Audit 406169

FY End
2025-06-30
Total Expended
$2.12B
Findings
53
Programs
32

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
1222516 2025-001 Material Weakness Yes AB
1222517 2025-001 Material Weakness Yes AB
1222518 2025-002 Material Weakness Yes ABF
1222519 2025-003 Material Weakness Yes B
1222520 2025-003 Material Weakness Yes B
1222521 2025-003 Material Weakness Yes B
1222522 2025-004 Material Weakness Yes AB
1222523 2025-004 Material Weakness Yes AB
1222524 2025-004 Material Weakness Yes AB
1222525 2025-004 Material Weakness Yes AB
1222526 2025-004 Material Weakness Yes AB
1222527 2025-004 Material Weakness Yes AB
1222528 2025-004 Material Weakness Yes AB
1222529 2025-004 Material Weakness Yes AB
1222530 2025-005 Material Weakness Yes F
1222531 2025-005 Material Weakness Yes F
1222532 2025-005 Material Weakness Yes F
1222533 2025-005 Material Weakness Yes F
1222534 2025-005 Material Weakness Yes F
1222535 2025-006 Material Weakness Yes G
1222536 2025-006 Material Weakness Yes G
1222537 2025-007 Material Weakness Yes G
1222538 2025-008 Material Weakness Yes I
1222539 2025-008 Material Weakness Yes I
1222540 2025-009 Material Weakness Yes L
1222541 2025-009 Material Weakness Yes L
1222542 2025-009 Material Weakness Yes L
1222543 2025-009 Material Weakness Yes L
1222544 2025-009 Material Weakness Yes L
1222545 2025-009 Material Weakness Yes L
1222546 2025-009 Material Weakness Yes L
1222547 2025-009 Material Weakness Yes L
1222548 2025-009 Material Weakness Yes L
1222549 2025-009 Material Weakness Yes L
1222550 2025-009 Material Weakness Yes L
1222551 2025-009 Material Weakness Yes L
1222552 2025-009 Material Weakness Yes L
1222553 2025-009 Material Weakness Yes L
1222554 2025-009 Material Weakness Yes L
1222555 2025-009 Material Weakness Yes L
1222556 2025-009 Material Weakness Yes L
1222557 2025-009 Material Weakness Yes L
1222558 2025-009 Material Weakness Yes L
1222559 2025-009 Material Weakness Yes L
1222560 2025-009 Material Weakness Yes L
1222561 2025-009 Material Weakness Yes L
1222562 2025-009 Material Weakness Yes L
1222563 2025-010 Material Weakness Yes L
1222564 2025-010 Material Weakness Yes L
1222565 2025-010 Material Weakness Yes L
1222566 2025-011 Material Weakness Yes M
1222567 2025-004 Material Weakness Yes AB
1222568 2025-010 Material Weakness Yes L

Programs

ALN Program Spent Major Findings
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $541.61M Yes 3
84.027 SPECIAL EDUCATION GRANTS TO STATES $167.15M Yes 6
10.555 NATIONAL SCHOOL LUNCH PROGRAM $116.64M Yes 3
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $79.69M Yes 2
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $76.50M Yes 1
84.938 DISASTER RECOVERY ASSISTANCE FOR EDUCATION $50.29M Yes 3
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $34.23M Yes 3
10.558 CHILD AND ADULT CARE FOOD PROGRAM $33.13M Yes 1
10.553 SCHOOL BREAKFAST PROGRAM $24.17M Yes 3
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $11.64M Yes 1
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $11.28M Yes 2
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $10.36M Yes 3
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $8.25M Yes 1
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $6.00M Yes 0
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $4.97M Yes 5
84.063 FEDERAL PELL GRANT PROGRAM $4.85M Yes 0
84.369 GRANTS FOR STATE ASSESSMENTS AND RELATED ACTIVITIES $4.33M Yes 0
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $3.77M Yes 0
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $2.78M Yes 0
84.041 IMPACT AID $2.53M Yes 0
45.310 GRANTS TO STATES $2.27M Yes 0
10.560 STATE ADMINISTRATIVE EXPENSES FOR CHILD NUTRITION $2.05M Yes 0
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $1.50M Yes 0
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $491,322 Yes 0
84.425 EDUCATION STABILIZATION FUND $404,070 Yes 1
84.013 TITLE I STATE AGENCY PROGRAM FOR NEGLECTED AND DELINQUENT CHILDREN AND YOUTH $175,345 Yes 0
10.541 CHILD NUTRITION-TECHNOLOGY INNOVATION GRANT $166,600 Yes 0
84.033 FEDERAL WORK-STUDY PROGRAM $99,808 Yes 0
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $75,482 Yes 0
93.079 COOPERATIVE AGREEMENTS TO PROMOTE ADOLESCENT HEALTH THROUGH SCHOOL-BASED SURVEILLANCE AND RISK BEHAVIOR REDUCTION $10,000 Yes 0
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $6,205 Yes 2
10.646 SUMMER ELECTRONIC BENEFIT TRANSFER PROGRAM FOR CHILDREN $4,478 Yes 0

Contacts

Name Title Type
TPFNBF5X8UC6 Evelyn Rodríguez Cardé Auditee
7877592000 José E. Díaz Martínez Auditor
No contacts on file

Notes to SEFA

The accompanying Schedule of Expenditures of Federal Awards (“the Schedule”) includes the Federal award activities of the Puerto Rico Department of Education of the Commonwealth of Puerto Rico (PRDE) under programs of the Federal Government for the year ended June 30, 2025. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the PRDE, some amounts presented in this Schedule may differ from amounts presented in, or used in the preparation of, the financial statement. The PRDE reporting entity is defined in Note (1) (A) to the financial statement. All Federal financial awards received directly from Federal agency as well as Federal financial awards passed-through other government agencies, if any, are included on the Schedule.
