Homeless Encampments

A trash truck parked next to a homeless encampment on the sidewalk.

Objective

To determine how well the city’s processes for encampment enforcement and the services it provides to people experiencing homelessness at encampments are effective, compliant with laws, and equitable.
To assess whether the city effectively designed its homeless encampment response program to achieve its mission, goals, and responsibilities.
To evaluate how well the city tracks spending related to encampments and monitors contractors.

Background

Several city agencies and contracted service providers are involved in responding to homeless encampments in the City and County of Denver. In addition to enforcing city laws and conducting health and safety assessments, the city provides outreach to connect people to services before the city cleans up an encampment site.

Why this matters

If city leaders do not adequately track expenses and keep reliable data for the city’s activities related to encampment response — including for enforcement, outreach, and cleanup — they cannot assess the effectiveness of their efforts, be transparent with Denver residents, or ensure cleanups are performed equitably and that services are provided to all people experiencing homelessness.

Findings

FINDING 1 – The city lacks sufficient procedures and reliable data to ensure people experiencing homelessness who live in unauthorized encampments are treated equitably and lawfully

While the city meets most requirements overall, it is not fully compliant with a recent settlement agreement that outlined requirements for encampment removal and cleanups.
The city cannot ensure people experiencing homelessness have equitable access to services or their stored personal belongings.

FINDING 2 – The city is not tracking expenses related to homeless encampments or sufficiently monitoring invoices and contract performance

The city does not have a formal process to track costs for homeless encampment-related efforts.
The city lacks sufficient monitoring over homeless encampment-related contractor.

FINDING 3 – A draft city plan needs improvement to effectively guide city agencies in their responsibilities over unauthorized encampment

While the city met with stakeholders to discuss program needs, it did not conduct a formal assessment or develop policies and procedures for all agencies involved in encampment response, including for enforcement and outreach.

FINDING 4 – The city’s encampment response program may not be appropriately staffed to achieve its goals and responsibilities

The Mayor’s Office did not conduct an analysis to identify the resources needed for the Unauthorized Encampment Response Program.

Recommendations

1.1 Establish and document roles and responsibilities – The Department of Transportation & Infrastructure should establish and document roles and responsibilities — either in a contract or elsewhere — for the department and its contractor to evaluate and dispose of property collected and stored in the city’s storage facility.

Agency Response: Agree, Implementation Date – June 30, 2023

1.2 Develop and document policies and procedures for property storage compliance – The Department of Transportation & Infrastructure should work with its contractor to develop policies and procedures for ensuring compliance with the Lyall Settlement regarding property storage and disposal. Policies and procedures should include how and where the department and its contractor will consistently document collection and disposal dates for property as well as when and how property will be disposed of. Transportation & Infrastructure should document a City Attorney’s Office review of the policies and procedures to ensure they comply with legal requirements.

Agency Response: Agree, Implementation Date – June 30, 2023

1.3 Develop and document policies and procedures for property storage data – The Department of Transportation & Infrastructure should work with its contractor to develop policies and procedures for inputting, tracking, and monitoring property storage data. Transportation & Infrastructure should document a City Attorney Office review of the policies and procedures to ensure they comply with legal requirements.

Agency Response: Agree, Implementation Date – June 30, 2023

1.4 Monitor property storage data – The Department of Transportation & Infrastructure should periodically monitor property storage data to ensure it supports compliance with legal requirements. It should document these periodic reviews and provide feedback to its contractor, as necessary

Agency Response: Agree, Implementation Date – June 30, 2023

1.5 Develop and document policies and procedures for providing notice at regular cleanups – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop policies and procedures to provide the required 48 hours’ notice for unattended personal property found at its regular citywide cleanups in compliance with the Lyall Settlement. It should also document a City Attorney’s Office review of the policies and procedures to ensure they comply with legal requirements.

Agency Response: Agree, Implementation Date – June 30, 2023

1.6 Develop and document policies and procedures for employee training – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with all agencies responsible for homeless encampment cleanup and response to develop and document policies and procedures for ensuring staff complete required trainings, including those required by the Lyall Settlement.

Agency Response: Agree, Implementation Date – July 31, 2023

1.7 Monitor compliance with employee training – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with all agencies responsible for homeless encampment cleanup and response to develop and document a process to monitor compliance with employee training requirements, including those required by the Lyall Settlement.

Agency Response: Agree, Implementation Date – July 31, 2023

1.8 Follow the city’s records retention policy – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with city agencies responsible for providing and monitoring training to ensure compliance with the city’s records retention policy related to preserving training documentation.

