. If attendance is not validated, the system automatically issues a notification and applies the necessary adjustment. This project, initiated in November 2020 with the collaboration of the Puerto Rico Fiscal Oversight and Management Board (FOMB), MS Consulting, the Department of the Treasury (Hacienda), the Financial Advisory Authority (AAFAF), and the Puerto Rico Innovation and Technology Service (PRITS), was fully integrated by February 2021. As a result, PRDE has significantly reduced overpayments, duplicate payments, and other payroll inconsistencies. To reinforce this effort, PRDE issued a new Time and Attendance Policy on December 7, 2021, later updated on April 11, 2022, which clearly defines employee responsibilities, authorized leaves, disciplinary procedures, and supervisor accountability. Under this policy, employees and supervisors are required to follow strict timekeeping procedures, and noncompliance triggers automatic system notifications and salary adjustments. The PRDE’s Time and Attendance staff continues to monitor and maintain compliance through: i. Ongoing training sessions for PRDE personnel; ii. System dashboards tracking attendance behaviors; iii. Issuance of notifications and payroll adjustments as required; and iv. Regular follow-up and evaluation activities. Additionally, PRDE’s Finance Office implemented a reconciliation process that integrates data from TAL, RHUM, and SIFDE, ensuring that payroll expenditures align with validated attendance records. The system now performs cross-checks before submission to the Treasury Department, preventing disbursements for unverified time. These combined measures—technological integration, policy enforcement, staff training, and reconciliation controls—have strengthened payroll accuracy, reduced the risk of overpayments, and improved financial accountability across the Department. IMPLEMENTATION DATE Done RESPONSIBLE PERSON Evelyn Rodríguez Cardé Finance Office Director Jullymar Octtaviani Vega Sub-Secretary of Administration

FINDING REFERENCE NUMBER 2024-006 FEDERAL PROGRAMS (ALN – 84.027) SPECIAL EDUCATION – GRANTS TO STATES (IDEA, PART B) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.173) SPECIAL EDUCATION – PRESCHOOL GRANTS (IDEA PRESCHOOL) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.425R) COVID-19 EDUCATION STABILIZATION FUND: CORONAVIRUS RESPONSE AND RELIEF SUPPLEMENTAL APPROPRIATIONS ACT, 2021 – EMERGENCY ASSISTANCE FOR NON-PUBLIC SCHOOLS (CRRSA EANS) (ALN – 84.425U) COVID-19 EDUCATION STABILIZATION FUND: AMERICAN RESCUE PLAN – ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF (ARP ESSER) (ALN – 84.938A) HURRICANE EDUCATION RECOVERY – IMMEDIATE AID TO RESTART SCHOOL OPERATIONS (RESTART) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS H027A230003 – 23A (07/01/2023 – 09/30/2024); H027A230003 – 24A (07/01/2024 – 09/30/2025); H173A230002 (07/01/2023 – 09/30/2024); H173A230002 (07/01/2024 – 09/30/2025); S425R210053 (06/28/2021 – 03/31/2025); S425U210029 (03/24/2021 – 03/28/2026); S938A180002 (04/26/2018 – 09/30/2025) COMPLIANCE REQUIREMENT EQUIPMENT AND REAL PROPERTY MANAGEMENT TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 2 CFR Section 200.313, establishes that procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. STATEMENT OF CONDITION As part of our procedures on equipment requirements, we requested an inventory of equipment from the PRDE as of June 30, 2024. No inventory was taken since 2019. The PRDE provided a list of all additions made during the fiscal year. In the list of additions provided to us, we found that a total amount of $844,273.56, classified as programs and licenses, should not be capitalized as equipment because they have a useful life of less than one year. From the samples selected for the different programs, we were able to identify that the property records are not being updated in a reasonable timeframe, since for a total of twenty-six (26) items evaluated, the person assigned as the equipment custodian in the records is not the current custodian of the equipment. We selected a sample of forty (40) units for the IDEA Cluster, to determine that the items were properly safeguarded and the usage was in accordance with the regulations. We found the following deficiencies: 1. There is an item describing a three-person sectional sofa, when we viewed the article, they showed us a five-burner stove with the sofa's property number. 2. One (1) item could not be observed. We selected a sample of forty (40) items for the Education Stabilization Fund Programs, to determine that the items were properly recorded, identified, safeguarded and the usage was in accordance with the regulations. We found the following deficiencies: 1. One (1) item could not be observed. 