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Response synthesis and audit

Responses to report 2608

BART qualifies multiple financial/service figures and governance interpretations, claims several directions/tools implemented, declines specific service/report-distribution requirements, and promises analysis updates and selected governance/risk work. Implemented labels coexist with conditional future actions, especially code review.

Response by BART Board of Directors

59

Addressed

5

Partially addressed

0

Not addressed

0

Unclear

County's stated disposition

These categories reflect the County's response to each recommendation, separate from this audit's assessment.

4

Implemented

6

Will be implemented

7

Requires further analysis

3

Will not be implemented

0

Unclear

How to read this audit

Editorial engagement review only, not a legal ruling or verification of factual claims, forecast accuracy or completed implementation. Finding scores assess the response’s stated position, reasons and traceability, not agreement with the jury. Each audit selects its unchanged original and physical PDF page. Dates are included only when supplied by the document; undated responses are not assigned inferred dates. Recommendation deadlines are not copied into agency commitments unless independently stated in the answer.

Commitments

Actions stated in the response

These are commitments extracted from the County's response. They describe what the response says will happen; they do not verify that implementation occurred.

17

Extracted commitments

14

Definite or bounded timing

2

Conditional timing

1

No timeframe

BART2608-R1 · Bounded timeframe

Provide Audit Committee an update on this recommendation and its analysis.

By the end of November 2026.

BART2608-R3 · Bounded timeframe

Provide Audit Committee an update on this recommendation and its analysis.

By the end of November 2026.

BART2608-R4 · Conditional timing

Initiate Phase Two Financial Efficiency Review if revenue measure succeeds.

If measure succeeds; comprehensive analysis expected in spring 2028, not guaranteed complete then.

BART2608-R6 · Bounded timeframe

Provide Audit Committee an update on this recommendation and its analysis.

By the end of November 2026.

BART2608-R7 · Bounded timeframe

Distribute video overtime-dashboard training to a broader group of managers and analysts.

By September 2026; response does not supply an exact day.

BART2608-R8 · Bounded timeframe

Continue analysis-based alignment of staffing, overtime and schedules, including audit actions and bargaining.

Targets range through FY2027; no single strategy-completion date stated.

BART2608-R9 · Bounded timeframe

Update ten-year Short Range Transit Plan and submit a draft to MTC.

Begin fall 2026; draft by May 2027. Revenue integration depends on measure outcome and available review recommendations.

BART2608-R10 · Conditional timing

Continue updates to OIG on outstanding span-of-control and overtime actions until completion.

Until all actions completed; target dates range through FY2027.

BART2608-R11 · Bounded timeframe

Provide Audit Committee an update on this recommendation and its analysis.

By the end of November 2026.

BART2608-R12 · Bounded timeframe

Provide Audit Committee an update on this recommendation and its analysis.

By the end of November 2026.

BART2608-R13 · Bounded timeframe

Provide Audit Committee an update on this recommendation and its analysis.

By the end of November 2026.

BART2608-R13 · No timeframe stated

Collaboratively review charters and appropriate organization charts and present recommended revisions to Audit Committee.

No target date stated

BART2608-R16 · Bounded timeframe

Provide Audit Committee an update on this recommendation and its analysis.

By the end of November 2026.

BART2608-R17 · Exact date

Formalize documented risk methodology for FY2028 assessment.

2027-04-01

BART2608-R18 · Exact date

Obtain Audit Committee and Board input for FY2028 risk assessment.

2027-04-01

BART2608-R19 · Bounded timeframe

Draft committee-charter revisions clarifying external-auditor procurement role for committee review and recommendation to Board.

January 2027 committee/Board process; no exact day supplied.

BART2608-R20 · Bounded timeframe

Provide updated Employee Code of Conduct for committee review and discussion.

January 2027 Audit Committee meeting; implemented label does not establish completed review.

Item-by-item review

Findings and recommendations

Assessments describe whether the response engages each cited item. Finding scores separately describe statutory-elements completeness under California Penal Code § 933.05(a) and public usefulness. They do not independently verify the response or constitute a legal conclusion.

