EIN: 756027740
UEI: Y3M7AGRYEFF3
Audited by: Sutton Frost Cary LLP
Oversight agency: 21 [Department of the Treasury]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 1, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 1, 2025 (590 days ago).
What is a management decision? →During testing of procurement, the auditors noted that the Organization did not have a process to obtain price quotes for vendors that exceeded the micro‐purchase threshold. The Organization had two material procurement transactions charged to the grant. Cause: Organization was unaware of federal procurement requirements. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with federal procurement requirements. Recommendation: Procedures should be implemented to obtain price quote documentation for covered transactions that exceed the micro‐purchase threshold. This documentation should be kept on file for all covered transactions. Management’s response: See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023‐001: Procurement – material weakness in internal controls over compliance and compliance finding. 21.027: Coronavirus State and Local Fiscal Recovery Funds Criteria: Section 200.320 of the Code of Federal Regulations requires non‐federal entities to obtain an adequate number of price quotes from qualified sources for acquisitions of property or services when the aggregate dollar amount exceeds the micro‐purchase threshold but does not exceed the simplified acquisition threshold. Condition: During testing of procurement, the auditors noted that the Organization did not have a process to obtain price quotes for vendors that exceeded the micro‐purchase threshold. The Organization had two material procurement transactions charged to the grant. Cause: Organization was unaware of federal procurement requirements. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with federal procurement requirements. Recommendation: Procedures should be implemented to obtain price quote documentation for covered transactions that exceed the micro‐purchase threshold. This documentation should be kept on file for all covered transactions. Management’s response: See corrective action plan.
Explanation: SFC's audit of Brother Bill’s Helping Hand highlighted non-compliance with Section 200.320 of the Code of Federal Regulations, which mandates non-federal entities to obtain multiple price quotes from qualified sources for acquisitions exceeding the micro-purchase threshold but not the simplified acquisition threshold. Analysis: While acknowledging SFC’s regulatory interpretation, BBHH management maintains that the federal grant was intended to sustain ongoing programs, negating the necessity to competitively procure counseling services or other third-party vendors. Actions Taken: BBHH, though initially unaware of the bidding requirement and not prompted by Dallas County, which endorsed the ongoing program approach, commits to implementing competitive bidding practices for future federal grants of similar magnitude. This proactive step ensures compliance with federal guidelines and enhances transparency in vendor selection. Responsibility: Wes Keyes, CEO of Brother Bill’s Helping Hand, assumes accountability for overseeing and implementing the revised procurement procedures. Timeline: Immediate adjustments will be made to institute competitive bidding processes for forthcoming grants of comparable scale, ensuring adherence to regulatory frameworks. Monitoring: BBHH anticipates that the revised bidding protocols will sufficiently address compliance concerns, obviating the need for additional monitoring measures. This plan ensures that Brother Bill’s Helping Hand aligns with federal requirements while upholding its commitment to effective grant management and program continuity.
During allowable cost testing for federal grants, 6 out of the 24 invoices tested did not have documented approval from management. Cause: The Organization did not have a standard procedure in place to document management’s approval for credit card transactions prior to payment. Effect: The Organization’s reporting of allowable cost is not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls related to documentation of approval for all credit card transactions prior to payment. Management’s Response: See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023‐002: Allowable costs – Material weakness in internal control over compliance. 21.027: Coronavirus State and Local Fiscal Recovery Funds Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance with cost principles for all transactions charged to the grant. Condition: During allowable cost testing for federal grants, 6 out of the 24 invoices tested did not have documented approval from management. Cause: The Organization did not have a standard procedure in place to document management’s approval for credit card transactions prior to payment. Effect: The Organization’s reporting of allowable cost is not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls related to documentation of approval for all credit card transactions prior to payment. Management’s Response: See corrective action plan.
Explanation: The audit conducted by SFC of Brother Bill’s Helping Hand identified noncompliance with Section 200 of the Code of Federal Regulations, which mandates recipients to establish robust internal controls ensuring adherence to cost principles for all grantrelated transactions. Among the sampled invoices for allowable costs under federal grants, 6 out of 24 lacked documented approval from management. Furthermore, the organization lacked a standardized procedure for documenting management approval of credit card transactions prior to payment. Analysis: Brother Bill’s Helping Hand acknowledges the non-compliance with Section 200 as identified by SFC. However, we maintain that the assertion implying absence of controls or standardized procedures for credit card expenditures is inaccurate. Each reimbursement submission to Dallas County undergoes meticulous scrutiny and personal vetting by CEO Wes Keyes. Mr. Keyes reviews every receipt before reimbursement and, if necessary, consults with the respective staff members regarding any discrepancies. Each reimbursement bears Mr. Keyes’ signature of approval. Nonetheless, SFC has recommended that CEO Keyes review and approve the credit card statement prior to payment, a practice not previously adhered to by BBHH. Actions Taken: Effective June 17, 2024, Mr. Keyes will review and sign each credit card statement prior to payment. These signed statements will be securely stored for potential future documentation needs. Responsibility: CEO Wes Keyes and Operations Manager Sarah Cienfuegos are responsible for implementing the change requiring CEO approval on credit card transactions prior to payment. Timeline: The corrective action has been implemented as of June 17, 2024. Monitoring: No ongoing monitoring is deemed necessary as the corrective measures have already been executed.
FAC accepted this audit on May 30, 2023 — management decision was due November 30, 2023.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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