2023-101 Santa Clara Valley Transportation Authority
Improvements Are Necessary to Strengthen Its Project Management and Financial Oversight
Published: June 11, 2024
Audit Recommendations Disclosure
When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor’s assessment of auditee’s response based on our review of the supporting documentation.
Recommendations to the Legislature
Recommendation 1
To ensure that VTA’s appointing powers appoint directors based on their relevant qualifications, the Legislature should amend state law to require that VTA’s appointing powers make public, consistent with applicable privacy protections, their rationales for the appointments they make to VTA’s board, including a description of the appointee’s relevant experience and qualifications related to transit and transportation.
Agency response status
pending
Recommendation 2
To make VTA’s term lengths more consistent with those of its peer transit agency boards and to help increase the overall experience and stability of board membership, the Legislature should amend state law to increase the length of VTA directors’ terms to four years.
Agency response status
pending
Recommendations to Santa Clara Valley Transportation Authority
Recommendation 3
To ensure that VTA’s board is fully informed when approving projects, VTA should update its planning procedures by December 2024 to do the following:
- Establish a threshold for estimated project cost that defines when project planning must include the performance of a cost-benefit analysis.
- Conduct a cost-benefit analysis for all capital projects that meet or exceed that cost threshold.
Agency response tatus
Fully implemented
Date of implementation
Jan. 2025
State Auditor assessment status
Fully implemented
60-Day Agency Response
VTA will define and implement a cost threshold for when a cost-benefit analysis must be completed.
In addition, VTA will continue to follow Caltrans’ Value Analysis process and prepare value analysis studies for projects that are $25 million and higher.
Implementing the recommendation(s) is in process and on schedule.
6-Month Agency Response
In process and on schedule. The Project Administration Manual (PAM) is in its final stages of review and is on target to be completed by the end of December 2024. The PAM includes information on procedures for cost benefit analysis.
In addition, VTA performs cost benefit analyses to assess and determine funding for projects as part of its biennial budgeting process. The proposed projects are subject to these analyses based on criteria (that consider costs and benefits) as defined in Appendix A of the Strategic Capital Investment Plan (SCIP), starting page 49, that was approved by the VTA Board of Directors.
1-Year Agency Response
The Project Administration Manual (PAM) was completed and placed into use in January 2025. It is a living, evolving document, receiving minor enhancements as needed, the most recent being June 5, 2025. The PAM includes information on procedures for cost benefit analysis [pages 62 – 66].
In addition, VTA performs cost benefit analyses to assess and determine funding for projects as part of its biennial budgeting process. The proposed projects are subject to these analyses based on criteria (that consider costs and benefits) as defined in Appendix A of the Strategic Capital Investment Plan (SCIP), starting page 49, that was approved by the VTA Board of Directors
Public Reasoning Behind State Auditor 1-Year Assessment
VTA has established the project cost threshold that we recommended and requires projects above that cost threshold to have a cost-benefit analysis.
Recommendation 4
To help ensure that it develops reliable cost estimates for its capital projects, VTA should, by December 2024, develop procedures that document the methodology for developing its capital project cost estimates, including costs other than those directly related to the design and construction of the project.
Agency response status:
Fully implemented
Date of implementation:
Jan. 2025
State Auditor assessment status:
Fully implemented
60-Day Agency Response
a) VTA will document our methodology for developing our capital project cost estimates including costs for all phases of the project.
b) VTA includes anticipated operating and maintenance costs in our Capital Project Request Forms required for every project and will document the procedures in estimating these costs.
The two component parts for implementing this recommendation are in process and on schedule.
6-Month Agency Response
In process and on schedule. The PAM is in its final stages of review and is on target to be completed by the end of December 2024. The PAM includes a section on the various cost estimates that are to be prepared throughout the life cycle of projects, including guidance on the preparation of capital project cost estimates.
1-Year Agency Response
The Project Administration Manual (PAM) was completed and placed into use in January 2025. It is a living, evolving document, receiving minor enhancements as needed, the most recent being June 5, 2025.
The PAM includes a section on the various cost estimates that are to be prepared throughout the life cycle of projects, including guidance on the preparation of capital project cost estimates [see pages 41 – 62].
Recommendation 5
To help ensure that it develops reliable cost estimates for its capital projects, VTA should, by December 2024, develop procedures that estimate the anticipated operation and maintenance costs for capital projects in development.