2. One (1) item, an air-conditioning, purchased in February 2024, at the time of our test in September 2025, is still uninstalled, as the area lacks the necessary connection. 3. Two (2) items, an institutional frying pan and a stainless-steel worktable, purchased in October 2023 and February 2024 respectively, at the time of our test in September 2025, remain in the equipment warehouse at Las Piedras without being installed and used. 4. One (1) item, a hydroponic nursery, purchased in November 2023, at the time of our test in September 2025, was not in used and looks as if not fully installed and deteriorated. 5. One (1) item, an Apple Computer, purchased in December 2023 to a private school, at the time of our test in September 2025 was observed at the OFA equipment warehouse because the private school closed operations, the equipment records were not updated to reflect these changes. QUESTIONED COSTS None. PERSPECTIVE INFORMATION Each school principal conducted an equipment count, but it was not reviewed, and not all schools did so. No inventory taken was provided, the last inventory was made in 2019, and the latter revealed deficiencies. The identified deficiencies constitute a systemic problem. Items purchased during fiscal year under audit were not installed, located, and no proper tracking of transfer of equipment is maintained in the PRDE. STATEMENT OF CAUSE Due to various natural events that have occurred and the COVID-19 pandemic, the PRDE has not been able to work with the inventory and update it. In addition, the Property Department does not have procedures in place in order to identify incomplete records, unidentified dispositions, equipment not installed or not in use. POSSIBLE ASSERTED EFFECT It was not possible to validate that the PRDE complies with the requirements established by the Federal regulation related to the maintenance of records of equipment acquired with Federal funds. In addition, deficiencies were noted in the usage and proper safeguard of the equipment purchased. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2023-006). RECOMMENDATIONS We recommend that the PRDE carry out an inventory and reconcile it with the records maintained by the PRDE. In addition, internal controls must be implemented to ensure that only equipment that is necessary for the operation of the programs is purchased. In addition, the use of this equipment must be monitored, so that its installation and use are followed up, as well as the transfer of equipment and changes to the property records. VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the finding and has initiated corrective actions to address each of the issues identified by the auditors. The Department of Education of Puerto Rico (PRDE) recognizes the importance of maintaining an accurate and up-to-date property inventory in accordance with federal regulations under 2 CFR §200.313(d), and is implementing measures to strengthen controls, ensure proper tagging, and monitor the location, use, and condition of all federally funded equipment. The Property Office has initiated a complete physical inventory to reconcile the existing property records with actual assets. All equipment custodians will be required to verify and certify their assigned inventory to ensure records are accurate and reflect current locations and responsible personnel. For deficiencies identified for the IDEA Cluster: Condition 1: For the item describing a three-person sectional sofa, which upon inspection corresponded to a five-burner stove, the Property Office corrected the equipment tag to ensure identification of both items. The correction was made directly on the physical assets to properly reflected the correct property numbers and descriptions. Condition 2: The item identified as not observed corresponds to software licenses that were distributed to teachers for instructional use. The Property Office maintains a detailed record identifying the licenses purchased, the specific equipment on which each license was installed, and the corresponding custodian. For deficiencies identified for the Education Stabilization Fund Programs: Condition 1: For the items that could not be observed during the auditors’ site visits, the Property Office will perform a follow-up investigation with the corresponding school to locate the equipment. Condition 2: The school where the air-conditioning unit is located has experienced electrical voltage issues, which have delayed its installation to prevent potential damage to the equipment. The situation is being addressed in coordination with the school’s maintenance team to correct the electrical problem. Once resolved, the PRDE will proceed with the installation. In parallel, the property office will consult with the corresponding