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.