Finding 1222567 (2025-004)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-06-30

AI Summary

  • Core Issue: The PRDE made incorrect payroll payments totaling $3,756,580, including $241,467 for employees not working on Federal programs.
  • Impacted Requirements: Compliance with 2 CFR Section 200.403(g) on cost documentation and prevention of improper payments.
  • Recommended Follow-Up: PRDE should establish better internal controls and payroll processes to catch errors in real-time.

Finding Text

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.

Corrective Action Plan

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 (ALN 10.553, 10.555, 10.559, 10.582, 84.010, 84.027, 84.425D, 84.425U. The PRDE recognizes that the recoup procedures established in the "Manual de Procedimiento de Nómina" are in place; however, the Department acknowledges that the detail of Accounts Receivable shows $3,756,580 corresponding to invoices generated during the audit year. The PRDE is working with the existing manuals, along with the new changes being implemented, to strengthen the recoup process for these overpayments. As such, the PRDE has implemented several procedures which have helped in this collection process. The PRDE is committed to strengthening its documentation practices and internal oversight mechanisms to ensure full compliance with 2 CFR § 200.403(g) and other applicable federal requirements. The PRDE further acknowledges that this is a repeat finding (prior year Finding 2024-005) and accepts the auditors’ recommendation to establish and implement formal procedures to obtain and review subrecipient audit reports in a timely manner, follow up on relevant audit findings, and maintain documentation of all monitoring activities performed IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Giovanni Siarez Deputy Director of Payroll Wilfredo Falcón Negrón Human Resources Area Director Office Time Attendance & Leave Evelyn E. Rodríguez Cardé Finance Director

Categories

School Nutrition Programs

Other Findings in this Audit

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

Programs in Audit

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