federal program to evaluate the possibility of relocating the unit to another school where the equipment is needed and can be safely installed and used. Condition 3: This type of equipment is kept in the warehouse until a specific need is identified in a school facility. Once a school requests or is identified as requiring the equipment, the Property Office initiates the corresponding transfer, and the movement is duly documented and updated in the property management system.. this process ensures that equipment is allocated efficiently based on program needs and that all transfers are properly supported with documentation. Condition 4: The hydroponic nursery will be relocated to a school where it can be properly utilized for educational purposes. The Property Office, in coordination with the corresponding program, will verify the current condition of the equipment and perform the necessary repairs or adjustments to ensure it is fully functional and in use as intended. Condition 5: The Property Office has already identified a new school to which the Apple computer will be transferred to ensure it is properly utilized for educational purposes. The transfer will be completed om coordination with the corresponding program, and the property records will be updated accordingly to reflect the new location and custodian of the equipment. The PRDE is committed to correcting all deficiencies noted in the finding. All actions described above will be documented and reported as part of the corrective action plan, with an expected completion timeline within fiscal year 2025. These measures will ensure compliance with the Uniform Guidance and strengthen the overall management and safeguarding of federally funded property and equipment. IMPLEMENTATION DATE In process. RESPONSIBLE PERSON Nilda Z. Morales Vazquez Property Office Director

FINDING REFERENCE NUMBER 2024-007 FEDERAL PROGRAM (ALN – 84.002) ADULT EDUCATION – BASIC GRANTS TO STATES U.S. DEPARTMENT OF EDUCATION AWARD NUMBER V002A210053 (07/01/2021 – 09/30/2023) COMPLIANCE REQUIREMENT MATCHING, LEVEL OF EFFORT, EARMARKING TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 29 USC 3302(a)(1) establishes that the 82.5% of the state eligible agency grant fund may use for grants and contracts for eligible providers. 29 USC 3302(a)(2) and 3303 establishes that the funds used for state leadership activities shall not exceed 12.5% of the state eligible agency’s grants funds. 29 USC 3302 (a)(3) establishes that the used for necessary and reasonable administrative expenses of the state eligible agency shall not be more than 5% of the grants funds, or $85,000, whichever is greater. STATEMENT OF CONDITION As part of our audit procedures over internal controls and compliance with Earmarking we performed a test to the expenses from V002A210053, that is the grant that ends in the fiscal year of our audit. The PRDE did not comply with the required earmarking percentages for the program. In the period expense analysis, we found that only 79% was allocated to grants and contracts for eligible providers, which is below than stipulated 82.5%. Additionally, they spent 13.4% on leadership activities, above the stipulated maximum of 12.5%. They spent 6% on administrative expenses, compared to the maximum of 5%. QUESTIONED COSTS None. PERSPECTIVE INFORMATION When the PRDE receives the program's budget, enters it into the accounting system with the earmarking percentages required by the Federal agency. The fiscal team monitors expenses to ensure compliance. However, they did not spend 100% of the funds and did not ensure that the expenses incurred from grant V002A210053 met the percentages stipulated by the program. STATEMENT OF CAUSE The PRDE lack of an adequate tracking system that would allow management to monitor the progress of expenses in relation to the Earmarking percentages during the fiscal year. POSSIBLE ASSERTED EFFECT Failure to comply with these requirements puts the PRDE at risk of having to return misallocated Federal funds. IDENTIFICATION OF REPEAT FINDING Not previously reported. RECOMMENDATIONS Management is encouraged to conduct ongoing expense analysis to ensure compliance with the program requirements. VIEWS OF RESPONSIBLE OFFICIALS The Workforce Innovation and Opportunity Act (WIOA) of 2014, Title II – Adult Education and Family Literacy Act, Section 3302(a) establishes the earmarking percentages that apply to the total amount of the federal award as follows: Section 3302(a) – State Distribution of funds: Each eligible agency receiving a grant under section 3291(b) for a fiscal year— (1) shall use not less than 82.5 percent of the grant funds to award grants and contracts under section 3321 of this title and to carry out section 3305 of this title, of