Showing 64 of 64 items

finding · BART2608-F1

F1: In FY2019, passenger fares generated $520 million in revenue, covering 66.7% of the Bay Area Rapid Transit District’s (BART) total operating expenses, nearly double the national heavy rail average of 32%, according to Federal Transit Administration National Transit Database data.

Audit: Addressed

Response says

Partially disagrees: NTD systemwide fares were $482.6m/72%; with parking, passenger-generated revenue was $519.6m/77%; heavy-rail averages differ.

Audit analysis

Defines disputed numerator, denominator and comparison universe using NTD reporting; no independent validation of figures.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Defines disputed numerator, denominator and comparison universe using NTD reporting; no independent validation of figures.

Scoring confidence: high

finding · BART2608-F2

F2: BART’s financial model depends on passenger fares for approximately two-thirds of its operating revenue, making the agency vulnerable to sustained declines in ridership.

Audit: Addressed

Response says

Agrees with clarification: FY2027 fares are budgeted at $308m of $387m operating revenue (80%); operating revenue covers 32% of uses.

Audit analysis

Preserves agreement label alongside materially revised percentage and distinct budget-year context.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Preserves agreement label alongside materially revised percentage and distinct budget-year context.

Scoring confidence: high

finding · BART2608-F3

F3: BART’s annual ridership peaked at approximately 132 million trips in FY2016 and declined 5.2% to 128.2 million trips by FY2019, according to BART’s National Transit Database reporting.

Audit: Addressed

Response says

Partially disagrees: NTD peak was 137.7m in FY2016, declining 6.9% to 128.2m in FY2019.

Audit analysis

Directly identifies disputed peak and decline with named dataset. Formal 132m/5.2% wording is retained in inventory.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Directly identifies disputed peak and decline with named dataset. Formal 132m/5.2% wording is retained in inventory.

Scoring confidence: high

finding · BART2608-F4

F4: Ridership had begun declining prior to the pandemic due to factors including lower gas prices, more dispersed job locations, and increased ride-hailing.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F4; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F4; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F5

F5: In FY2025, passenger miles traveled amounted to 44.6% of the FY2019 figure, with year-over-year improvement slowing from 9.0% between FY2022 and FY2023 to 2.3% between FY2024 and FY2025.

Audit: Addressed

Response says

Agrees with clarification but gives NTD recovery of 45.3%, growth of 30% then 7%, and preliminary FY2026 estimate of 896.4m miles.

Audit analysis

Clearly replaces material numeric claims while retaining the source’s label; periods and preliminary status remain distinct.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Clearly replaces material numeric claims while retaining the source’s label; periods and preliminary status remain distinct.

Scoring confidence: high

finding · BART2608-F6

F6: In Fiscal Year (FY) 2025, BART operated 18.5% more service hours than in FY2019 while recording 44.6% of FY2019 passenger miles.

Audit: Addressed

Response says

Agrees with clarification: train revenue hours rose 18.5%, vehicle revenue hours fell 2.5%; cites Berryessa extension and September 2023 service changes.

Audit analysis

Explains differing service units and supplies corrected passenger-mile ratio of 45.3% with named dataset and dated changes.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Explains differing service units and supplies corrected passenger-mile ratio of 45.3% with named dataset and dated changes.

Scoring confidence: high

finding · BART2608-F7

F7: The gap between BART's service hours index and passenger miles index widened from 55.5% in FY2021 to 73.9% in FY2025, with no trend toward closure based on data through FY2025.

Audit: Addressed

Response says

Agrees with clarification: NTD gaps are 55.4 and 73.2 percentage points; rejects this ratio as a sole service-planning basis.

Audit analysis

Identifies revised values and specific planning factors through NTD and Rail Service Plan rather than treating the jury metric as verified performance.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Identifies revised values and specific planning factors through NTD and Rail Service Plan rather than treating the jury metric as verified performance.

Scoring confidence: high

finding · BART2608-F8

F8: Approximately 63% of BART’s FY2025 operating costs are fixed or semi-fixed and do not decline proportionally with service reductions.

Audit: Addressed

Response says

Agrees with clarification: FY2026 service-sensitive categories total $444m/42%, implying about 58% fixed costs.