Agency response status:
Fully implemented
Date of implementation:
Jan. 2025
State Auditor assessment status:
Fully implemented
60-Day Agency Response
VTA agrees.
a) VTA will document our methodology for developing our capital project cost estimates including costs for all phases of the project.
b) VTA includes anticipated operating and maintenance costs in our Capital Project Request Forms required for every project and will document the procedures in estimating these costs.
Implementation efforts are underway and on schedule.
6-Month Agency Response
In process and on schedule. The PAM is in its final stages of review and on target to be completed by December 2024. The PAM has references to processes for estimating anticipated operational and maintenance costs for different types of projects.
1-Year Agency Response
The Project Administration Manual (PAM) was completed and placed into use in January 2025. It is a living, evolving document, receiving minor enhancements as needed, the most recent being June 5, 2025.
The PAM has references to processes for estimating anticipated operational and maintenance costs for different types of projects [see pages 60 – 62].
Recommendation 6
To help ensure that the board can monitor project costs and schedules, VTA should develop procedures by December 2024 to monitor project costs and schedules against preconstruction estimates and present this information as part of its semiannual report to both the Capital Program Committee and the board. This report should provide status updates on the agency’s existing capital projects and identify deviations from projects’ preconstruction estimates.
Agency response status:
Fully implemented
Date of implementation:
Nov. 2024
State Auditor assessment status:
Partially Implemented, Department did not substantiate its claim of full implementation
60-Day Agency Response
VTA currently monitors project costs and schedule and is currently enhancing its project status reporting to the Capital Program Committee and board. The project budget and schedule at the time of contract award will be monitored and reported, and procedures documenting this process will be developed.
Implementation efforts are underway and on schedule. Enhanced capital project reports are scheduled to be presented at the next VTA Capital Program Committee meeting.
6-Month Agency Response
Completed. At the October 2024 Capital Program Committee (CPC) meeting, VTA’s Engineering and Program Delivery (EPD) Division presented on key performance indicators (KPIs) for budgets and schedules for the EPD Division’s Transit Program (Item 9, page 64) and the Highway Program (Item 8, page 78). This reporting of capital program schedule and budget KPIs will be ongoing and occur regularly at future CPC meetings.
1-Year Agency Response
At the October 24, 2024 Capital Program Committee (CPC) meeting, VTA’s Engineering and Program Delivery (EPD) Division presented on key performance indicators (KPIs) for budgets and schedules for the EPD Division’s Transit Program (Item 7, page 64) and the Highway Program (Item 8, page 78). This same information was provided at the November 7, 2024 VTA Board meeting (see Items 6.5 & 6.6 starting page 125). This reporting of capital program schedule and budget KPIs is ongoing and will occur regularly at future CPC and Board meetings, the most recent installments being the April 28, 2025 CPC meeting (see Items 8 -10, starting page 84) and the May 1, 2025 VTA Board meeting (Items 6.12 – 6.14, starting page 157).
Public Reasoning Behind State Auditor 1-Year Assessment
VTA did not respond to a request for clarification on the measurements it is using to track deviations from preconstruction estimates. Without further information, we cannot confirm that VTA’s practices conform with our recommendation.
Recommendation 7
To ensure that VTA receives stakeholder input on the Strategic Capital Investment Plan (SCIP), the agency should ensure that it presents all subsequent updates to the SCIP to the appropriate advisory committees, solicits their input, and presents that input to the board.
Agency response status:
Not fully implemented
Date of implementation:
By March 2026
State Auditor assessment status:
Pending
6-Month Agency Response
The Strategic Capital Investment Plan (SCIP) update is in process and on schedule, with completion anticipated for late 2025.
1-Year Agency Response
Work on the update of the SCIP is currently underway. The completed call-for-projects for the capital element of VTA’s FY 2026 & FY 2027 Biennial Budget provides the most recent project information needed to update the SCIP.
The capital element of the FY 2026 & FY 2027 Biennial Budget forms the first two years of the SCIP. This item was reviewed and input received at the May 7, 2025, joint workshop of five (5) VTA advisory committees (Item 2.1, starting page 3). Additionally, on June 5, 2025, the VTA Board approved the FY 2026 & FY 2027 Biennial Budget (Item 7.1, starting page 355).