A. Expenditures reported on the Schedule are reported on the cash basis of accounting, which is Other Comprehensive Basis of Accounting (OCBOA). Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. It is drawn primarily from the PRDE’s internal accounting records, which are the basis for the PRDE’s Statement of Cash Receipts and Cash Disbursements and Net Changes – Governmental Funds (the “Statement”). B. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. C. Pass-through entity identifying numbers are presented where available and applicable.
The PRDE has elected not to use the 10% de minimis indirect cost rate. The amount expended includes $40.6 million claimed as an indirect cost recovery using an approved indirect cost rate of 3.1% for school lunch programs and 3.0% for all other programs based on salaries and wages, including fringe benefits.
The information included in the Schedule may not fully agree with other Federal award reports submitted directly to Federal granting agencies.
The Assistance Listing Number, formerly known as the Catalog of Federal Domestic Assistance (CFDA) Number, is a five-digit number assigned in the awarding document for all Federal assistance award mechanisms, including Federal grants and cooperative agreements.
A cluster of programs means Federal programs with different Assistance Listing Numbers that are defined as a cluster of programs because they are closely related programs that share common requirements. The Schedule includes the following clusters: Cluster Title Federal Program Federal Assistance Listing Number Child Nutrition: School Breakfast Program (SBP) 10.553 National School Lunch Program (NSLP) – Food Donation – Commodities (Non-Cash Assistance) 10.555 National School Lunch Program (NSLP) 10.555 Summer Food Service Program for Children (SFSP) 10.559 Fresh Fruit and Vegetable Program (FFVP) 10.582 Student Financial Assistance: Federal Supplemental Educational Opportunity Grants (FSEOG) 84.007 Federal Work-Study Program 84.033 Federal Pell Grant Program 84.063 Special Education (IDEA): Special Education – Grants to States (IDEA, Part B) 84.027 Special Education – Preschool Grants (IDEA Preschool) 84.173
Expenditures of Federal awards are reported in the PRDE’s Statement of Cash Receipts, Disbursements, and Net Changes – Governmental Funds in the Federal Title I Fund and Other Federal Governmental Funds columns.
The amounts shown as current year expenditures represent only the Federal grant portion of the program costs. Entire program costs, including the state’s portion, are more than shown.
The Schedule includes one program for which receipts and disbursements are in the form of non-cash items. These non-cash items are valued in accordance with the guidelines established by the U.S. Department of Agriculture. This program is not included in the PRDE’s Financial Statement.