Audit analysis

Engages cost rigidity while using a different year and classification; does not silently replace formal FY2025 63%.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Engages cost rigidity while using a different year and classification; does not silently replace formal FY2025 63%.

Scoring confidence: high

finding · BART2608-F9

F9: Between FY2019 and FY2021, BART reduced service by approximately 40% while operating costs declined by only approximately 12%, demonstrating that large service reductions produce limited cost savings due to the fixed-cost nature of heavy rail operations.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F9; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F9; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F10

F10: BART’s FY2027 Preliminary Operating Budget, presented to the BART Board of Directors (Board) on March 31, 2026, projects a $375 million structural operating deficit beginning in FY2027.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F10; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F10; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F11

F11: BART’s operating cost model, as documented in the FY2027 Preliminary Operating Budget, indicates that service reductions alone cannot close the $375 million structural deficit.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F11; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F11; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F12

F12: BART’s cost-reduction strategies include both permanent savings and temporary cost deferrals, including $197 million in deferred capital contributions through FY2027 and a retirement incentive program that generated $18.5 million in net FY2022 savings but increased long-term retiree medical and pension obligations projected to begin in FY2028.

Audit: Addressed

Response says

Agrees with clarification but cannot confirm $197m deferred contributions; estimates retirement-program net savings through FY2026 at $12.1m.

Audit analysis

Explicitly marks the unconfirmed amount and distinct savings period; no supporting record for revised calculation identified in the answer.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
1/2

Explicitly marks the unconfirmed amount and distinct savings period; no supporting record for revised calculation identified in the answer.

Scoring confidence: high

finding · BART2608-F13

F13: BART has pursued revenue enhancement initiatives including new faregate installation ($8–$10 million), Clipper BayPass ($7 million), fiber and cellular leases ($7.8 million), parking lot leases (approximately $1 million), Transit-Oriented Development ground leases (approximately $2 million), and Low Carbon Fuel Standard credits ($16 million).

Audit: Addressed

Response says

Agrees with clarification: SB63 Financial Efficiency Study supports initiative estimates through FY2025; further non-fare work continues.

Audit analysis

Named study and period make the basis traceable; revenue realization is not independently established.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Named study and period make the basis traceable; revenue realization is not independently established.

Scoring confidence: high

finding · BART2608-F14

F14: BART estimates its planned revenue enhancement initiatives will generate approximately $43–$45 million in annualized recurring revenue above the FY2025 baseline, addressing approximately 11% of the projected $375 million structural deficit, according to BART’s FY2027 Preliminary Operating Budget.

Audit: Addressed

Response says

Agrees with clarification and cites SB63 Financial Efficiency Study while describing continued non-fare revenue work.

Audit analysis

Addresses estimate provenance without establishing that forecast recurring revenue has materialized.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Addresses estimate provenance without establishing that forecast recurring revenue has materialized.

Scoring confidence: high

finding · BART2608-F15

F15: The Connect Bay Area Measure is a regional sales tax authorized by Senate Bill 63 for the November 3, 2026 ballot, proposing a 0.5% tax in Alameda, Contra Costa, San Mateo, and Santa Clara counties and a 1% tax in San Francisco, projected to generate approximately $975 million annually across the five-county area for a period of 14 years.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F15; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F15; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F16

F16: BART has identified the Connect Bay Area Measure as the primary mechanism to address its projected structural deficit, with BART’s projected annual allocation of approximately $310 million.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F16; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F16; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F17

F17: BART’s FY2027 Preliminary Operating Budget projects that the Connect Bay Area Measure’s $310 million annual allocation to BART is less than the $375 million FY2027 structural deficit, and that the Measure alone will not achieve structural balance in FY2027.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F17; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F17; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F18

F18: BART’s five-year financial forecast (FY2027-2031) projects cumulative net deficits of approximately $192 million through FY2031 even with Connect Bay Area Measure revenues beginning in FY2028, and projects that additional cost reduction or revenue measures will be required to achieve structural balance.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F18; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F18; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F19

F19: BART has not developed an integrated financial strategy combining Connect Bay Area Measure revenues with identified cost reduction measures sufficient to achieve structural balance across the FY2028-FY2031 forecast horizon.

Audit: Addressed

Response says

Agrees with clarification, saying staff continue cost control and revenue development toward structural balance.