Recommendation 8
To ensure that it more effectively safeguards against a breach of fiduciary duty, VTA should complete the following by December 2024:
- Establish a policy requiring relevant staff, including the secretary’s office, to report to the FPPC those directors who do not submit their Form 700s in a timely manner.
- Establish a process for verifying whether directors have completed their biennial ethics training and following up to remind those who have not done so to complete the training.
Agency response status:
Fully implemented
Date of implementation:
Jan. 2025
State Auditor assessment status:
Fully implemented
6-Month Agency Response
a) VTA staff, in consultation with Santa Clara County Filing Officer, is developing the policy and procedures to ensure timely reporting of Board Member Form 700 non-filers to the Fair Political Practices Commission (FPPC).
b) VTA staff is developing a comprehensive solution that will monitor the submission of Board Member biennial ethics training and that will include a reminder system.
Implementation efforts for these recommendations are underway and on schedule.
1-Year Agency Response
Procedures were developed to document the workflow and requirements for both processes and were placed into operation by the end of January 2025.
Recommendation 9
To help ensure financial viability, VTA should determine by June 2025 the extent to which it can rely on revenue sources that are less uncertain than sales tax revenue. In reaching this determination, VTA should consider taking action to increase its farebox recovery ratio by, for example, raising fares or cutting expenses. VTA should then pursue any additional revenue sources it identifies to the extent possible.
Agency response status:
Fully implemented
Date of implementation:
Dec. 2024
State Auditor assessment status:
Pending, Department did not substantiate its claim of full implementation
60-Day Agency Response
VTA is in the process of finalizing a comprehensive Long Range Financial Plan that will review the viability of all VTA revenues and their sustainability, inclusive of operating cost efficiencies to improve financial metrics such as farebox recovery.
Effort to implement this recommendation are underway and on schedule.
6-Month Agency Response
In process and on schedule. VTA’s comprehensive Long Range Financial Plan was scheduled for initial review by the Governance & Audit Committee at its 12/5/24 meeting, but due to last-minute cancellation of that meeting this item will now be presented for Board consideration at the 1/24/25 and 2/21/25 Board workshops.
1-Year Agency Response
In response to the recommendations outlined in the State Auditor’s report, VTA developed a comprehensive Long-Range Financial Plan (LRFP) in late 2024. This plan has been integrated into the agency’s biennial budget development process and includes a 10-year forecast of all revenues and expenditures. The forecast was reviewed and discussed with the Board during the 2/28/25 VTA Board workshop (Item 2.3, starting page 60). LRFP will be updated periodically to account for the volatility in sales tax revenues, TDA and STA revenues, 2000 Measure A and 2016 Measure B subsidies, and trends in farebox collections. The model highlights the dependency on sales tax as the primary funding source.
VTA staff has also engaged the Board in discussions about identifying additional revenue streams—such as revenues generated from Express Lanes and Transit-Oriented Development (TOD). As these projects and program phases progress toward completion, there is potential to allocate a portion of these revenues to support transit operations.
Public Reasoning Behind State Auditor 1-Year Assessment
VTA did not provide a copy of its LRFP, which would allow us to validate its statements about recommendation implementation.
Recommendation 10
To improve VTA’s forecasts of future financial scenarios, VTA should begin forecasting multiple expense scenarios for its transit fund by December 2024 and use those scenarios to create a projection of expenses to present to the board. Further, it should incorporate into these projections any anticipated increases in operational costs because of capital projects.
Agency response status:
Fully implemented
Date of implementation:
Nov. 2024
State Auditor assessment status:
Pending, Department did not substantiate its claim of full implementation
60-Day Agency Response
VTA is nearly complete in developing a more robust modeling tool to assist in long range financial planning.
The Long-Range Financial Plan will enable VTA to understand the external economic factors and the risk they pose to our major revenue sources, like sales tax. We will be able to run scenarios based on various internal cost assumptions, revenue trends and external economic factors and how they all impact VTA’s fiscal position.
This plan will also address total cost of ownership for capital projects and include assumptions for operating costs related to those projects.
Implementation efforts for this recommendation are underway and on schedule.
6-Month Agency Response
In process and on schedule. VTA’s modeling tool will be included as a component of VTA’s comprehensive Long Range Financial Plan being presented at the 1/24/25 and 2/21/25 Board workshops.