A schoolwide program is a comprehensive reform strategy designed to upgrade the entire educational program in a Title I school, its primary goal is to ensure that all students, particularly those who are low achieving, demonstrate proficient and advanced levels of achievement on State academic achievement standards. Schoolwide programs are not separate Federal programs as defined in the Uniform Guidance; amounts used in schoolwide programs are included in the total expenditures of the program contributing the funds in the Schedule. The following program amounts were expended by the PRDE in its schoolwide program: Federal Assistance Listing Number Name of Federal Program Expenditures in the Schoolwide Fund 84.010A Title I Grants to Local Educational Agencies (Title I, Part A of the ESEA) $ 388,790,476 84.365 English Language Acquisition State Grants 4,979,427 84.367A Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 67,019,318 N/A Community School Program – State Funds 710,083,822 $ 1,170,873,043
The Elementary and Secondary Educational Act (ESEA), as amended by Every Students Succeed Act (ESSA), allows a local educational agency (LEA), upon approval by the state education agency, to consolidate and use funds for the administration of one or more programs under this Act (Section 8203 (a)). The main goal for the use of the consolidated funds is administration of the programs included in the consolidation, or the use funds available for administrative activities designed to enhance the effective and coordinated use of funds under programs included in the consolidation. Consolidated funds are not separate Federal programs as defined in the Uniform Guidance; amounts used in consolidated funds, are included in the total expenditures of the program contributing the funds in the Schedule. The following Federal programs amounts were expended by the PRDE in its consolidated fund: Federal Assistance Listing Number Name of Federal Program Expenditures in the Consolidated Fund 84.010A Title I Grants to Local Educational Agencies (Title I, Part A of the ESEA) $ 27,308,166 84.013 Title I State Agency Program for Neglected and Delinquent Chilldren and Youth 699 84.287 Twenty-First Century Community Learning Centers 497,735 84.365 English Language Acquisition State Grants 180,572 84.367A Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2,042,751 84.424A Student Support and Academic Enrichment Program 127,700 84.425U Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 1,813,795 84.425V Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 33,412 84.425W Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 43,619 $ 32,048,449
In early 2020, the U.S. Congress appropriated funds in response to the COVID-19 pandemic. These funds were made possible through the Coronavirus Aid, Relief, and Economic Security (CARES) Act and other supplemental legislation. In March of 2021, additional funds were appropriated through the American Rescue Plan Act. The main goal for the use of the COVID-19 funds is to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the Nation and to help safely reopen and sustain the same operation of schools. To maximize the transparency and accountability of COVID-19 expenditures, governments must separately identify COVID-19 expenditures on the SEFA. This includes the new COVID-19 only programs.
The Single Audit reporting package, as defined and required in 2 CFR 200 for fiscal year ended June 30, 2025, could not be submitted in a timely manner. The Single Audit for fiscal year 2025 has been subject to delays due to difficulties in the collection of financial data, which represented significant amounts in the financial statement. The complexities surrounding the aforementioned matters have demanded additional time for thorough examination, resolution, and documentation to ensure the accuracy and completeness of our Single Audit for the year 2025.

Finding Details

FINDING REFERENCE NUMBER 2025-001 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 H027A230003 (07/01/2023 – 09/30/2024); H027A240003 (07/01/2024 – 09/30/2025); H173A230002 (07/01/2023 – 09/30/2024); H173A240002 (07/01/2024 – 09/30/2025) COMPLIANCE REQUIREMENTS ACTIVITIES ALLOWED OR UNALLOWED // ALLOWABLE COSTS/COSTS PRINCIPLES TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE 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. In addition, IDEA’s Special Education—Grants to States program (IDEA, Part B) provides grants to states, and through them to LEAs, to assist them in providing special education and related services to eligible children with disabilities ages 3 through 21 (20 USC 1411). STATEMENT OF CONDITION As part of our procedures over internal controls and compliance for the allowable activities’ requirement, we selected a sample of eighty-five (85) disbursement to suppliers made during fiscal year under audit. We noted the following deficiencies: 1. In three (3) disbursement vouchers, the Excel master sheet and the adjustment report presented different amounts. No justification was provided for the differences in the reports. 2. In one (1) disbursement we found that the therapy, monthly, and tuition costs per student did not match the contract, which already stipulated a cost for each service per student. We were not presented with any evidence that the contract had been amended; we were only provided with a letter from PRDE approving the cost increase across the board. 3. In forty-three (43) 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 attending and invoiced, according to their age. 4. In five (5) disbursement vouchers related to educational services and therapies, we found in the master Excel spreadsheet of three (3) different entities, participants ranging in age from 22 to 31 years old were provided educational services. In total, seven (7) students over 21 years of age were identified among the three entities. The amount related to these students is $85,535. 5. In two (2) disbursement vouchers related to educational services in private institutions, three (3) participants were invoiced and paid, who, in accordance with the excel master of each institution, attend to another private institution. 6. In eight (8) disbursement vouchers related to therapies provided by private educational institutions, the costs for therapies are higher than the costs according to the contract fee schedule. 7. In eight (8) disbursement vouchers, no details were provided on how the monthly educational costs were determined. The proposals submitted are inconsistent with the invoices and do not describe the services included in each monthly payment. 8. Of the selected sample, there was one (1) disbursement voucher for which we were not provided with evidence of the master Excel spreadsheet, a document that details each participant, the service provided, the cost of the service, among other information necessary to evaluate the disbursement. The amount paid for this invoice was $568,968. 9. On a disbursement voucher, we noticed that the invoice included 38.5 hours of service. However, the invoice details only showed 36 hours of service rendered, with payment made for 2.5 hours for which no details of the services rendered were provided. The total overpayment to the supplier is $312.50. QUESTIONED COSTS We understand that the $312.50 described in the condition number 9 is not allowable. In addition, because the PRDE was not able to provide the Excel Master spreadsheet for a disbursement voucher, we were unable to audit this transaction. The amount of this voucher is $568,968. In relation to participants who are more than 21 years old, the amount included in the vouchers evaluated is $85,535; for a total estimated amount of $654,815.50. 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. In addition, standardized documentation in the educational services should be maintained which presents clear costs for services provided and reasons for modification of the legal contract, modifying amounts and services, should be available for inspection. The sample was statistically valid sample. 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. No evidence regarding how the PRDE monitors the age of the participants when they reach 21 years of age and properly documents the reasons to continue providing the services after reaching 21 years of age. 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. There is no clear process in place for negotiations with private institutions, nor is there a clear way to determine whether the cost of educational services is reasonable. 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 good were not provided as contracted. The PRDE was not able to present how they are monitoring that the services provided to the participants are reasonable and comply with the necessities of the child. Furthermore, no proper documentation is maintained when services are provided to participants who reach 21 years and are required to provide any service. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2024-002). 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.