Audit analysis

Explicit agreement engages absence of an integrated strategy, but added work description is general and identifies no record or completed plan.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

7/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

3/6

Public usefulness

Coverage
2/2
Reason specificity
1/2
Support traceability
0/2

Explicit agreement engages absence of an integrated strategy, but added work description is general and identifies no record or completed plan.

Scoring confidence: high

finding · BART2608-F20

F20: BART’s five collective bargaining agreements have provisions that require minimum staffing levels tied to physical locations rather than service levels, and workforce protections that establish terms that can be expanded through bargaining but require further negotiation to modify.

Audit: Addressed

Response says

Partially disagrees: only ATU has location-based minimums, covering about 11% of workforce; train operators have no minimum.

Audit analysis

Identifies accepted negotiability and disputed breadth with a named agreement and classification-specific explanation.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Identifies accepted negotiability and disputed breadth with a named agreement and classification-specific explanation.

Scoring confidence: high

finding · BART2608-F21

F21: BART’s overtime represented between 9.4% and 12.4% of regular Full-Time equivalent (FTE) staffing in every fiscal year from FY2015 through FY2025, with the exception of FY2021, when COVID-related service reductions and an early retirement program temporarily depressed the ratio.

Audit: Partially addressed

Response says

Partially disagrees because BART does not convert overtime to FTEs; lists absence cover, capital work, maintenance and special services.

Audit analysis

Does not directly resolve the jury’s 9.4%–12.4% historical range or explain whether that conversion is invalid. Disputed numerical scope remains incomplete.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

7/10

3/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
1/2

4/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
1/2

Does not directly resolve the jury’s 9.4%–12.4% historical range or explain whether that conversion is invalid. Disputed numerical scope remains incomplete.

Scoring confidence: high

finding · BART2608-F22

F22: The FY2024 and FY2025 Quarterly Financial Reports did not identify overtime expenditure drivers by cause or category or establish a management target for overtime.

Audit: Addressed

Response says

Agrees with clarification: FY2025 $88.3m overtime includes $24.8m capital work and $63.5m operating costs.

Audit analysis

Explains reporting scope with named Quarterly Financial Report context; does not claim historical reports already supplied cause-based targets.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Explains reporting scope with named Quarterly Financial Report context; does not claim historical reports already supplied cause-based targets.

Scoring confidence: high

finding · BART2608-F23

F23: All five recommendations from the OIG’s 2024 span of control audit remain unimplemented.

Audit: Partially addressed

Response says

Partially disagrees, citing dated status updates and July 8 HRIS announcement, while acknowledging more work on data and organization charts.

Audit analysis

Documents implementation efforts but does not specify which of the five span-of-control recommendations were completed. Disputed completion scope is incomplete.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

3/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
1/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Documents implementation efforts but does not specify which of the five span-of-control recommendations were completed. Disputed completion scope is incomplete.

Scoring confidence: high

finding · BART2608-F24

F24: Four of the five recommendations from the OIG’s 2025 overtime management audit remain unimplemented at the time of this report.

Audit: Addressed

Response says

Partially disagrees: by mid-July 2026 two overtime recommendations were closed and three remained in progress; cites dated updates.

Audit analysis

Separates later progress from report-time status, providing a named audit and dated records rather than silently correcting historical finding.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Separates later progress from report-time status, providing a named audit and dated records rather than silently correcting historical finding.

Scoring confidence: high

finding · BART2608-F25

F25: BART’s organizational chart places Internal Audit within the executive management hierarchy, reporting through the Director of Performance and Audit and Chief Financial Officer (CFO) to the General Manager, with no direct reporting line to the Audit Committee depicted.

Audit: Addressed

Response says

Agrees with clarification: chart depicts management only; July 2025 charter provides functional committee reporting and administrative GM reporting.

Audit analysis

Addresses chart omission and governance distinction with named charter and District Act.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Addresses chart omission and governance distinction with named charter and District Act.

Scoring confidence: high

finding · BART2608-F26

F26: Internal Audit’s engagements include audits of financial reporting and other functions within the CFO’s organizational span of control.