which no more than 20 percent of such amount shall be available to carry out section 3305; (2) shall use not more than 12.5 percent of the grant funds to carry out State leadership activities under section 3303; and (3) shall use not more than 5 percent of the grant funds, or $85,000, whichever is greater, for the administrative expenses of the eligible agency. In accordance with this statutory requirement, the Puerto Rico Department of Education (PRDE) allocated the required percentage of the total federal award as established by WIOA. The earmarking requirement is based on allocation, not expenditure, as confirmed by federal regulations and guidance. The PRDE fully executed this process and properly allocated the percentage of the total grant to subgrants, leadership, and administrative activities. This is evidenced in the PRDE financial system (SIFDE) and the federal financial report (FFR) issued by the program at the end of the grand period. Actual expenditure levels depend on factors outside the agency’s direct control, such as provider operational changes, enrollment fluctuations, or cost variances. Federal law does not equate earmarking with expenditures; instead, it requires allocation of grant funds according to the statutory percentages. For the reasons, management does not concur with the audit finding and respectfully asserts that the PRDE is in full compliance with the WIOA Title II earmarking requirements. Auditor Comment on Management Response for Finding No. 2024-007 As stated in your response to the finding, the PRDE made a “budget allocation” for the authorized funds in the award. But, as stated in PRDE response, also WIOA Regulation established the following: “The Workforce Innovation and Opportunity Act (WIOA) of 2014, Title II – Adult Education and Family Literacy Act, Section 3302(a) establishes the following requirement: Section 3302(a) – State distribution of funds: Each eligible agency receiving a grant under section 3291(b) for a fiscal year— (1) shall use not less than 82.5 percent of the grant funds to award grants and contracts under section 3321 of this title and to carry out section 3305 of this title, of which no more than 20 percent of such amount shall be available to carry out section 3305; (2) shall use not more than 12.5 percent of the grant funds to carry out State leadership activities under section 3303; and (3) shall use not more than 5 percent of the grant funds, or $85,000, whichever is greater, for the administrative expenses of the eligible agency.” Regulation stated clearly that the earmarking compliance requirement are based on use (“shall use” not “shall allocate”). IMPLEMENTATION DATE None RESPONSIBLE PERSON Yarilis Santiago Ramos Auxiliary Secretary of Alternative Education María de los A. Lizardí Valdés Office of Federal Affairs Director

FINDING REFERENCE NUMBER 2024-008 FEDERAL PROGRAMS (ALN – 84.002) ADULT EDUCATION–BASIC GRANTS TO STATES (ALN – 84.027) SPECIAL EDUCATION–GRANTS TO STATES (IDEA, PART B) (ALN – 84.048A) CAREER AND TECHNICAL EDUCATION–BASIC GRANTS TO STATES (PERKINS V) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS V002A210005 (07/01/2021 – 09/30/2023); H027A210003 (07/01/2021 – 09/30/2023); V048A210052 (07/01/2021 – 09/30/2023) COMPLIANCE REQUIREMENT PERIOD OF PERFORMANCE TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA According to the 2 CFR §200 Appendix XI, 84.000-Cross-Cutting Section, all ESEA and other programs as identified in the program documents except subrecipients under Career Technical Education (CTE) – Funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. STATEMENT OF CONDITION For the ALN 84.002, 84.027, and 84.048A, we obtained all the disbursements made during the fiscal year 2023-2024 for the grant awards V002A210005, H027A210003, and V048A210052 which had an ending date by September 30, 2023. For these disbursements we verified that they had purchase orders issued with an effective date on or before September 30, 2023. However, for the population of each program we noted and identified purchases order were issued with an effective date for the month of October 2023, clearly indicating these transactions were been obligated after the Grant Award ending date September 30, 2023. For the ALN 84.002 we noted one (1) purchase order, for the ALN 84.027 we found two (2) purchase orders, and for the ALN 84.048A we noted five (5) purchase orders. QUESTIONED COSTS None. PERSPECTIVE INFORMATION This is a systemic deficiency. The PRDE does not have in place proper documented internal control procedures which could prevent to create and approving a purchase order after the period of performance of an award. STATEMENT OF CAUSE The PRDE lacks a standardized and documented monitoring process in the Budget