FINDING REFERENCE NUMBER 2025-002 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 INTERNAL CONTROL AND COMPLIANCE – SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE 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 activity’s requirement, we selected a sample of forty (40) disbursements from a population of six hundred forty-two (842) disbursements to suppliers made during the fiscal year 2024-2025. During our testing, the following deficiencies were noted: 1. 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 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 This is a systemic deficiency. 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. The sample was statistically valid sample. STATEMENT OF CAUSE 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 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 Yes, this finding is a repeat of a finding reported in the prior audit. The corresponding prior year Finding Number is 2024-003. RECOMMENDATIONS We recommend that the PRDE provides training to all relevant personnel on the importance of accurate accounting and documentation, particularly for equipment purchases, and ensures 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).
FINDING REFERENCE NUMBER 2025-003 FEDERAL PROGRAMS FEDERAL PROGRAMS IN THE CONSOLIDATED FUNDS: (ALN – 84.010A) TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES (TITLE I, PART A OF THE ESSEA) (ALN – 84.287) TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS (ALN – 84.367A) SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS S010S220052 (Fiscal Year: 07/01/2022 – 09/30/2023); S010S230052 (Fiscal Year: 07/01/2023 – 09/30/2024); S010S240052 (Fiscal Year: 07/01/2024 – 09/30/2025) S287C230039A (Fiscal Year: 0701/2023 – 09/30/2024); S287C230039A (Fiscal Year: 0701/2023 – 09/30/2024) S367A230052 (Fiscal Year: 0701/2023 – 09/30/2024); S367A240052B (Fiscal Year: 0701/2024 – 09/30/2025) COMPLIANCE REQUIREMENT ALLOWABLE COSTS/COSTS PRINCIPLES TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE 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 (included in the Consolidated Fund), we selected seven (7) 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 25AP0268 7/29/2024 $ 2,500,000.00 830311-2024-39 7/1/2024 Jun-24 5,421.00 $ 2,500,000.00 $ 672,893.25 $ 337.04 1277646 9/9/2024 2,500,000.00 830311-2024-40 8/1/2024 Jul-24 5,777.00 2,500,000.00 89,160.12 417.32 1281131 9/23/2024 2,500,000.00 830311-2024-41 9/1/2024 Aug-24 6,414.00 2,500,000.00 55,557.56 381.11 1287473 10/11/2024 2,500,000.00 830311-2024-42 10/1/2024 Sep-24 6,082.00 2,500,000.00 142,510.00 387.62 1300722 12/5/2024 2,500,000.00 830311-2024-43 11/1/2024 Oct-24 6,311.00 2,500,000.00 56,081.93 387.25 1301526 1/7/2025 2,500,000.00 830311-2024-44 12/2/2024 Nov-24 5,060.00 2,500,000.00 70,654.00 480.11 1309568 2/14/2025 2,500,000.00 830311-2025-45 1/1/2025 Dec-24 5,302.00 2,500,000.00 60,040.27 460.20 1316767 3/5/2025 2,500,000.00 830311-2025-46 2/1/2025 Jan-25 5,538.00 2,500,000.00 37,906.95 444.58 1324572 3/25/2025 2,500,000.00 830311-2025-47 3/1/2025 Feb-25 4,961.00 2,500,000.00 80,429.52 487.72 1333390 / 1333392 4/25/2025 & 5/6/2025 2,500,000.00 830311-2025-48 4/1/2025 Mar-25 5,260.00 2,500,000.00 58,231.99 464.21 1345009 5/26/2025 2,375,000.00 830311-2025-50 5/1/2024 Apr-25 5,223.00 2,375,000.00 614,961.22 ● 336.98 1356525 6/26/2025 2,375,000.00 830311-2025-51 6/1/2024 May-25 5,187.00 2,375,000.00 229,866.71 413.56 $ 29,750,000.00 $ 29,750,000.00 $ 2,168,293.52 ●This amount include $570,000 of Performance Bond Insurance. 2. Allocability – the payment made was distributed among several Federal programs (Consolidated Funds) and state funds as follows: State Fund CONSOLIDATED FUNDS (SEA/LEA) TOTAL ALLOCATED AMOUNT $ - $ 2,500,000.00 $ 2,500,000.00 - 2,500,000.00 2,500,000.00 - 2,500,000.00 2,500,000.00 - 2,500,000.00 2,500,000.00 2,500,000.00 - 2,500,000.00 2,500,000.00 - 2,500,000.00 2,500,000.00 - 2,500,000.00 2,500,000.00 - 2,500,000.00 2,500,000.00 - 2,500,000.00 195,723.15 2,304,276.85 2,500,000.00 2,375,000.00 - 2,375,000.00 - 2,375,000.00 2,375,000.00 $ 15,070,723.15 $ 14,679,276.85 $ 29,750,000.00 50.66% 49.34% Based on the payment documentation of the evaluated invoices, the allocations were made based on available budget of administrative allocation of Federal awards that “consolidate administration funds of those programs”, the invoices didn't include any basis for the allocation of costs between Federal and non-Federal funds, and no allocation was made to programs that do not consolidated administration funds but benefited from the TPFA process. QUESTIONED COSTS Based on the Criteria 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 $14,679,276.85 as questioned costs for not supported documentation. See also Perspective Information for more support. PERSPECTIVE INFORMATION This is a systemic deficiency. 