Audit: Addressed

Response says

Partially disagrees: external auditors audit statements; IA may review CFO-area processes such as payroll without operational responsibility.

Audit analysis

Defines accepted assurance work and disputed statement-audit scope with a concrete segregation rationale.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
1/2

Defines accepted assurance work and disputed statement-audit scope with a concrete segregation rationale, but identifies no supporting audit record or policy for these operational assertions.

Scoring confidence: high

finding · BART2608-F27

F27: Generally Accepted Government Auditing Standards (GAGAS) Section 3.44 and 3.52 and Institute of Internal Auditors (IIA) Standard 7.1 identify the placement of an audit function within the reporting line of the areas it audits as a structural threat to independence.

Audit: Addressed

Response says

Partially disagrees: acknowledges structural threat but cites GAGAS3.56 criteria and functional reporting/access safeguards.

Audit analysis

Explains mitigation argument using named standards; does not independently establish safeguards are effective.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Explains mitigation argument using named standards; does not independently establish safeguards are effective.

Scoring confidence: high

finding · BART2608-F28

F28: BART’s Internal Audit Charter and Audit Committee Charter both reflect that final approval authority over the Internal Audit Charter and annual audit plan rests with executive management rather than the Audit Committee, while IIA Standards 6.2 and 6.3 require that the governing body hold this approval authority.

Audit: Addressed

Response says

Partially disagrees: Chief Audit Executive rather than executive management approves; committee only reviews, so full conformity may still be lacking.

Audit analysis

Identifies disputed approver and conceded committee-authority gap using July 2025 charter. The response’s own description of charter assignment is internally awkward and not silently reconciled.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Identifies disputed approver and conceded committee-authority gap using July 2025 charter. The response’s own description of charter assignment is internally awkward and not silently reconciled.

Scoring confidence: high

finding · BART2608-F29

F29: Management’s approval of the Internal Audit Charter and annual audit plan does not comply with IIA Standards 6.2 and 6.3, which require the governing body to approve these documents.

Audit: Addressed

Response says

Partially disagrees: attributes final approval to Chief Audit Executive while acknowledging lack of explicit committee approval authority.

Audit analysis

Clearly identifies disputed actor and admitted standards issue through named charters.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Clearly identifies disputed actor and admitted standards issue through named charters.

Scoring confidence: high

finding · BART2608-F30

F30: The Audit Committee Charter is inconsistent with IIA Standards 6.2 and 6.3 because it requires only a review, rather than formal approval, of the Internal Audit Charter and the annual risk-based audit plan.

Audit: Addressed

Response says

Agrees with clarification: distinguishes 2021 committee charter from January 2025 standards and admits review-only authority may not conform.

Audit analysis

Dated governance documents and standards explain the conceded gap without independently determining conformity.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Dated governance documents and standards explain the conceded gap without independently determining conformity.

Scoring confidence: high

finding · BART2608-F31

F31: BART’s Internal Audit Charter states that Internal Audit functionally reports to the Audit Committee—meaning the Committee is responsible for overseeing Internal Audit’s work, approving its plans, and receiving its findings.

Audit: Partially addressed

Response says

Partially disagrees: describes functional committee and administrative GM reporting, plus access/independence safeguards.

Audit analysis

Does not squarely explain the formal finding’s assertion that functional reporting includes approval of plans; related reporting detail leaves that disputed proposition unresolved.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

8/10

3/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
1/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Does not squarely explain the formal finding’s assertion that functional reporting includes approval of plans; related reporting detail leaves that disputed proposition unresolved.

Scoring confidence: high

finding · BART2608-F32

F32: BART’s organizational chart places Internal Audit within the executive management hierarchy with no direct reporting to the Audit Committee.

Audit: Addressed

Response says

Partially disagrees: organizational chart omits Board committees; July 2025 charter establishes functional reporting to Audit Committee.

Audit analysis

Explains chart purpose versus actual claimed relationship through a quoted charter.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Explains chart purpose versus actual claimed relationship through a quoted charter.

Scoring confidence: high

finding · BART2608-F33

F33: There is no documented policy governing the form, content, or timing of Internal Audit’s communications to the Audit Committee, as IIA Standard 15.1 requires.

