February 10, 2022

Portland Public Schools

account information changes for vendors who are enrolled in the ACH payment program;

however, testing of these controls was not performed.

The objective of the ACH Audit - Phase 2 was to test the internal controls related to the setup of

new vendors to the ACH payment program and making account information changes for vendors

who are enrolled in the ACH payment program.

The Office of Internal Performance Audit has completed the ACH Audit - Phase 2. Based on

the results of testing performed within the scope of the audit, it is our opinion that, overall, the

internal controls over the setup of new vendors to the ACH payment program and making

obtained provides a reasonable basis for our findings, if applicable, and conclusions based on our

audit objective.

We extend our appreciation to the staff within the Finance Department for their assistance and

cooperation during the course of the audit.

We look forward to discussing the report with you at an upcoming Audit Committee

meeting. Thank you for your ongoing support of the Office of Internal Performance Auditing.

In August of 2019, the District experienced a fraudulent transaction attempt through its ACH

payment method in the amount of approximately $2.9 million in District funds. Once the incident

was identified, the District immediately took actions to address the fraudulent attempt and

are prevented.

Deputy Superintendent Claire Hertz requested the District’s Office of Internal Performance Audit

(OIPA) perform the ACH Payment Method Audit post the incident, which the Audit Committee

agreed with. The request was submitted and approved by the Board of Education on October

account information changes for vendors who are enrolled in the ACH payment program;

however, testing of these controls was not performed.

The objective of the ACH Audit - Phase 2 was to test the internal controls related to the setup of

new vendors to the ACH payment program and making account information changes for vendors

who are enrolled in the ACH payment program.

District Accounts Payable management has the primary responsibility to establish, implement,

review. Those standards require that we plan and perform the audit to obtain sufficient,

appropriate evidence to provide a reasonable basis for our findings and conclusions based on

our audit objective. We believe that the evidence obtained provides a reasonable basis for our

The objective of the ACH Audit - Phase 2 was to test the internal controls related to the setup of

new vendors to the ACH payment program and making account information changes for vendors

who are enrolled in the ACH payment program.

ACH bank information since the process was re-started in November 2020 through June

5, 2021.

● Reviewed applicable PPS Accounts Payable Internal Control Narrative.

● Performed tests and analysis of the objective areas to support our conclusions.

Based on the results of the testing performed, overall, we found the District’s internal controls over

follows best practices in design and appear to be working efficiently and effectively to mitigate

potential fraud associated with an ACH payment program and safeguard District funds.