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. 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 $29,750,000. Of this amount 50.66% were covered with state funds, and 49.34% with consolidated activities administrative funds of Federal Awards of some programs. Some payments were charged completely to state funds or consolidated funds, while others were prorated between the two funding sources without documentation of services provided. 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 in 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 2024-004). RECOMMENDATIONS We recommend 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.
FINDING REFERENCE NUMBER 2025-005 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 H027A220003 (07/01/2023 – 09/30/2023); H027A230003 (07/01/2023 – 09/30/2024); H027A240003 (07/01/2024 – 09/30/2025); H173A230002 (07/01/2023 – 09/30/2024); H173A240002 (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 INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE 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, 2025. 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 $10,356,037.76, classified as programs and licenses, should not be capitalized as equipment because they have a useful life of less than one year. 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. Eight (8) items do not have the assigned person updated. 2. One (1) was not physically observed because is a program license software. 3. Two (2) items don’t have the location updated and no transfer documentation was provided. 4. Two (2) items the description does not agree with the property 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. Seven (7) items do not have the assigned person updated. 2 One (1) item does not have the location updated and no transfer documentation was provided. 3 One (1) item does not have the assigned person and location updated and no transfer documentation was provided. 4 One (1) item does not have the assigned person updated, in addition the property is not in use because it is damaged and no updated in the records was performed to reflect the condition of the property. 5 One (1) of the selected items represents the acquisition of eighty-two (82) air conditioning units for several classrooms and only one (1) property number was assigned to the purchase, therefore all units have the same property number. 6 One (1) of the selected items could not be shown at the location because the custodian is on sick leave. As an alternative procedure, a photograph of the computer/laptop was sent to us as evidence, but it does not show the tag or serial number for validation. We were able to observe that the equipment exists and is in good condition. We selected a sample of forty (40) items for the Restart Program, 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. Seven (7) items do not have the assigned person updated. 2. Twelve (12) items included in the assigned person the name of the public or private school as the custodian. 3. Five (5) items do not have the location updated and no transfer documentation was provided. From these items, four (4) were servers and backup batteries that were purchased through a memorandum of understanding between the PRDE and the Puerto Rico Police Department. The equipment was not in school or in custody of a person from the PRDE, instead it is in custody of a Sargeant of the Puerto Rico Police Department. QUESTIONED COSTS None. PERSPECTIVE INFORMATION This is a systemic deficiency. Each school Principal conducted an equipment count, but it was not reviewed, and not all schools did so. No inventory has been conducted since 2019. The identified deficiencies constitute a systemic problem. Items purchased during fiscal year under audit did not properly identify the custodian, location, description, and no proper tracking of transfer of equipment is maintained in the PRDE. The sampling was a statistically valid sample. STATEMENT OF CAUSE PRDE has not been able to work with the inventory and update it as of June 30, 2025. In addition, the Property Department does not have procedures in place in order to identify incomplete records, unidentified dispositions, or transferred equipment. 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 2024-006). 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.