Audit: Partially addressed

Response says

Partially disagrees: IIA15.1 permits varied communications; July 2025 charter defines topics; no separate policy is maintained.

Audit analysis

Explains policy interpretation and channels but does not resolve the report’s observation that required topics were not always covered.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

8/10

3/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
1/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Explains policy interpretation and channels but does not resolve the report’s observation that required topics were not always covered.

Scoring confidence: high

finding · BART2608-F34

F34: Complete Internal Audit reports were not provided to the Audit Committee on a consistent basis in connection with Internal Audit’s appearances.

Audit: Addressed

Response says

Agrees with clarification: summaries support oversight; full reports may contain asset vulnerabilities and require risk-based distribution under GAGAS9.57.

Audit analysis

Explains why reports are not always broadly distributed using a named standard; appropriateness of restrictions is not independently verified.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Explains why reports are not always broadly distributed using a named standard; appropriateness of restrictions is not independently verified.

Scoring confidence: high

finding · BART2608-F35

F35: There is no documented policy establishing how Internal Audit reports are to be distributed to the Audit Committee following completion of an engagement, as required by GAGAS Section 9.57 and IIA Standard 15.1.

Audit: Addressed

Response says

Disagrees, citing Internal Audit Manual2026 guidance on appropriate recipients and GAGAS9.57 risk assessment.

Audit analysis

Identifies documented guidance and the reason it differs from unrestricted distribution; legality/conformity remains attributed.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Identifies documented guidance and the reason it differs from unrestricted distribution; legality/conformity remains attributed.

Scoring confidence: high

finding · BART2608-F36

F36: Internal Audit’s public webpage includes the Internal Audit Charter and annual activity reports containing summarized audit findings but does not include the annual audit plan, completed audit reports, or the status of audit recommendation implementation.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F36; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F36; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F37

F37: There are no documented restrictions precluding public availability of Internal Audit’s completed audit reports, indicating that BART’s Internal Audit function does not comply with the public distribution requirements of GAGAS Section 9.56.

Audit: Addressed

Response says

Disagrees: applies GAGAS9.57 to internal audits, argues public distribution is not mandatory and disclosure risks require review.

Audit analysis

Explicit whole disagreement with standard-specific interpretation and confidentiality rationale.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Explicit whole disagreement with standard-specific interpretation and confidentiality rationale.

Scoring confidence: high

finding · BART2608-F38

F38: Internal Audit’s risk assessment methodology does not comply with IIA Standards 9.3 and 9.4 because it does not include documented scoring criteria, risk-weighting factors, a defined process for gathering risk information, or evidence of management input.

Audit: Addressed

Response says

Partially disagrees: prior assessments used impact/likelihood scoring and management surveys; methodology can be better documented.

Audit analysis

Engages scoring, weighting, information gathering and input using IIA9.3/9.4 and identified assessment methods.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Engages scoring, weighting, information gathering and input using IIA9.3/9.4 and identified assessment methods.

Scoring confidence: high

finding · BART2608-F39

F39: The 2025 annual audit plan presented to the Audit Committee relied on internal surveys to identify risks and did not include documented input from the Audit Committee or Board of Directors, contrary to IIA Standard 9.4, which requires that the risk assessment be informed by input from the board and senior management.

Audit: Addressed

Response says

Partially disagrees: senior-management surveys and committee plan review informed risks, but Board/committee were not survey participants.

Audit analysis

Distinguishes informal review from formally documented input and acknowledges room for improvement, with FY2025 plan context.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Distinguishes informal review from formally documented input and acknowledges room for improvement, with FY2025 plan context.

Scoring confidence: high

finding · BART2608-F40

F40: During the 2020 and 2025 external auditor procurement cycles, BART staff issued the Request for Proposals in both cycles without prior Audit Committee review, and in the 2025 cycle the Committee was not provided the RFP or the responses received from prospective auditors.

Audit: Addressed

Response says

Partially disagrees: charter does not require pre-issuance RFP review; cites March 2021 and October/November 2025 proposal reviews.

Audit analysis

Addresses both authority and actual proposal access with charter clause and dated meetings, without independently verifying procurement history.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Addresses both authority and actual proposal access with charter clause and dated meetings, without independently verifying procurement history.

