Co-Responder Expansion Grant and Contract Compliance

A Denver Police Car Parked on the 16th Street Mall

Objective

To determine whether the Denver Police Department is effectively monitoring Caring for Denver’s Co-Responder Expansion grant and contract expenditures, whether it is compliant with grant and contract requirements, and the extent to which it verifies the accuracy and reliability of the data WellPower uses for annual reports.

Background

In 2018, voters approved a 0.25% sales and use tax increase to fund behavioral health services for city residents. The Police Department receives this grant funding via the Caring for Denver Foundation and contracted with WellPower to implement the Co-Responder Expansion Program to provide behavioral and mental health support to Denver residents. Both the Police Department and the Department of Public Safety oversee the grant and contract.

Why this matters

Not complying with grant and contract requirements jeopardizes future funding for the Police Department’s Co-Responder Expansion Program. This could hinder the program’s goals of reducing the use of emergency services by frequent users and increasing treatment and care services, such as those related to substance use, employment, and supportive housing.

Findings

Finding 1 - The Denver Sheriff Department Does Not Have a Strategy for Its Mental Health Programs
 

The department’s decentralized mental health programs lack an overarching strategy, and it has not clearly defined what success means for all programs. The programs also lack oversight. Meanwhile, one program appears inequitable because it is offered only to men.

Finding 2 - The Denver Sheriff Department’s Data Processes Should Be Improved

The department needs to improve its data tracking for evaluating mental health programs and services. Also, it is not reliably tracking and evaluating individuals’ requests and complaints while in custody. Meanwhile, the department uses paper medical charts and manual data entry, which may complicate both mental health services and continuity of care.

Recommendations

1.1 Establish Secure Document-Sharing Procedures – The Denver Police Department and Department of Public Safety should work with WellPower and the city’s Technology Services agency to identify a secure way to transfer invoices and supporting documentation. WellPower should notify designated department staff of file transfers, and department staff should confirm receipt until both parties are confident that documents are being sent and received on time.

Agency Response: Agree, Implementation Date – June 20, 2022


1.2 Calculate and Pay Overdue Interest – The Denver Police Department and Department of Public Safety should work with the city’s Finance Department to identify the prompt-pay interest the city owes WellPower from late invoice payments. Once the amount owed is identified, the department should work with WellPower to determine an agreed-upon amount owed and pay this amount to WellPower from a funding source other than the grant. If WellPower agrees to waive any amount of interest owed, the decision should be documented.

Agency Response: Disagree


1.3 Follow City’s Records Retention Policy – The Denver Police Department should work with the Department of Public Safety to ensure it complies with the city’s records retention policy related to invoice supporting documentation.

Agency Response: Agree, Implementation Date – June 20, 2022


1.4 Develop Succession Planning – The Denver Police Department and the Department of Public Safety should develop and document formal succession plans for all positions related to grant and contract management to ensure the departments can continue to comply with the grant and contract if key staff leave.

Agency Response: Agree, Implementation Date – March 1, 2022


1.5 Determine Indirect Costs – The Department of Public Safety and the Denver Police Department should work with the city’s Finance Department to:

  • Identify another source of funding to make up for the 20-percentage-point difference in the indirect cost rate between the grant agreement and the contract with WellPower.
  • Reimburse the grant award for the amount of indirect costs the department has overcharged the grant.

Agency Response: Agree, Implementation Date – Aug. 1, 2022


1.6 Deduct Program Income – The Department of Public Safety and the Denver Police Department should work with the city’s Finance Department to determine whether the program income WellPower received should be deducted from the direct costs or the total costs, including both direct and indirect costs.

Agency Response: Agree, Implementation Date – Dec. 15, 2022


1.7 Support Program Income – The Department of Public Safety and the Denver Police Department should ensure WellPower is providing documentation to support monthly program income (e.g., the amount billed to and paid by insurance) along with other invoice supporting documentation for future invoices.

Agency Response: Agree, Implementation Date – Sept. 1, 2022


1.8 Clarify Contract Language – Because the Co-Responder Program is funded on an annual basis, the department should work with the City Attorney’s Office to formalize the program’s indirect costs and program income deduction approach in future contracts related to the program to ensure clarity and fairness for both the city and the service provider.

Agency Response: Agree, Implementation Date – Nov. 30, 2022


1.9 Reimburse Travel Expenses – The Denver Police Department and the Department of Public Safety should identify another source of funds to cover travel reimbursements for the Co-Responder Program’s outreach case coordinators. Once identified, the Police Department should use this to reimburse the 2020 Caring for Denver Co-Responder Program grant for the $4,427.84 in unallowable travel costs.

Agency Response: Agree, Implementation Date – Aug. 16, 2022


1.10 Allocate Costs for Respective Grant Periods – The Denver Police Department and Department of Public Safety should work with the city’s Finance Department to identify and implement an appropriate accounting practice to allocate expenses to correct grant award periods.

Agency Response: Agree, Implementation Date – July 1, 2022


1.11 Use the Workday Grant Management System – The Denver Police Department and the Department of Public Safety should be trained on and use the city’s grant management function in Workday, the city’s system of record, to help manage and monitor the Co-Responder Expansion Program grant for compliance and for accounting awareness of grant expenses.

Agency Response: Agree, Implementation Date – Nov. 30, 2022

 

1.12 Update Interest Earnings –  The Denver Police Department and the Department of Public Safety’s point of contact with the city’s Budget and Management Office and Controller’s Office should ensure they are receiving monthly notifications related to grant interest earnings. The responsible party should then update the Workday budget-to-actual report accordingly.

