Affordable Housing Follow-Up

The Department of Housing Stability fully implemented two recommendations made in the original audit report. However, the department only partially implemented four others, and it has not taken sufficient steps to address the risks 13 other recommendations had sought to resolve.

The department is better able to monitor property managers’ compliance with income requirements to make sure affordable housing is used for those who need it most. Also, the department is complying with city fiscal rules for system integration. Through its comprehensive policies and procedures, the department is set up to successfully implement and manage the prioritization program.

Remaining Risks

The recommendations the department did not fully implement — including the two recommendations it did not agree to implement — present several lingering risks. Among them:

• The Department of Housing Stability is still not providing sufficient oversight over Denver Housing Authority and its intergovernmental agreement known as “DHA Delivers for Denver Program” — or D3. As a result, the housing authority is not building the required number of units for people earning less than 80% area median income and is not held accountable for providing required information to the department.
• The department is still not following city processes for amending agreements before changing the requirements for the contractor.
• Without a formal staffing analysis, the department does not understand the number of staff it needs to accomplish department goals and objectives and to complete inspections on affordable housing. Furthermore, without formally documenting a responsible party, it remains unclear what role the department has in overseeing the quality and safety of affordable housing through inspections.
• By not including Denver Labor early in the contract process, the department risks not complying with federal, state, and local wage laws to ensure people are paid their appropriate wage.

Auditor's Letter

January 8, 2026

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 November 2023 we audited the Department of Housing Stability and found risks involving oversight of Denver Housing Authority, contract compliance, affordable housing inspections, and data reliability. The Department of Housing Stability agreed to implement 17 of our 19 recommendations by June 30, 2024.

We recently followed up and found the department fully implemented only two recommendations. Four recommendations were partially implemented, but 11 recommendations were not.

Although Housing Stability has made some progress in managing its prioritization policy and documenting income verification procedures, it did not fully address most of 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 did not update the status of the two recommendations the department did not agree to implement, as we presume it took no action toward implementing those. We include these recommendations in this report as a reference.

We appreciate the leaders and team members in the Department of Housing Stability 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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