FINDING REFERENCE NUMBER 2025-006 FEDERAL PROGRAM (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 H027A240003 (07/01/2024 – 09/30/2025); H173A240002 (07/01/2024 – 09/30/2025) COMPLIANCE REQUIREMENT MATCHING, LEVEL OF EFFORT, EARMARKING TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE CRITERIA 34 CFR section 300.163, states for the Maintenance of Effort requirement that a State must not reduce the amount of State financial support for special education and related services for children with disabilities, or otherwise made available because of the excess costs of educating those children, below the amount of that support for the preceding fiscal year. In addition, 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’s 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. STATEMENT OF CONDITION As part of our audit procedures related to the Level of Effort – Maintenance of Effort requirement, we request the Annual State Application for FFY 2024 funds, and the documents that support the information included in the report. The PRDE was unable to provide evidence of the amount reported as State financial support made available for Special Education and related services, used in the computation. QUESTIONED COSTS None. PERSPECTIVE INFORMATION This deficiency is a systemic problem that is related to lack of proper internal controls over financial documentation. The Annual State Application for FFY 2024, PRDE reported $349,659,000 as the amount of State Financial Support made available for Special Education and Related Services for FY2022, in relation to FY2023, the reported amount was $350,153,444, from this amount, $5,624,444 was not provided a detail or supporting documentation. The supported amount was $344,509,000 which is not in compliance with the requirements. STATEMENT OF CAUSE The PRDE does not have an established procedure to collect and archive the documents used to prepare these reports. POSSIBLE ASSERTED EFFECT The PRDE could not be in compliance with the Level of Effort requirement. In addition, the information submitted in the report could not be corroborated for accuracy validation purposes. IDENTIFICATION OF REPEAT FINDING Not previously reported. RECOMMENDATIONS We recommend that the PRDE establishes processes and uniformity in the filing of the documents that support the information reported to the US Department of Education.
FINDING REFERENCE NUMBER 2025-007 FEDERAL PROGRAM (ALN – 84.048) CAREER AND TECHNICAL EDUCATION BASIC GRANT TO STATES (PERKINS V) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS V048220052 (Fiscal Years: 07/01/2022 – 09/30/2023) COMPLIANCE REQUIREMENT MATCHING, LEVEL OF EFFORT, EARMARKING TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE CRITERIA According to the Section 112(b) of Perkins V 20 USC 2322 (b) – A state must match, from nonfederal sources and on a dollar-for-dollar basis, the funds reserved for administration of the state plan. The matching requirement may be applied overall, rather than line-by-line, to state administrative expenditures. As established in the PRDE State Plan, the state administration expenditure would be 5%. STATEMENT OF CONDITION During the performance of our audit procedures to validate compliance with the state funds administrative 5% matching established in the PRDE State Plan, we obtained from PRDE a detail of salary paid to employees during the year 2024-2025, which represented the 5% of administrative matching established in the State Plan. Then, to corroborate payment and the accountability of the salary amounts we requested PRDE to provide the GL-200 Report, which is an internal accounting report of the Government of Puerto Rico. It is used by government agencies to reconcile payroll, related costs, and expenditures of state and Federal funds using the Treasury Department's main system. Since the GL-200 Report was not provided by PRDE, we were unable to validate the disbursement of this administrative 5% matching state funds. This represents an scope limitation. QUESTIONED COSTS None. PERSPECTIVE INFORMATION This is a systemic deficiency. During the performance of our audit procedures to validate the matching requirement, the PRDE used to provide a detail named State Position – Matching Corresponding to the 5% Administration of the Carl D. Perkins Occupational and Technical Education Act. Then we proceeded to request evidence of the corresponding expenditures of this state funds for covering the percentage established for administrative matching in the State Plan. After numerous requests for this evidence, the PRDE was unable to provide this evidence. The amount reported as matching was $1,530,733.68. STATEMENT OF CAUSE Due to the lack of data management performed by the PRDE, the GL-200 Report could not be provided as requested to support the state expenditure for compliance with the 5% matching requirements established in the State Plan. POSSIBLE ASSERTED EFFECT The PRDE being unable to provide evidence documentation (GL-200 Report), could be incurred in non-compliance with the 5% matching requirement as established in the State Plan of the program. This situation could result in a loss of Federal funding. IDENTIFICATION OF REPEAT FINDING Not previously reported. RECOMMENDATIONS We recommend that the PRDE to proper identifies the supporting documentation (GL-200 Report) to properly be able to trace and identify the administrative matching data in order to support the compliance with the 5% matching as established in the State Plan for this program.
