Auditor’s addendum to agency response for Recommendation 1.1
The intent of this recommendation is not to question whether the Mayor’s Office should address unsheltered homelessness. Rather, it is to highlight that the Mayor’s Office launched the All In Mile High initiative without conducting a formal needs assessment to determine the needs of people experiencing unsheltered homelessness who would enter the program. As discussed in this report, Department of Housing Stability staff said many risks were not addressed and that they remained unclear on whether the city had sufficient resources to achieve the mayor’s stated goals.
Leading practices from United Way emphasize that a needs assessment is a foundational step in program design. A needs assessment helps organizations identify the scope and nature of the problem and helps evaluate whether adequate resources, infrastructure, and operationalcapacity exist to meet program objectives. This process should include consultation with the teams responsible for implementing the work, like Department of Housing Stability staff.
Without conducting a formal needs assessment for All In Mile High, the Mayor’s Office risks not knowing whether it has the necessary resources to meet its goals and whether the program fully addresses the needs of people experiencing unsheltered homelessness. We reaffirm the importance of conducting a needs assessment and this recommendation.
Auditor’s addendum to agency response for Recommendation 1.8
As discussed on page 19, some Department of Housing Stability staff said the Citywide Progress Report dashboard is “unclear” and “misleading” or expressed confusion over what a successful outcome is. We also found at least one news report mistakenly referring to the Citywide Progress Report as All In Mile High’s results.
Leading practices from the U.S. Department of State says communicating program progress creates awareness for the cause, increases public support, and maintains accountability for stakeholders. Also, by counting both permanent and stable housing toward the city’s permanent housing goal, the dashboard does not align with the U.S. Department of Housing and Urban Development’s “2024 HMIS Data Dictionary,” which classifies the city’s stable housing as “temporary housing.” We reaffirm the need for further clarity in the city’s public reporting and our recommendation.
Auditor’s addendum to agency response for Recommendation 1.10
As outlined on page 22, neither the Mayor’s Office nor the Department of Housing Stability have documented policies and procedures for monitoring or evaluating All In Mile High’s success. Staff said they are conducting monitoring, but the monitoring is not documented. As a result, we could not independently verify that the monitoring is actually being performed.
The third-party evaluation — mentioned in the agency response — was not completed before our audit work concluded. Further, in May 2025 Housing Stability staff said the third-party evaluation was not anticipated to be completed for three years. With over a year until the evaluation is expected to be completed, it is crucial the city documents its current monitoring and evaluation process.
The leading practices from the U.S. Government Accountability Office and the U.S. Department of State referenced in this report emphasize the need for ongoing monitoring to help the organization respond to change and to make more informed decisions. While separate, periodic evaluations can provide important feedback on program effectiveness, they do not enable an organization to quickly respond to change like ongoing monitoring does.
We reaffirm our finding and recommendation.
Auditor’s addendum to agency response for Recommendation 1.11
As shown on page 26, the site selection criteria provided did not include consideration of racial and ethnic demographics or income levels. The site selection documents were incomplete, including no formal documentation of how the Mayor’s Office ultimately selected the shelter locations. Mayor’s Office staff said the process for procuring shelter sites constantly changed to meet the mayor’s goals. They also said the selection criteria were not always realistic for achieving the program’s goals.
After the Mayor’s Office reviewed the first draft of this report, staff provided a map of All In Mile High shelter sites with general data on Denver’s racial and ethnic demographics and median household income. However, the Mayor’s Office provided no evidence this data was used to inform shelter site selection. Race and income data was not included in the city’s site selection criteria.
Program guidance from the U.S. Department of State and United Way say the development of new programs should be guided by a needs assessment. A needs assessment allows for clear understanding of what the problem is and any existing gaps in the established system. Also, nationally recognized policy organizations, like the Urban Institute and the Center on Budget andPolicy Priorities, say that decisions related to homelessness resolution should be informed by data specific to people experiencing homelessness and to historically marginalized communities, with specific attention to communities of color.
We reaffirm the need for greater documentation of the site selection process, increased consideration for the communities both served and impacted, and our recommendation.
Auditor’s addendum to agency response for Recommendation 1.12
As noted on page 30, Executive Order No. 8 says any deviations from the standard contract procurement process, like a sole-source contract, need to be formally documented. But the Department of Housing Stability could not provide any documentation to support its claim that no other partners were willing or able to set up and manage a non-congregate shelter.
Also, the Department of Housing Stability could not prove compliance with city procurement requirements. While it provided the identities of the other bidders and scoring sheets to show that Colorado Coalition for the Homeless had the highest score, it could not provide the completed proposals from all bidders. The city cannot be certain the Department of Housing Stability picked the most qualified bidder without the completed proposals from all bidders to review.
The city’s records retention schedule says the city must keep records for accepted bids for seven years and unsuccessful bids for three years after the contract is awarded. Without the required supporting documentation, Housing Stability cannot verify that its contract-procurement process adheres to the city’s competitive procurement rules. The department also did not follow the city’s record retention schedule.
We reaffirm this finding and our recommendation.