Area to avoid the registration of any purchase order after September 30, of each year, for any closing grant awards. We corroborated with PRDE that this process is manually performed by one of the accountants in the Budget Department who closes access in SIFDE to create a new purchase order after the period of performance due date. POSSIBLE ASSERTED EFFECT Programs did not comply with this requirement, which could lead to unallowable costs. In addition, an over-expenditure could occur and not properly prevented by PRDE. IDENTIFICATION OF REPEAT FINDING Not previously reported. RECOMMENDATIONS We recommend that the PRDE create and document internal control procedures for reviewing purchase order recorded in the grant award that will end during the current fiscal year in order to ensure that there are not any obligations incorrectly recorded in a closed grant award. In addition, proper procedures should be in place and properly documented in the Budget Division, that prevents a grant continuation open and allows the creation of purchase orders after the period of performance. VIEWS OF RESPONSIBLE OFFICIALS The PRDE acknowledges and accepts the finding. Management recognizes the importance of ensuring that all obligations and expenditures are properly incurred within the authorized period of performance established for each grant in compliance with federal regulations under 2 CFR §200.77 and §200.309. The PRDE has initiated a comprehensive review of the purchase orders (POs) identified in the finding that were obligated after the grant award end date of September 30, 2023. Each program—Adult Education (84.002), Special Education (IDEA, 84.027), and Career and Technical Education (Perkins V, 84.048A)—will evaluate these transactions to determine whether they correspond to allowable and valid obligations incurred during the active grant period. Where applicable and supported by documentation, PRDE will adjust or reclassify the expenses to the appropriate and current grant period. In instances where reassignment to an active grant is not possible, PRDE will identify available state funds to absorb these costs and will process the corresponding reimbursements or journal entries to ensure full compliance with federal requirements. Furthermore, PRDE’s Budget Office, in coordination with the Federal Affairs Office and Finance Office, is in the process of strengthening internal control procedures to prevent the creation of POs after the period of performance. This includes: (i)Automating system controls within the SIFDE accounting system to restrict the creation of POs for grants whose period of performance has expired; (ii)Implement an internal monitoring checklist at the program and budget level to validate the effective date of POs prior to approval; (iii)Establishing a communication between the Budget Office and program offices to ensure that any pending obligations are reviewed and processed before the closeout of the grant period. These corrective actions aim to ensure compliance with federal regulations, strengthen accountability, and enhance the overall effectiveness of the internal control environment related to the management of federal funds. IMPLEMENTATION DATE December 30, 2025 RESPONSIBLE PERSON María de los A. Lizardí Valdés Director Office of Federal Affairs Evelyn Rodríguez Cardé Director of Finance Dr. Jorge L. Acosta Irizarry Auxiliary Secretary of Occupational and Technical Education Dr. Yarilis Santiago Ramos Auxiliary Secretary of Adult Education Enid Díaz Nieves Associate Secretary of Special Education Executive Director

FINDING REFERENCE NUMBER 2024-009 FEDERAL PROGRAMS (ALN – 84.027) SPECIAL EDUCATION – GRANTS TO STATES (IDEA, PART B) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.173) SPECIAL EDUCATION – PRESCHOOL GRANTS (IDEA PRESCHOOL) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.938A) HURRICANE EDUCATION RECOVERY – INMMEDIATE AID TO RESTART SCHOOL OPERATIONS (RESTART) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS H027A220003 (07/01/2022 – 09/30/2023); H027A230003 (07/01/2023 – 09/30/2024); H173A220003 (07/01/2022 – 09/30/2023); H173A230003 (07/01/2023 – 09/30/2024); S938A180002 (04/26/2018 – 09/30/2025). COMPLIANCE REQUIREMENT PROCUREMENT AND SUSPENSION AND DEBARMENT TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 2 CFR Section 200.317, establishes that when conducting procurement transactions under a Federal award, a State or Indian Tribe must follow the same policies and procedures it uses for procurements with non-Federal funds. 