1-Year Agency Response
VTA’s Long-Range Financial Plan (LRFP) was completed in late 2024 and presented as part of the 2/28/25 VTA Board workshop on development of VTA’s FY 2026 & FY 2027 Biennial Budget (Item 2.3, starting page 60).
In alignment with the State Auditor’s recommendation, VTA’s LRFP was designed to support comprehensive scenario planning for the Transit Fund. The LRFP includes the development of multiple financial scenarios that model varying expense trajectories based on economic trends, funding uncertainties, and policy assumptions.
This approach enables VTA to better anticipate and plan for a range of possible futures by incorporating key cost drivers—such as labor, non-labor operations, and capital-related operating impacts—into long-term forecasts. By simulating these different financial outcomes, VTA can more effectively assess potential budgetary pressures and proactively develop strategies to address them. Additionally, the tool identifies potential future budget deficits and serves as a proactive planning resource, enabling VTA to implement targeted cost containment strategies and proactively look for additional revenue sources, when necessary.
The modeling tool was also used to forecast multiple scenarios based on different parameters for the Recommended FY 2026 & FY 2027 VTA Biennial Budget that was adopted by the VTA Board on June 5, 2025 (Item 7.1, starting page 352).
The LRFP is under constant review.
Public Reasoning Behind State Auditor 1-Year Assessment
VTA has not provided evidence of its LRFP or how it informed the budgetary information it presented to its board.
Recommendation 11
To ensure that VTA is consistent in its budget monitoring and oversight, VTA should adopt documented procedures by December 2024 that include, at a minimum, the following:
- A process that VTA will use to examine variances between budgeted and actual amounts of revenues and expenses.
- The use of quarterly variance reports by both the board and VTA staff, and expectations for appropriate actions to be taken when significant deviations are identified.
- Assignments that show which staff will be responsible for performing and reviewing variance analyses, and ensure continuity of these reviews when there is turnover in key management positions.
Agency response status:
Fully implemented
Date of implementation:
Jan. 2025
State Auditor assessment status:
Partially Implemented, Department did not address all aspects of the recommendation
60-Day Agency Response
Although VTA has been following this practice and presenting variance reports to internal stakeholders, finance committees, and the VTA board, we have not had documented procedures guiding the process of quarterly variance reviews with internal divisions.
We are working on finalizing a procedure for the budget office that will document the aforementioned process, use of the reports, and staff responsible for this recommendation.
Implementation efforts for this recommendation are underway and on schedule.
6-Month Agency Response
Although VTA has been following this practice and presenting variance reports to internal stakeholders, finance committees, and the VTA board, we have not had documented procedures guiding the process of quarterly variance reviews with internal divisions.
Development of a procedure for the budget office that documents the aforementioned process, use of the reports, and staff responsible for this recommendation has been completed. However, consideration of this item was recently deferred to the 2/6/25 Governance & Audit Committee (G&A) meeting due to unexpected cancellation of the 12/5/24 G&A meeting.
1-Year Agency Response
This internal procedure (work process) was developed and placed into operation by January 2025.
Public Reasoning Behind State Auditor 1-Year Assessment
The VTA’s procedure does not address the actions to be taken when there are significant deviations identified through quarterly variance reports.
Recommendation 12
To ensure that it is informed about VTA’s performance against key financial indicators, the board should require VTA staff to regularly report on specified financial metrics—including its farebox recovery ratio, trips per revenue hour, and operating cost per revenue hour—beginning in December 2024 or sooner.
Agency response status:
Fully implemented
Date of implementation:
Dec. 2024
State Auditor assessment status:
Partially Implemented, Department did not address all aspects of the recommendation
60-Day Agency Response
VTA is in the process of identifying the various metrics to share and the cadence of reporting. Certain operational metrics, which have financial implications, are presently shared with committees and will be incorporated in full Board reports. It is anticipated that this will be an iterative process as VTA and the Board refine the reporting needs.
Implementation efforts for this recommendation are underway and on schedule.
6-Month Agency Response
VTA is in the process of identifying the various metrics to share and the cadence of reporting. Certain operational metrics, which have financial implications, are presently shared with committees and will be incorporated into full Board reports. It is anticipated that this will be an iterative process as VTA and the Board refine the reporting needs.
This item is in process and on schedule.
