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Deloitte & Touche LLP 361 South Marine Corps Drive Tamuning, GU 96913-3911 USA Tel: (671)646-3884 Fax: (671)649-4932 www.deloitte.com May 29, 2009 Dr. Nerissa Bretania Shafer Superintendent of Education Guam Public School System Government of Guam: We have performed an audit of the financial statements of the governmental activities, each major fund, and the aggregate remaining fund information of the Guam Public School System (GPSS) as of and for the year ended September 30, 2008, in accordance with auditing standards generally accepted in the United States of America ( generally accepted auditing standards ) and have issued our report thereon dated May 29, 2009. We have prepared the following comments to assist you in fulfilling your obligation to oversee the financial reporting and disclosure process for which management of GPSS is responsible. OUR RESPONSIBILITY UNDER GENERALLY ACCEPTED AUDITING STANDARDS AND GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS Our responsibility under auditing standards generally accepted in the United States of America and standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States, have been described in our engagement letter dated September 30, 2008. As described in that letter, the objective of a financial statement audit conducted in accordance with the aforementioned standards is: To express an opinion on the fairness of each opinion unit in GPSS s basic financial statements and the accompanying supplementary information, and to disclaim an opinion on the required supplementary information for the year ended September 30, 2008 in conformity with accounting principles generally accepted in the United States of America ( generally accepted accounting principles ), in all material respects; To express an opinion on whether the supplementary information that accompanies the basic financial statements is presented fairly, in all material respects, in relation to the basic financial statements taken as a whole; To report on GPSS s internal control over financial reporting and on its compliance with certain provisions of laws, regulations, contracts, and grant agreements and other matters for the year ended September 30, 2008 based on an audit of financial statements performed in accordance with the standards applicable to financial audits contained in Government Auditing Standards; and To report on GPSS 's compliance with requirements applicable to each major federal program and on internal control over compliance in accordance with the U.S. Office of Management and Budget (OMB) Circular A-133 Compliance Supplement (OMB Circular A-133). Member of Deloitte Touche Tohmatsu

Our responsibilities under generally accepted auditing standards include forming and expressing an opinion about whether the financial statements that have been prepared by management with the oversight of the Office of the Superintendent are presented fairly, in all material respects, in conformity with generally accepted accounting principles. The audit of the financial statements does not relieve management or the Office of the Superintendent of their responsibilities. We considered GPSS s internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of GPSS s internal control over financial reporting. Accordingly, we do not express an opinion on the effectiveness of GPSS s internal control over financial reporting. Our consideration of internal control over financial reporting would not necessarily identify all deficiencies in internal control over financial reporting that might be significant deficiencies or material weaknesses. ACCOUNTING ESTIMATES Accounting estimates are an integral part of the financial statements prepared by management and are based on management s current judgments. Those judgments are normally based on knowledge and experience about past and current events and on assumptions about future events. Significant accounting estimates reflected in GPSS s 2008 financial statements include management s estimate of the allowance for uncollectible accounts, which is determined based upon past collection experience and aging of the accounts, and management s estimate of depreciation expense, which is based on estimated useful lives of the respective capital assets. During the year ended September 30, 2008, we are not aware of any significant changes in accounting estimates or in management s judgments relating to such estimates. AUDIT ADJUSTMENTS AND UNCORRECTED MISSTATEMENTS As the result of our audit work, we identified matters that resulted in audit adjustments that we believe, either individually or in the aggregate, would have a significant effect on GPSS s financial reporting process. Such proposed adjustments, listed in Appendix I, have been recorded in the accounting records and are reflected in the 2008 financial statements. Those proposed adjustments that were not recorded by management are also included in the schedule described in the next paragraph. In addition, we have attached to this letter, as Appendix II, a summary of uncorrected misstatements aggregated by us during the current engagement and pertaining to the latest period presented that were determined by management to be immaterial, both individually and in the aggregate, to the financial statements taken as a whole. SIGNIFICANT ACCOUNTING POLICIES GPSS s significant accounting policies are set forth in Note 1 to GPSS s 2008 financial statements. During the year ended September 30, 2008, there were no significant changes in previously adopted accounting policies or their application, except for the following pronouncements adopted by GPSS: GASB Statement No. 45, Accounting and Financial Reporting by Employers for Postemployment Benefits Other Than Pensions, which establishes standards for the measurement, recognition, and display of other postemployment benefits expense/expenditures and related liabilities, note disclosures, and, if applicable, required supplementary information in the financial reports of state and local governmental employers. GASB Statement No. 48, Sales and Pledges of Receivables and Future Revenues and Intra- Entity Transfer of Assets and Future Revenues, which establishes criteria that governments will use to ascertain whether certain transactions should be regarded as a sale or a collateralized borrowing, and includes a provision that stipulates that governments should not revalue assets that are transferred between financial reporting entity components.

GASB Statement No. 50, Pension Disclosures an amendment of GASB Statements No. 25 and 27, which more closely aligns the financial reporting requirements for pensions with those for other post-employment benefits. The implementation of these pronouncements did not have a material effect on the financial statements of GPSS. OTHER INFORMATION IN THE ANNUAL REPORTS When audited financial statements are included in documents containing other information such as GPSS s 2008 Annual Report, we will read such other information and consider whether it, or the manner of its presentation, is materially inconsistent with the information, or the manner of its presentation, in the financial statements audited by us. We will read the other information in GPSS s 2008 Annual Report and will inquire as to the methods of measurement and presentation of such information. If we note a material inconsistency or if we obtain any knowledge of a material misstatement of fact in the other information, we will discuss this matter with management and, if appropriate, with the Board. DISAGREEMENTS WITH MANAGEMENT We have not had any disagreements with management related to matters that are material to GPSS s 2008 financial statements. CONSULTATION WITH OTHER ACCOUNTANTS We are not aware of any consultations that management may have had with other accountants about auditing and accounting matters during 2008. MANAGEMENT S REPRESENTATIONS We have made specific inquiries of GPSS s management about the representations embodied in the financial statements. Additionally, we have requested that management provide to us the written representations GPSS is required to provide to its independent auditors under generally accepted auditing standards. We have attached to this letter, as Appendix III, a copy of the representation letter we obtained from management. MAJOR ISSUES DISCUSSED WITH MANAGEMENT PRIOR TO OUR INITIAL ENGAGEMENT OR RETENTION Throughout the year, routine discussions were held or were the subject of correspondence with management regarding the application of accounting principles or auditing standards in connection with transactions that have occurred, transactions that are contemplated, or reassessment of current circumstances. In our judgment, such discussions or correspondence were not held in connection with our retention as auditors. SIGNIFICANT DIFFICULTIES ENCOUNTERED IN PERFORMING THE AUDIT In our judgment, we received the full cooperation of GPSS s management and staff and had unrestricted access to GPSS s senior management in the performance of our audit. CONTROL-RELATED MATTERS We have issued a separate report to you, also dated May 29, 2009, containing certain matters involving GPSS s internal control over financial reporting that we consider to be significant deficiencies under standards established by the American Institute of Certified Public Accountants, and on its compliance with certain provisions of laws, regulations, contracts, and grant agreements and other matters.

* * * * * * * * This report is intended solely for the information and use of GPSS, the management of Guam Public School System and the Office of the Public Auditor of Guam and is not intended to be and should not be used by anyone other than these specified parties. We wish to thank the staff and management of GPSS for their cooperation and assistance during the course of this engagement. Very truly yours,