2 CFR §200.318(a)(i) establishes that the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. STATEMENT OF CONDITION For the ALN 84.938A Restart program, we selected the same sample determined to audit the compliance requirement activities allowed or unallowed/allowable costs/cost principle of forty (40) disbursements from a population of six hundred eighty-three (683) disbursements to suppliers made during the fiscal year 2023-2024. For these forty (40) disbursements, we evaluated the procurement process, and we found the following deficiencies: For nineteen (19) of the cases, the PRDE did not provide either all the necessary documentation or, in some instances, only partial information, preventing a proper assessment of the procurement process for each authorized disbursement. In relation to the IDEA Cluster Program (ALNs 84.027 and 84.173), we requested a list of all procurement procedures performed related to professional services and direct services to participants. No information was provided related to procurement procedures. In addition, we selected a sample of twenty-five (25) transactions for which a quotation process should have been performed, no evidence of quotation process was provided. This represents a scope limitation. QUESTIONED COSTS None. PERSPECTIVE INFORMATION After we requested all the supporting information related to procurement processes, the PRDE was not be able to provide the basic documentation for the procurement performed during the reasonable period of time. STATEMENT OF CAUSE In relation to the IDEA Cluster, the program performs a procurement process related to specific services for which no evidence of the procurement performed was provided. In addition, quotations for some purchases are performed through the Purchase Department of the PRDE. Evidence of the sample selection was not provided for evaluation For the ALN 84.938A, due to the lack of an adequate archiving process for the documentation of the procurement processes, the evidence could not be provided for our evaluation POSSIBLE ASSERTED EFFECT Due to the lack of filing documentation related to the procurements performed program ALN 84.938A Restart, we were unable to properly ascertain if compliance with the procurement process was performed. In relation to the IDEA Cluster, we were unable to ascertain compliance with the procurement compliance requirements. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2023-007). RECOMMENDATIONS We recommend that the PRDE review its internal control procedures for filings to ensure that all procurement documentation is readily available to any auditor or entity tasked with assessing the procurement process. VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding. The Puerto Rico Department of Education (PRDE) acknowledges that the requested procurement documentation was not fully available at the time of the auditors’ review. However, management made every effort to gather and reconstruct the information for all the selected transactions, and the complete documentation will be available. Furthermore, the PRDE is taking actions to improve the accessibility and organization of procurement files to ensure that all documentation is readily available for review in a timely manner. Internal controls over document retention and filing procedures are being reinforced to prevent recurrence of this situation. It is important to note that the procurement processes followed by the PRDE comply with the applicable requirements established under the Code of Federal Regulations (2 CFR Part 200 – Uniform Guidance). Management remains committed to strengthening its internal controls, ensuring full compliance with federal and state requirements, and maintaining complete and timely documentation to support all procurement activities. IMPLEMENTATION DATE Current Fiscal Year. RESPONSIBLE PERSON María de los A. Lizardi Valdés Office of Federal Affairs Director Edgar Delgado Serrano Office of Federal Affairs Associate Director

FINDING REFERENCE NUMBER 2024-010 FEDERAL PROGRAMS ALL MAJOR PROGRAMS AWARD NUMBERS ALL MAJOR PROGRAMS COMPLIANCE REQUIREMENT REPORTING TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 2 CFR § 200.512 Report Submission, (a) (1) The audit must be completed and the data collection form described in paragraph (b) of this Section and reporting package described in paragraph (c) of this Section must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. STATEMENT OF CONDITION The PRDE did not submit the Data Collection Form and Reporting Package to the Federal Audit Clearinghouse of fiscal year ending June 30, 2024 during the required period. QUESTIONED COSTS None PERSPECTIVE INFORMATION The PRDE was unable to provide a timely financial statement and the Schedule of Expenditures of Federal Awards (SEFA), and related supporting documentation in order to apply required audit procedures. STATEMENT OF CAUSE The PRDE did not have an effective accounting system and procedures to