FINDING REFERENCE NUMBER 2025-008 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 H027A230003 (07/01/2023 – 09/30/2024); H027A240003 (07/01/2024 – 09/30/2025); H173A230003 (07/01/2023 – 09/30/2024); H173A240003 (07/01/2024 – 09/30/2025); COMPLIANCE REQUIREMENT PROCUREMENT AND SUSPENSION AND DEBARMENT TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE 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 As part of our audit procedures over procurement process, 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 relation to quotation process, we selected a sample of forty (40) transactions for which a quotation process should have been performed. We found the following deficiencies: 1. In one quotation process, we were not provided with the document listing the bidders, evidence of the bidder selection, and the reasons for that selection. 2. In another quotation process, the requisition specifying the goods for which quotations were requested did not correspond to the fiscal year and made no reference to the quotations submitted. In addition, we requested a detailed list of all contracts formalized during the year and financed with IDEA funds. When selecting a sample of twenty-five (25) contracts, we were informed that several were financed with State funds. We requested the list of IDEA program contracts again, but it was not provided. This constitutes a scope limitation. QUESTIONED COSTS None. PERSPECTIVE INFORMATION After we requested all the supporting information related to procurement processes and contracts, the PRDE was not able to provide the basic documentation for the procurement performed and a list of contracts with IDEA funding during a reasonable period of time. This is a systemic deficiency that should properly be corrected, and the information should be available for audit process. The samples were statistically valid samples. STATEMENT OF CAUSE The IDEA program performs a procurement process related to specific services for which no evidence of the procurement performed was provided. The PRDE does not maintain a detail of contracts financed with IDEA funding. In addition, quotations for some purchases are performed through the Purchase Department of the PRDE, and no proper controls over the documentation are maintained POSSIBLE ASSERTED EFFECT Due to the lack of filing documentation related to the procurements performed and formalized contracts, we were unable to ascertain compliance with the procurement and suspension and debarment process. In relation to the quotation process, PRDE is not maintaining proper documentation to demonstrate compliance with procurement. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2024-009). 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.
FINDING REFERENCE NUMBER 2025-009 FEDERAL PROGRAMS ALL MAJOR PROGRAMS AWARD NUMBERS ALL MAJOR PROGRAMS COMPLIANCE REQUIREMENT REPORTING TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE 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, 2025 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. This is a systemic deficiency. On March 2026, PRDE requested a waiver to US Department of Education, establishing why the Single Audit might not be issued on or before the due date, but no response was received. STATEMENT OF CAUSE The PRDE was obtaining all required data for the Programs ALN 97.036 and 14.228; and validating all required information as the Compliance Supplement 2025 and the Uniform Guidance version of 2024 requires. The Compliance Supplement was issued on November 27, 2025, affecting the timing of the SEFA preparation in accordance with the requirements. 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 2024-010). 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 should continue the implementation of internal controls in accordance with the Uniform Guidance.
FINDING REFERENCE NUMBER 2025-011 FEDERAL PROGRAM (ALN 84.287) TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS S287C200039C (07/01/2020 – 09/30/2021); S287C220039C (07/01/2022 – 09/30/2023); S287C220039C (07/01/2022 – 09/30/2023) COMPLIANCE REQUIREMENT SUBRECIPIENT MONITORING TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE 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, complies with the terms and conditions of the subaward, and achieves performance goals. In additions to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by terms and conditions of the award, subaward monitoring must include the following: Reviewing financial and programmatic (performance and special reports) required by PTE, following-up and ensuring that the subrecipients takes timely and appropriate action on all deficiencies pertaining to the Federal award, provide the subrecipient from the PTE detected through audits, on site reviews, and other means, issuing a management decision for audits findings pertaining to the Federal award provided to the subrecipient from the PTE as requires by 2 CFR 200.521(c). STATEMENT OF CONDITION As part of our procedures on subrecipient requirements, based on the subrecipient monitoring procedures established by the PRDE in the “Manual de Programa 21st CCLC”, we requested the risk analysis that established the monitoring plan for a period of three (3) years, this information was not provided for our evaluation. Based on this monitoring plan they established the type of monitoring that they will perform to the subrecipient, site reviews, desk reviews or closing reviews. Based on the terms and conditions of the award all subrecipients are required to submit their Single Audit Reports, for review and evaluation. As part of our audit procedures, we obtained the list of subrecipients active during the fiscal year 2024-2025 with a total of eighteen (18) subrecipients. We selected a sample of four (4) subrecipients to test internal controls and compliance with the subrecipient monitoring requirement related to the submission of Single Audit Reports. During our test we noted the following deficiencies: 1. For one (1) subrecipient the management decision for the audit’s findings reported in the subrecipient Single Audit was not provided for our evaluation. 2. For one (1) subrecipient, they notify that the program expenditures were not included in the entity Schedule of Expenditures of Federal Awards, but no evidence of follow-up about this matter was 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. This is a systemic deficiency. The sampling was a statistically valid sample. STATEMENT OF CAUSE The PRDE did not adequate documentation related to the procedures to comply with the subrecipient monitoring requirements. Although procedures are established in the “Manual de Programa 21st CCLC” no evidence was provided to ensure compliance with the procedures established in the manual. POSSIBLE ASSERTED EFFECT Failure to review subrecipient monitoring requirement 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 This is a repeat finding (Finding Reference Number 2024-012). 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.