Agency Response: Agree, Implementation Date – July 31, 2023

1.9 Update city webpage – The City Attorney’s Office should work with responsible agencies to ensure the city’s website contains, at a minimum, all information required by the Lyall Settlement and that the information is accurate so people experiencing homeless can be easily informed of where and how to retrieve their personal belongings.

Agency Response: Agree, Implementation Date – April 3, 2023

1.10 Continue developing centralized data tracking – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should continue developing a centralized database for the encampment response teams to help provide consistent and centralized data tracking at encampment sites.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.11 Identify consistent method for location tracking – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with agencies to identify and adopt a consistent method for tracking location data, such as latitude and longitude coordinates.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.12 Develop and document policies and procedures for outreach data – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop policies and procedures for data input, tracking, and monitoring for outreach data. The policies should include what data should be tracked, such as location, services provided, and demographic information.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.13 Monitor outreach data – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should periodically monitor outreach data to ensure accuracy and identify trends. It should document these periodic reviews and revise policies and procedures as necessary.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.14 Develop and document policies and procedures for cleanup and assessments data – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop policies and procedures for data input, tracking, and monitoring of its cleanup and assessments data.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.15 Monitor cleanup and assessments data – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should periodically monitor cleanup and assessments data to ensure accuracy. It should document these periodic reviews and revise policies and procedures as necessary.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.16 Conduct a needs assessment – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should conduct a needs assessment to determine the most appropriate location for one or more property storage facilities as well as appropriate hours of operation to ensure equitable access by people experiencing homelessness. The city should consider transportation needs and options as part of its assessment. The contract with the city’s property storage service provider should be amended as necessary to align with changes to property storage hours and location.

Agency Response: Agree, Implementation Date – April 1, 2024

1.17 Document long-term property storage process – The Department of Transportation & Infrastructure should work with its contractor to document the process for when property can be moved from the main storage facility to long-term storage. Transportation & Infrastructure should document a City Attorney Office’s review of the policies and procedures to ensure they comply with legal requirements.

Agency Response: Agree, Implementation Date – June 30, 2023

1.18 Provide equitable access to information – The city should go above and beyond the Lyall Settlement’s requirements by providing information related to cleanups and property storage equitably to people who have limited English proficiency or who have a disability. The city can conduct a language assessment, create a language access plan, or perform a comparison with other cities to identify an appropriate way to determine which languages it should use for communication. This process should be documented in policy and procedure.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.19 Provide consistent communication – The Department of Transportation & Infrastructure should work with the City Attorney’s Office to revise notices at encampment sites to clearly state how long property will be kept at both the main storage facility as well as long-term storage. Notices should clarify that a person may have to visit the main storage facility more than once to retrieve any belongings being held off-site.

Agency Response: Agree, Implementation Date – April 20, 2023

2.1 Identify expenses to track – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with city agencies to determine how encampment-response expenses should be calculated and should identify which expenses should be included.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.2 Develop an expense tracking method – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop a method for tracking homeless encampment expenses, such as, but not limited to, using Workday tags.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.3 Develop and document expense-tracking policies and procedures – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop and document policies and procedures for calculating annual encampment response-related expenses to ensure consistency across city agencies. Policies and procedures should be included in the program management plan.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.4 Establish oversight of invoices – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with agencies involved with encampment response to identify a person within each agency to be responsible for reviewing and approving invoice payments — including reviewing supporting documentation — for encampment-related contracts used by multiple city agencies to ensure expenses are allowable and that the contractor fulfills contractual requirements.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.5 Develop and document invoice policies and procedures – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with city agencies with encampment-related contracts to develop policies and procedures for requesting, reviewing, and maintaining supporting documentation for invoice payments to ensure invoices are paid according to contract requirements.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.6 Establish contract and master purchase order oversight – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with city agencies involved with encampment response to identify a person within each agency to be responsible for monitoring contract and master purchase order compliance and performance of contractors for encampment-related contracts and purchase orders used by multiple city agencies.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.7 Develop and document contract monitoring policies and procedures – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should work with city agencies with encampment-related contracts and master purchase orders to develop policies and procedures for monitoring compliance and performance.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.8 Follow the city’s records retention policy – City agencies responsible for invoice payment and contract monitoring should comply with the city’s records retention policy related to invoice supporting documentation.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

2.9 Ensure security services are provided – The Department of Transportation & Infrastructure and the Department of Public Health and Environment should identify and implement a method to ensure adequate security services are provided during all hours the property storage facility is open to the public in compliance with the Environmental Hazmat Services contract.