assure that the required financial statement and SEFA, and supporting documentation was made available for audit purposes within the required period established to comply with the Federal regulations. POSSIBLE ASSERTED EFFECT The PRDE did not comply with the submission date required for the Data Collection Form and Reporting Package, this could affect the continuance and new approvals of Federal funds. IDENTIFICATION AS A REPEAT FINDING This is a repeat finding (Finding Reference Number 2023-008). RECOMMENDATION We recommend the PRDE maintain adequate accounting records related to the non-Federal and Federal funds in order to properly prepare the financial statement and SEFA accurately, and in a timely manner. In addition, PRDE needs to implement adequate internal controls procedures in order to ensure that the supporting documentation is available in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the finding. The delay in the submission of the Data Collection Form and Reporting Package to the Federal Audit Clearinghouse for the fiscal year ended June 30, 2024, was primarily due to the timing of the contracting process for the audit firm. To address this issue and ensure full compliance with the federal submission deadlines, PRDE has already completed the contracting process and engaged the external audit firm for the fiscal year 2024-2025. This proactive measure will allow the audit process to begin and be completed within the established timeframe, ensuring that the required reporting package and Data Collection Form are submitted timely to the Federal Audit Clearinghouse. Through this action, PRDE demonstrates its commitment to maintaining compliance with federal audit requirements and improving internal controls over the preparation and submission of financial statements and SEFA schedules. IMPLEMENTATION DATE Current Fiscal Year RESPONSIBLE PERSON Evelyn Rodríguez Cardé Finance Office Director Jullymar Octavianni Vega Subsecretary of Administration

FINDING REFERENCE NUMBER 2024-011 FEDERAL PROGRAMS (ALN – 10.553) SCHOOL BREAKFAST PROGRAM (SBP) – CHILD NUTRITION CLUSTER (ALN – 10.555) NATIONAL SCHOOL LUNCH PROGRAM (NSLP) – CHILD NUTRITION CLUSTER (ALN – 10.559) SUMMER FOOD SERVICE PROGRAM FOR CHILDREN (SFSP) – CHILD NUTRITION CLUSTER U.S. DEPARTMENT OF AGRICULTURE AWARD NUMBERS 241PR300306B (07/01/2023 – 06/30/2024); 241PR300306N (07/01/2023 – 06/30/2024); 241PR300306S (07/01/2023 – 06/30/2024) COMPLIANCE REQUIREMENT REPORTING – FFATA TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA In accordance with 2 CFR Part 170, establishes that recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-Federal entity or Federal agency must report each obligating action to http://www.fsrs.gov. For subaward information, report no later than the end of the month following the month in which the obligation was made. STATEMENT OF CONDITION As part of our audit procedures, we interviewed staff responsible for the Child Nutrition Cluster [School Breakfast Program (SBP), National School Lunch Program (NSLP) and Summer Food Service Program for Children (SFSP)] programs, and we were told that they had not submitted the required Federal Funding Accountability and Transparency Act (FFATA) reports during the 2023-2024 fiscal year. QUESTIONED COSTS None PERSPECTIVE INFORMATION During the fiscal year, the PRDE awarded approximately sixty-one (61) awards [thirty-seven (37) under the National School Lunch Program (NSLP) and the School Breakfast Program (SBP), and twenty-four (24) under the Summer Food Service Program for Children (SFSP)] that exceeded the $30,000 reporting threshold subject to the FFATA requirements. STATEMENT OF CAUSE The PRDE staff were unaware of the requirements related to the Federal Funding Accountability and Transparency Act (FFATA) applicable to the Child Nutrition Cluster programs they manage for that fiscal year ended June 2024. POSSIBLE ASSERTED EFFECT The PRDE is in non-compliance with the requirements to report through the FFATA Subaward Reporting System (FSRS) platform. This condition does not allow for the transparency that this report requires. IDENTIFICATION AS A REPEAT FINDING This is a repeat finding (Finding Reference Number 2023-009). RECOMMENDATION We recommend management to provide training and technical assistance to the personnel they designate to monitor all the funds delegation contracts that meet the requirements to be reported on the FSRS portal, and to be able to keep track of when they had to be reported, the date in which they submitted the information to the portal, and all the elements required to be submitted on the platform. VIEWS OF RESPONSIBLE OFFICIALS In response to the finding regarding the untimely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports, the