Agency Response: Agree, Implementation Date – July 26, 2022


1.13 Close the Grant and Return Unspent Funds – The Denver Police Department and Department of Public Safety should close the 2020 Caring for Denver grant for the Co-Responder Expansion Program and return the unspent money — including interest earned — to the Caring for Denver Foundation.

Agency Response: Agree, Implementation Date – Sept. 15, 2022


1.14 Establish Grant Oversight – The Denver Police Department and the Department of Public Safety should identify an individual or individuals responsible for monitoring grant compliance and ensuring deliverables and milestones are met.

Agency Response: Agree, Implementation Date – July 19, 2022


1.15 Establish Contract Oversight – The Denver Police Department and the Department of Public Safety should identify an individual or individuals responsible for monitoring contract compliance and performance.

Agency Response: Agree, Implementation Date – June 19, 2022


1.16 Provide Grant and Contract Management Training – The Denver Police Department and the Department of Public Safety should ensure individuals responsible for oversight are sufficiently trained on grant and contract management.

Agency Response: Agree, Implementation Date – Nov. 30, 2022


1.17 Document Grant-Monitoring Policies and Procedures – The Denver Police Department and the Department of Public Safety should establish and document policies and procedures focused on ensuring grant compliance. These should identify roles and responsibilities related to grant management as well as processes for ensuring all deliverables — such as annual reports and milestones — are completed and that project meetings are documented.

Agency Response: Agree, Implementation Date – Oct. 31, 2022


1.18 Document Contract-Monitoring Policies and Procedures – The Denver Police Department and the Department of Public Safety should establish and document policies and procedures focused on ensuring contract compliance, including WellPower’s compliance with contract requirements. These policies and procedures should include identifying roles and responsibilities related to contract management as well as developing processes for ensuring all deliverables, such as due-diligence reviews and risk assessments, are completed and that project meetings are documented.

Agency Response: Agree, Implementation Date – Oct. 31, 2022


1.19 Complete Sole-Source Justification – The Denver Police Department and the Department of Public Safety should ensure any sole-source justification documentation for WellPower is completed and kept in future contract agreements with WellPower.

Agency Response: Agree, Implementation Date – Aug. 18, 2022


1.20 Conduct and Document a Subrecipient Risk Assessment and Due Diligence Review – The Denver Police Department and the Department of Public Safety should conduct a subrecipient risk assessment and due-diligence review of WellPower to comply with the contract.

Agency Response: Agree, Implementation Date – Aug. 16, 2022


1.21 Prepare and Submit Complete and Accurate Annual Reports – The Denver Police Department and the Department of Public Safety should prepare and submit accurate annual reports to the Caring for Denver Foundation as required by grant agreements. The reports should align with the grant budget as well as the final expenditures generated from the city’s financial system of record, Workday.

Agency Response: Agree, Implementation Date – Aug. 15, 2022


2.1 Develop and Document Policies and Procedures for Data Entry – The Denver Police Department should work with WellPower to develop and document policies and procedures for data entry related to the department’s Co-Responder Expansion Program.

Agency Response: Agree, Implementation Date – Dec. 15, 2022


2.2 Develop and Document Quality Assurance Reviews – The Denver Police Department should work with WellPower to develop and document quality assurance processes for data related to the department’s Co-Responder Expansion Program to ensure it is reliable and accurate.

Agency Response: Agree, Implementation Date –Dec. 15, 2022


2.3 Finalize Data-Sharing Agreement – The Denver Police Department and WellPower should finalize the proposed data-sharing agreement with WellPower to allow the department to access and review individual-level data in addition to the aggregate data already provided.

Agency Response: Agree, Implementation Date – Dec. 31, 2022


2.4 Monitor Program Data – The Denver Police Department should periodically monitor the data it collects about its Co-Responder Expansion Program to ensure program measures and objectives are being met and to make decisions related to programmatic changes.

Agency Response: Agree, Implementation Date – Sept. 1, 2022

Auditor's Letter

September 15, 2022

We audited the Caring for Denver Co-Responder expansion grant and contract managed by the Denver Police Department and Department of Public Safety to determine the agencies’ compliance with requirements. I now present the results of this audit.

The audit found the Police Department and Public Safety are not sufficiently managing the grant or contract for the Co-Responder Expansion Program. We also found the Police Department is not ensuring the contractor’s data used to report on program success is reliable and accurate.

By implementing recommendations for stronger contract and grant monitoring, both departments will be better able to ensure grant and contract requirements are being met and funding is being used appropriately to help people.

I am disappointed the Police Department and Public Safety chose to disagree with a recommendation that would clearly demonstrate department leadership understood and wanted to correct the negative operational impact on WellPower when the city did not pay multiple invoices on time. Further explanation is in the Auditor’s Addendum on page 39.

This performance audit is authorized pursuant to the City and County of Denver Charter, Article V, Part 2, Section 1, “General Powers and Duties of Auditor.” We conducted this performance audit in accordance with generally accepted government auditing standards. 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 objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

We appreciate the leaders and team members from the Denver Police Department, Public Safety, the Department of Finance, and WellPower who shared their time and knowledge with us during the audit. Please contact me at 720-913-5000 with any questions.

Denver Auditor's Office

Auditor's Signature
Timothy O'Brien, CPA
Denver Auditor


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AUDITOR TIMOTHY O'BRIEN, CPA
Denver Auditor



Denver Auditor´s Office

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