VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed / Allowable Costs/Cost Principles compliance requirement under the IDEA Special Education Cluster (Assistance Listing ...
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed / Allowable Costs/Cost Principles compliance requirement under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173). The PRDE recognizes that certain deficiencies identified by the auditors relate to inconsistencies in supporting documentation, documentation retained in departmental systems, and the need to strengthen administrative controls over the documentation supporting disbursements for private educational and therapy services. The Department further acknowledges opportunities to improve the consistency of information maintained in supporting schedules, contract documentation, proposals, and other records used during the invoice review and payment process. The PRDE respectfully clarifies that, in several instances identified during the audit, the questioned conditions were attributable to documentation inconsistencies, system-generated reporting errors, or documentation that supports the transactions but was not maintained or presented in a standardized manner during the audit process. Specifically, the Department notes that adjustment reports recorded in the financial system agreed with the disbursement vouchers despite errors identified in certain Excel master schedules; that invoice validations performed by the Centers are based on the corresponding "Carta de Aprobación de Consulta de Ubicación," which establishes the approved services and applicable rates for each student; and that federal regulations authorize IDEA Part B (ALN 84.027) funds to be used for eligible children ages 3 through 21, including expenses otherwise allowable under the Preschool Grant (ALN 84.173), as permitted under 34 CFR §300.202(a). With respect to students identified as over 21 years of age, the PRDE conducted an individual review of the affected student records and determined that the population includes students who exited the program at age 21 as well as students for whom documentation exists supporting the continuation of services through individualized educational determinations, transition planning activities, or compensatory educational services. The Department recognizes, however, that documentation supporting these determinations was not maintained in a standardized manner that facilitated timely retrieval during the audit. The PRDE further acknowledges that improvements are needed to ensure that procurement documentation, contract amendments, proposals, invoice support, Excel master schedules, and student-level supporting documentation are complete, accurate, consistent, and readily available for audit and monitoring purposes. Accordingly, the Department accepts the auditors' recommendations and is committed to implementing corrective actions designed to strengthen internal controls, standardize documentation practices, improve supervisory review procedures, and enhance coordination among the responsible program and administrative units IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Enid Diaz Nieves Executive Director III Alayra Figueroa Gonzalez Associate Secretary for Special Education