Puerto Rico Department of Education (PRDE) acknowledges the observation made by the auditors. While the audit notes that program staff were unaware of the FFATA reporting requirement, we would like to clarify that the staff was aware of the requirement; however, the program was in the process of gathering the necessary data and ensuring a full understanding of the report components and submission procedures in order to comply accurately with the federal guidelines. Nevertheless, PRDE recognizes that this does not justify the delay in the submission of the reports. To prevent future occurrences, PRDE is currently developing and scheduling a comprehensive training for all program and fiscal staff involved in the Child Nutrition Cluster. This training will cover the FFATA reporting requirements, data collection procedures, submission timelines, and documentation standards to ensure full and timely compliance with the reporting process moving forward. PRDE will continue strengthening internal controls and monitoring procedures to ensure that all applicable FFATA reports are submitted accurately and on time in the FSRS portal. IMPLEMENTATION DATE December 30, 2025 RESPONSIBLE PERSON Odalis Menard AESAN Director Lourdes García Santiago AESAN Sub-Director

FINDING REFERENCE NUMBER 2024-012 FEDERAL PROGRAM (ALN 84.287) TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS S287C190039C (07/01/2019 – 09/30/2020); S287C200039C (07/01/2020 – 09/30/2021); S287C220039C (07/01/2022 – 09/30/2023) COMPLIANCE REQUIREMENT SUBRECIPIENT MONITORING TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA In accordance with 2 CFR § 200.332(f), pass-through entities are required to monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes and in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. This includes reviewing subrecipient Single Audit reports to determine whether any audit findings related to the subaward exist and whether appropriate corrective actions are being taken. STATEMENT OF CONDITION As part of our audit procedures, we obtained the list of subrecipients active during the fiscal year 2023-2024, monitoring visit schedules and disbursements made. We selected a sample of three (3) subrecipients to test compliance with internal control policies and compliance with the subrecipient monitoring requirement. We noted the following deficiencies during our tests: 1. For three (3) subrecipients, we did not find any evidence of the receipt of the Single Audit Report or the required financial statements and special Agreed-Upon Procedure Report. 2. For three (3) subrecipients, we were unable to review the performance reports submitted by the subrecipients during the fiscal year because no documentation was provided for our evaluation. 3. The monitoring plan for the fiscal year 2023-2024 was not provided for our evaluation. QUESTIONED COSTS None PERSPECTIVE INFORMATION The PRDE does not maintain an internal control process that provides reasonable assurance of complying with the requirement of receipt, evaluation and issuance of management decisions as required by Federal regulations and the required corrections of any findings and disposition of questioned costs within the required timeframes of the Federal regulations from audit or monitoring process. STATEMENT OF CAUSE The PRDE did not have formal procedures in place to ensure timely collection and review of subrecipients’ Single Audit Report. Responsibilities for this function were not clearly assigned, and monitoring activities were inconsistently documented. POSSIBLE ASSERTED EFFECT Failure to review subrecipient Single Audit Reports increases the risk that audit findings or noncompliance at the subrecipient level may go undetected and unaddressed. This may lead to improper use of Federal funds and noncompliance with Federal requirements. IDENTIFICATION AS A REPEAT FINDING Not previously reported. RECOMMENDATION We recommend that the PRDE establish and implement formal procedures to: Identify all subrecipients subject to Single Audit requirements, obtain and review their audit reports in a timely manner, follow up on relevant audit findings, and maintain documentation of all monitoring activities performed. VIEWS OF RESPONSIBLE OFFICIALS The PRDE acknowledges the auditor’s finding. It Is important to note that information requested is available and exists just that it was not provided in a timely manner for evaluation. The PRDE and the area accepts the recommendations and will work on corrective action plans that help mitigate the delay in providing information per auditors’ requests. IMPLEMENTATION DATE None RESPONSIBLE PERSON Luis M. Oppenheimer Rosario Program Coordinator María de los Ángeles Lizardi Valdés Office of Federal Affairs Director