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.