Finding Text
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