1-Year Agency Response
VTA reports on farebox recovery and other key financial metrics in its audited Annual Comprehensive Financial Report (ACFR), the most recent ACFR covering FY 2024 (Farebox Recovery is show on Table 22 on page 3-23). This document was reviewed by the VTA Board at its December 5, 2024 meeting (Item 7.2, starting page 427).
Additionally, in November 2024 the VTA Board approved the 2026/2026 VTA Business Plan (BP) (Item 7.1, starting page 407) that is designed to implement the vision, mission and goals of VTA’s Strategic Plan and be reviewed and updated as needed every six (6) months.
The BP contains several new goals, key performance indicators (KPIs), metrics, targets, and strategies. The detailed goals and KPIs are shown in Appendix B (starting page 12). Reporting on KPI status to the Board is intended to be quarterly, with several key metrics to be reported monthly as part of the GM/CEO’s report at each VTA Board meeting.
It is anticipated that this will be an iterative process as VTA and the Board further refine the reporting needs and cycles for the BP.
Public Reasoning Behind State Auditor 1-Year Assessment
The indicators included in VTA’s business plan do not include all we recommended. Specifically, VTA has not adopted operating cost per revenue hour as an indicator. Our audit found this was a metric that warranted further assessment because VTA’s costs were higher than its peers.
Recommendation 13
To ensure that VTA has a current strategic plan that incorporates best practices, VTA should create a comprehensive strategic plan by December 2025 that includes goals, measurable objectives, strategies, and performance measures to track progress. It should also adopt procedures to ensure monitoring of progress on the strategic plan and regular reporting to the board.
Agency response status:
Not fully implemented
Date of implementation:
Summer 2026
State Auditor assessment status:
Pending
60-Day Agency Response
VTA will prepare a comprehensive strategic plan. VTA staff is developing a work plan and schedule for the development of the five-year strategic plan for Board approval by the end of 2024. The strategic plan will be completed according to the schedule adopted by the Board.
Implementation efforts for this recommendation are underway and on schedule.
6-Month Agency Response
In process and on schedule. An update on Strategic Plan development process, including the draft completion schedule, was provided at the 11/7/24 Board meeting. Per the direction of the Board Chair, the draft implementation schedule for the plan update will be provided to the Board in 2025 for their input.
1-Year Agency Response
An update on the Strategic Plan development process, including the draft completion schedule, was provided at the 11/7/24 VTA Board meeting (Item 6.17, starting page 334).
Following internal and external engagement and the input received, the development process and completion schedule have subsequently been revised slightly, which were most recently presented at the May 7, 2025 joint VTA Advisory Committee workshop meeting (Item 2.2, starting page 162). The current projected completion schedule is Spring – Summer 2026.
Recommendation 14
To help ensure that the CEO is guiding VTA to achieve its goals, the board should formally adopt by June 2025 the new evaluation process for its CEO and amend VTA’s Administrative Code to document the process. The evaluation process should include performance expectations for its CEO based on the agency’s objectives, including the goals in VTA’s most current strategic plan. All subsequent updates to the evaluation process and its goals and metrics should be formally approved by the board.
Agency response status:
Fully implemented
Date of implementation:
Nov. 2024
State Auditor assessment status:
Fully implemented
60-Day Agency Response
Development of a revised evaluation process for the GM/CEO that includes expectations, goals, and performance metrics is underway and any subsequent updates to the evaluation process will be formally approved by the board. In addition, the VTA Administrative Code will be updated accordingly to reflect the revised process.
Implementation efforts for this recommendation are underway and on schedule.
6-Month Agency Response
In process and on schedule. VTA Board approved new evaluation process for Board direct reports on 10/6/24. Corresponding changes to VTA Administrative Code are scheduled for Board approval on 2/6/25.
1-Year Agency Response
The Board approved the new evaluation policy/process for Board direct reports on 10/6/24.
Meeting Agenda: 10-3-24 VTA Board Meeting Agenda (Item 8.3, starts page 349)
Meeting Minutes: 10-3-24 VTA Board Meeting Minutes (Item 8.3, page 14)
Corresponding changes to VTA Administrative Code were approved by the VTA Board on 3/6/25.
Meeting Agenda: 3-6-25 VTA Board Meeting Agenda (Item 6.7, starts page 239, Section 2.2)
Meeting Minutes: 3-6-25 VTA Board Meeting Minutes (Item 6.7, page 7 of 15)