Homeless Encampments Follow-Up

The city fully implemented six recommendations made in the original audit report. However, the city partially implemented only 11 others and it has not taken steps to address the risks 11 other recommendations had sought to resolve. We did not review eight recommendations associated with findings 3 and 4 because the Unauthorized Encampment Response Program no longer exists.

Regardless of the program no longer existing, the city took steps to implement recommendations originally assigned to the program such as ensuring compliance with the Lyall Settlement — an agreement that outlined requirements for encampment removal and cleanups — by drafting policies and procedures for providing notice at cleanups and before storing personal items, as well as providing employees with homelessness sensitivity training. Furthermore, the city updated its webpage to provide required information to people experiencing homelessness about how and where to pick up their personal belongings. The city also identified a uniform method for tracking encampment response data. Finally, the city will be better able to track encampment-related expenses using a new tag in its financial system of record once agencies identify which expenses to track.

Remaining Risks

The 22 recommendations the city did not fully implement present several lingering risks. Among them:

• While the city developed comprehensive policies and procedures for property storage, ensuring compliance with the settlement, and employee training, we found issues with the implementation of the policy in all areas. By not following its own policy, the city risks destroying peoples’ property before it is allowed, and staff who work with people experiencing homelessness may not be properly trained.
• The city has still not identified expenses to track related to encampment response and is still not adequately monitoring contracts or reviewing supporting documentation for invoices. This means that the city is not able to be fully transparent about spending for encampment-related efforts and may be paying for services that have not been provided. Without effective contract monitoring, the city may not be ensuring contractors are meeting requirements and that programs are effective.
• While Mayor’s Office staff said they meet with agencies involved in encampment response daily, they have not formally documented their review of outreach, assessment, or cleanup data. Without having a periodic and formalized review process for data accuracy, the Mayor’s Office cannot ensure the data it receives is accurate and reliable to use for decision-making and evaluating trends.
• Additionally, if the city did not consider recommendations related to the Unauthorized Encampment Response Program or its associated draft program management plan when developing and implementing a new program — All in Mile High — the risks we identified in the 2023 audit related to program need, time frames and goals, policies and procedures, and staffing may be present in this new initiative.

Auditor's Letter

March 6, 2025

In keeping with generally accepted government auditing standards and Auditor’s Office policy, as authorized by city ordinance, we have a responsibility to monitor and follow up on audit recommendations to ensure city agencies address audit findings through appropriate corrective action and to aid us in planning future audits.

In April 2023, we audited how city agencies respond to homeless encampments and found risks involving compliance with laws and a legal settlement, equitable access to stored belongings, data input and monitoring, invoice and contract oversight, and encampment expense tracking. The city agreed to implement all 36 of our recommendations.

We recently followed up and found the city fully implemented six recommendations, partially implemented 11, and did not implement another 11 recommendations. I am disappointed that the city has not made much progress in tracking expenses and monitoring contracts related to homeless encampments.

We did not review the eight recommendations related to findings 3 and 4, which centered on the Denver Unauthorized Encampment Response Program and its draft program management plan because the program no longer exists. The program was in place during the previous administration but leaders under the new mayor said the city changed its approach to responding to encampments and people experiencing homelessness by creating a new program — All in Mile High. We plan to audit this new program in the future and will consider the associated risks and recommendations at that time.

Although the city has made some progress, it did not fully address all the risks associated with our original findings. Consequently, we may revisit these risk areas in future audits to ensure the city takes appropriate corrective action.

We appreciate the leaders and team members at the Mayor’s Office, City Attorney’s Office, Transportation & Infrastructure, Public Health and Environment, Housing Stability, Parks & Recreation, Public Safety, the Denver Police and Fire departments, and Denver Human Services, as well as those at Environmental Hazmat Services Inc. who shared their time and knowledge with us throughout the audit and the follow-up process. Please contact me at 720-913-5000 with any questions.

Denver Auditor's Office


Timothy O'Brien, CPA

AUDITOR TIMOTHY O'BRIEN, CPA
Denver Auditor

Denver Auditor's Office

201 W. Colfax Ave. #705 Denver, CO 80202
Email: auditor@denvergov.org
Call: 720-913-5000
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