Audit Report

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Syringe Access and Sharps Disposal Programs

The objective of our audit was to assess whether the Denver Department of Public Health and Environment provides effective management and oversight of its syringe access and sharps disposal programs and to assess the extent to which the department measures progress and ensures the programs’ success.

Denver’s Department of Public Health and Environment is dedicated to improving the city’s environmental and public health. The department oversees many services and has six divisions.

The department’s Community and Behavioral Health Division oversees most of the city’s substance and opioid misuse prevention and treatment programs — such as the syringe access and sharps disposal programs — primarily by administering contracts with community providers. The syringe access and sharps disposal programs seek to reduce harm for people who use drugs and to reduce harm for the community at large by providing access to sterile injection equipment and safe disposal options.

The Department of Public Health and Environment Could Better Manage Its Syringe Access and Sharps Disposal Programs, and It Could Better Assess whether the Programs Are Effective in Reducing Harm

The Department of Public Health and Environment should improve strategies for data management and program evaluation — particularly regarding needs assessment, data collection, periodic evaluation, and documentation of evaluation results used to inform its decision-making.

The department could coordinate more effectively with the syringe access providers to assess the success of the program in reducing harm for people who use drugs or inject substances.

The department should also take steps to improve its program management practices to determine the effectiveness of the syringe access and sharps disposal programs. The department should assess these programs to determine the extent to which the people who need these services are actually receiving them.

1.1 Review and Document Critical Program Activities – The Department of Public Health and Environment should review all critical syringe access and sharps disposal program oversight activities and ensure these processes are documented, communicated, and accessible to all staff involved in oversight, so the department can improve consistency of oversight activities, protect against the effects of staff turnover, and allow for more effective coordination of oversight activities.

Agency Response: Agree, Implementation Date Dec. 31, 2020

1.2 Determine Sufficiency of Allocated Resources – Once processes are documented in accordance with Recommendation 1.1, the Department of Public Health and Environment should conduct a formal staffing review and analysis to determine whether the current scope of the syringe access and sharps disposal programs are sufficiently staffed. The department should consider making changes either to scope or staffing levels as appropriate.

Agency Response: Agree, Implementation Date Dec. 31, 2020

1.3 Develop and Conduct a Needs Assessment – The Department of Public Health and Environment should leverage existing data and identify new data to inform a formal needs assessment that estimates the amount and location of Denver residents who need syringe access and sharps disposal services. This assessment should be updated periodically or biannually, in accordance with available resources and leading practices.

Agency Response: Agree, Implementation Date Dec. 31, 2020

1.4 Collect and Report Standardized, Comparable, and Meaningful Program Data – The Department of Public Health and Environment should ensure it collects standardized, comparable, and meaningful (i.e., relevant, reliable, and complete) data regarding program operations. This should include holding program providers accountable for reporting comparable data by providing technical assistance to program providers and partners on data definitions and collection methods, as well as identifying other data necessary to develop key performance indicators for the syringe access and sharps disposal programs.

Agency Response: Agree, Implementation Date Dec. 31, 2020

1.5 Evaluate Program Performance and Incorporate Results in Decision-Making – The Department of Public Health and Environment should evaluate program processes and determine outcomes to assess program performance, identify barriers, and develop solutions. In accordance with leading practices, this evaluation should be conducted periodically on a defined timeline, involve stakeholders in design and reporting, and serve as the foundation for ongoing quality improvement and management decision-making. The department should document those decisions to further inform program progress.

Agency Response: Agree, Implementation Date Dec. 31, 2020

1.6 Develop Communication Protocols – The Department of Public Health and Environment should

develop formal communication protocols with internal and external partners to inform and improve program evaluation and program performance. This should include involving providers, division personnel within Public Health and Environment, and other city partners — such as Denver 311, the 911 Emergency Communications Center, and the Parks and Recreation Department — in identifying and revising data collection, reporting, and program evaluation processes as relevant to program needs.

Agency Response: Agree, Implementation Date Dec. 31, 2020

1.7 Develop and Document Policies and Procedures – The Department of Public Health and Environment should develop and document policies and procedures and implement those to ensure it appropriately monitors contract compliance. These policies should clarify and formalize roles within Public Health and Environment related to the syringe access program providers.

Agency Response: Agree, Implementation Date Dec. 31, 2020

1.8 Review City Ordinance – The Department of Public Health and Environment should identify the appropriate stakeholders to gather the necessary information and feedback to determine whether the existing syringe access ordinance is appropriate. If the department determines the ordinance is not, the department should document those suggested changes and work through the appropriate channels to advocate for changing the ordinance.

Agency Response: Agree, Implementation Date Dec. 31, 2020

The objective of our audit of the City and County of Denver’s syringe access and sharps disposal programs was to assess whether the Department of Public Health and Environment provides effective management and oversight to help ensure the programs’ success. I am pleased to present the results of this audit.

The audit revealed gaps in Public Health and Environment’s strategies for data management and program evaluation of both programs, including its documentation of key oversight practices. The audit also
found Public Health and Environment should improve its contract monitoring processes to hold providers accountable with contract terms, and it should assess whether laws for the syringe access program are too restrictive or outdated. If unaddressed, these risks could lead to inefficient allocation of city resources and an inability to determine the program’s success at reducing harm and connecting people to other health services.

By implementing recommendations for documented policies, data management, and collaboration with program partners, the Department of Public Health and Environment will be better equipped to measure, monitor, and ensure the success of its syringe access and sharps disposal programs, as well as the people the programs serve.

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 extend our appreciation to the personnel at the Denver Department of Public Health and Environment and the syringe access program providers who assisted and cooperated with us during the audit. For any questions, please feel free to contact me at 720-913-5000.

Follow-up report

A follow-up report is forthcoming. 

Audit Team: Katja E. V. Freeman, Jared Miller, Catherine Friday, Ronald F. Keller, Kristin McCormack
Methodological Support: Samuel Gallaher