Agency Response: Agree, Implementation Date – March 1, 2023

3.1 Document program need – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should document the need for the Denver Unauthorized Encampment Response Program, including a formal assessment of risks and stakeholder input, to inform the draft program management plan.

Agency Response: Agree, Implementation Date – July 1, 2023

3.2 Establish timeline for goals – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop a timeline for achieving all program goals.

Agency Response: Agree, Implementation Date – Oct. 31, 2023

3.3 Develop performance metrics for goals – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop performance metrics for all program goals.

Agency Response: Agree, Implementation Date – Oct. 31, 2023

3.4 Develop and document cleanup prioritization criteria – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should develop and document criteria for systematically determining how to prioritize encampment cleanups.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

3.5 Update and finalize the draft program management plan – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should update its draft program management plan to identify all responsible parties, document policies and procedures for all agencies and teams involved in encampment response efforts — including enforcement, outreach, and cleanup — and establish a process for ongoing program monitoring. Once the draft plan is revised, the coordinator with the Mayor’s Office should finalize the plan.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

3.6 Monitor program effectiveness – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should use quality data to monitor program effectiveness and progress towards meeting the defined goals and objectives of the program.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

3.7 Revise program management plan as needed – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should revise the Denver Unauthorized Encampment Response Program plan in line with leading practices and after reviewing the results of program monitoring, as necessary.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

4.1 Conduct a staffing analysis – The Denver Unauthorized Encampment Response Program coordinated by the Mayor’s Office should conduct a formal staffing or workforce analysis to identify existing staffing levels across agencies involved in encampment response and determine needs to meet program objectives and goals.

Agency Response: Agree, Implementation Date – Dec. 31, 2024

Interactive Encampments Map

This map shows locations of encampment cleanups, assessments, and outreach that city agencies conducted from Jan. 1, 2022, through June 30, 2022.

How to use it

By hovering over a dot on the map with your cursor, you can view the:

Latitude and longitude or cross-street address, as provided by city agencies.
The distance between each encampment and the city’s main property storage facility.
The number of times an agency visited a location.

Explore the map by clicking on the group names under the filter box. Click on a specific group name to focus on only a single group. For example, if you want to see only the locations of large-scale encampment cleanups, you can click on “Cleanup” in the filter box. This would hide the locations of other types of encampments. To display additional layers, hold down the control button (Ctrl) and click any additional groups. You can also hold down the control button (Ctrl) and click any selected group name to remove them from the map.

Use your mouse to click and drag around the map to view different Denver neighborhoods and scroll the mouse wheel to zoom in and out.

View this map full screen

Data limitations

This map includes only those locations with reported active encampment activity during the time period we audited.

We relied on the addresses as written by city agencies. Therefore, we used our professional judgment to identify the latitude and longitude coordinates and location counts. In some cases, a location could not be determined, so we excluded these addresses from the map.

Read our “Homeless Encampments” audit report to learn about our findings, and see Appendix B of the report for additional information on our analysis.

Auditor's Letter

April 20, 2023

We audited how city agencies respond to homeless encampments to determine whether the city’s process for encampment response — including for enforcement, outreach, and cleanup — are effective, compliant, and equitable. We also assessed whether the city effectively designed its unauthorized homeless encampment response program to achieve its goals. Finally, we analyzed how the city tracks encampment-related spending and monitors contractors. I now present the results of this audit.

In our first multi-agency audit of the city’s response to homeless encampments, we found the city was mostly, but not fully, compliant with laws and a legal settlement and appeared to equitably provide services, conduct assessments, and perform cleanups throughout the city. However, we determined the city needs to do more to ensure people experiencing homelessness have equitable access to stored personal belongings. The city also needs to document policies and procedures for data input and monitoring and responsibilities. And the city needs to identify a consistent way to track encampment-related spending.

By implementing recommendations for stronger policies and procedures and expense tracking, the city will be better able to ensure the encampment response program is helping people experiencing homelessness and conducting assessments and cleanups equitably and lawfully.

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 who shared their time and knowledge with us during the audit — specifically those at the Mayor’s Office, the City Attorney’s Office, Transportation & Infrastructure, Public Health and Environment, Housing Stability, Parks and Recreation, Public Safety, the Denver Police and Fire Departments, and Denver Human Services, as well as those at Environmental Hazmat Services, Inc. Please contact me at 720-913-5000 with any questions.

Denver Auditor

Timothy O'Brien, CPA