Housing Stability does little to fix known shelter oversight issues

Housing Stability does little to fix known shelter oversight issues

Published on May 21, 2026

En español(PDF, 176KB)

DENVER - The Department of Housing Stability remains unaware of how much taxpayer money is being spent for each homeless shelter and whether funds are being used appropriately, according to a follow-up report of the City Shelters audit from Denver Auditor Timothy M. O'Brien, CPA. The department did not fully implement any recommendations and only partially implemented five of the original 15 recommendations. Ongoing risks involving shelter security plans, protecting sensitive information, and invoicing documentation remain.

"Housing Stability has functionally moved the needle since our original audit, but it's not enough. Meaningful improvements are still needed," Auditor O'Brien said.

Expenses and invoice documentation

Housing Stability did not implement our recommendation to routinely track all shelter-related expenses. During our follow-up, we learned of a new department process moving some expense-tracking responsibilities from one internal department division to another, but this is not reflected in any documentation. Also, staff could not provide evidence of training on expense tracking.

The department's updated procedures do not include clear guidelines for how much supporting documentation for invoices should be uploaded to the city's system of record. The procedures do not offer guidance for rejecting invoices with insufficient supporting documentation or how to address issues found during invoice review.

Housing Stability did not update provider invoice submission guidelines, so it risks reimbursing shelter providers for unallowable costs and is unable to hold shelter providers accountable for contract requirements and proper use of city funds.

"It's disappointing to see these problems linger despite our flagging these critical issues in 2024 and providing clear recommendations for reducing these risks. Housing Stability should account for every penny of taxpayer money supporting shelters," said Auditor O'Brien.

Also, a documented process to review invoices for sensitive information is still not in place. Five of 13 invoices we reviewed, or 38%, had sensitive information present, including shelter guests' personally identifiable information One invoice had a shelter provider's bank account number listed several times.

Shelter security

One partial improvement is that the department now requires shelter providers to submit security plans within 90 days of a contract's start. Housing Stability gives shelter providers a security-plan template, but the template does not include any requirements for determining what security measures are needed, like the number of security guards or cameras, or the cost of those measures.

Also, the department has created other new policies for security, but the policies do not outline expectations for when shelters should implement security measures. Housing Stability's implementation of security monitoring policies through quarterly site visits is inconsistent. A risk remains that providers may not have security measures in place before a shelter begins operating.

"While Housing Stability took positive steps to improve security policies, the updates are not enough to ensure timely security measures are implemented or enforced," Auditor O'Brien said.

Other findings

We recommended Housing Stability perform a staffing analysis to find out whether it has enough staff to process invoices. Staff said they had a hiring plan, but after multiple requests, they did not provide documentation supporting this claim.

Risks also remain involving shelter guests who want to file a grievance with a shelter or who are discriminated against.

Of the 15 recommendations from the original audit, we did not review the one recommendation the department did not agree to implement because we presume it took no action to end its new cost-reimbursement policy.

This is the third report we have published in 2026 involving Housing Stability. The other reports were a follow-up of Affordable Housing and an audit of All In Mile High.

"Housing Stability is a focus of recent audits because Denver cares about our unhoused neighbors. The city is accountable for how we fund, implement, and track efforts to support Denver. Our audits have uncovered some serious reoccurring issues that I find concerning," said Auditor O'Brien. "We will continue to monitor the programs and costs the city has allocated for homelessness solutions."

AUDITOR TIMOTHY O'BRIEN, CPA
Denver Auditor

Denver Auditor's Office

201 W. Colfax Ave. #705 Denver, CO 80202
Email: [email protected]
Call: 720-913-5000
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