FINDING REFERENCE NUMBER 2025-004 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 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 – 84.425D) 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 (10/01/2017 – 09/30/2018); 1PRAEA19SCESUBA (10/01/2018 – 09/30/2019); 1PRAEA20SCESUBA (10/01/2019 – 09/30/2020); 1PRAEA21SCESUBA (10/01/2020 – 09/30/2021); 1PRAEA22SCESUBA (10/01/2021 – 09/30/2022); 1PRAEA23SCESUBA (10/01/2022 – 09/30/2023); 1PRAEA24SCESUBA (10/01/2023 – 09/30/2024); 1PRAEA25SCESUBA (10/01/2024 – 09/30/2025); H027A1200003 (07/01/2020 – 09/30/2021); H027A2200003 (07/01/2022 – 09/30/2023); H027A2300003 (07/01/2023 – 09/30/2024); H027A2400003 (07/01/2024 – 09/30/2025); V048A180052 (07/01/2018 – 09/30/2019); S425D200029 (06/16/2020 – 09/30/2021); S425D210029 (01/05/2021 – 09/30/2022); S425U210029 (03/24/2021 – 09/30/2023) COMPLIANCE REQUIREMENT ACTIVITIES ALLOWED OR UNALLOWED // ALLOWABLE COSTS/COSTS PRINCIPLES TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE 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 $3,756,580. Invoices issued during the fiscal year ended June 30, 2025, balance, were distributed as federal and state, as follows: Assistance Listing Number Program Description Transaction Balance 10.553/ 10.555/ 10.559/ 10.582 Child Nutrition Program Cluster $ 94,915 84.010A Title I Grants to Local Educational Agencies (Title I, Part A of the ESEA) 13,665 84.027 Special Education – Grants to States (IDEA, Part B) 33,798 84.425D COVID-19 Education Stabilization Fund: Elementary and Secondary School Emergency Relief Fund 43,252 84.425U COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) 55,837 Subtotal 241,467 Not Determined Schoolwide Program (State and Federal Funds) 2,106,827 Not Determined Consolidated Funds (State and Federal Funds) 32,730 Not Applicable State Funds 1,375,556 Total Invoices Issued Balance at 06/30/2025 $ 3,756,580 QUESTIONED COSTS Identified questioned costs are $241,467, 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 This is a systemic deficiency. The amount of $3,756,580, corresponds to incorrect payroll payments made from current and prior years, for which during fiscal year 2024-2025, 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 2024-005). 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 2025-010 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 251PR300306B (Fiscal Years: 07/01/2024 – 06/30/2026); 251PR300306N (Fiscal Year: 07/01/2024 – 06/30/2025); 251PR300306S (Fiscal Year: 07/01/2024 – 06/30/2025) COMPLIANCE REQUIREMENT REPORTING – FFATA TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE 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 The audit revealed that the Department did not adhere to the FFATA reporting procedures during the fiscal year. We found that 100% (9 out of 9) required reports were submitted after the required due date. 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. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 0 9 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,954,867 $0 $2,954,867 $0 $0 STATEMENT OF CAUSE The PRDE staff have been implementing corrective actions regarding the compliance with this requirement related to the Federal Funding Accountability and Transparency Act (FFATA); however, some reports related primarily to contract amendments were not filled on a timely manner. POSSIBLE ASSERTED EFFECT The PRDE is in non-compliance with the requirements to report through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FFATA) 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 2024-011). RECOMMENDATION We recommend that the PRDE continue 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.