Scoring confidence: high

finding · BART2608-F41

F41: The Employee Code of Conduct was adopted in 2013.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F41; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F41; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F42

F42: The Audit Committee Charter requires the Audit Committee to conduct biennial reviews of the Employee Code of Conduct.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F42; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F42; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BART2608-F43

F43: The Employee Code of Conduct has not been reviewed by the Audit Committee since the Committee’s inception in 2021.

Audit: Addressed

Response says

Agrees with clarification: April/June 2026 future-agenda requests anticipated January 2027 code review.

Audit analysis

Identifies dated agenda requests but does not represent planned review as already completed.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Identifies dated agenda requests but does not represent planned review as already completed.

Scoring confidence: high

finding · BART2608-F44

F44: BART’s Internal Audit Charter, Audit Committee Charter, and organizational chart are inconsistent with one another regarding Internal Audit’s reporting relationships and the Audit Committee’s authority, creating ambiguity about where authority over Internal Audit actually resides.

Audit: Addressed

Response says

Agrees with clarification: chart depicts management; charter gives functional/administrative distinction and will be kept aligned with revisions.

Audit analysis

Preserves source label although explanation qualifies the asserted inconsistency, using named charter and specific governance roles.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Preserves source label although explanation qualifies the asserted inconsistency, using named charter and specific governance roles.

Scoring confidence: high

recommendation · BART2608-R1

R1: By March 1, 2027, the BART Board of Directors (Board) should consider directing management to incorporate into the Long-Range Financial Plan measurable targets for non-fare revenue as a percentage of total operating revenue, with annual reporting to the Board on progress against those targets, as a structural strategy to reduce the agency’s dependence on fare revenue.

County: Requires further analysisAudit: Addressed

Response says

Will assess non-fare metrics and update Audit Committee by end of November 2026; challenges percentage metric and notes no document titled Long-Range Financial Plan.

Audit analysis

Specific analysis/update commitment, not acceptance of the precise proposed metric.

Extracted commitments

Provide Audit Committee an update on this recommendation and its analysis.

Responsible party
BART Board of Directors
Timing
By the end of November 2026. · Bounded timeframe

recommendation · BART2608-R2

R2: By March 1, 2027, the BART Board should consider directing management to incorporate into the annual Rail Service Plan a formal service-to-ridership alignment framework that defines target service levels relative to ridership demand, establishes measurable utilization thresholds, and requires annual Board reporting on whether actual service hours are appropriately aligned with passenger miles traveled.

County: Will not be implementedAudit: Addressed

Response says

Declines single-metric alignment framework, citing network frequency, connections, crowding, equity and operational constraints.

Audit analysis

Explains alternative planning/reporting through Rail Service Plan and Quarterly Performance Report.

recommendation · BART2608-R3

R3: By March 1, 2027, the BART Board should consider incorporating its existing fixed/semi-variable/variable cost model into regular Board reporting and budget presentations and requiring that any proposed service reduction be accompanied by a written analysis applying that model to demonstrate projected cost savings, estimated effects on ridership and fare revenue, and net impact on the structural deficit.

County: Requires further analysisAudit: Addressed

Response says

Will refine fiscal-impact reporting and update committee by end of November 2026; says O&M model is not sufficiently precise alone for near-term decisions.

Audit analysis

Specific model limitation and alternative scheduling/energy analyses explain qualified response.

Extracted commitments

Provide Audit Committee an update on this recommendation and its analysis.

Responsible party
BART Board of Directors
Timing
By the end of November 2026. · Bounded timeframe

recommendation · BART2608-R4

R4: By March 1, 2027, the BART Board should consider directing management to develop structural cost reductions in future budgets.

County: ImplementedAudit: Addressed

Response says

Claims implemented through budgets, June 11 efficiency recommendations and July 20 service changes; further service-affecting strategies await measure outcome.

Audit analysis

Preserves completed-direction claims alongside conditional future work and expected spring 2028 PhaseTwo review, not verified structural balance.

Extracted commitments

Initiate Phase Two Financial Efficiency Review if revenue measure succeeds.

Responsible party
BART Board of Directors
Timing
If measure succeeds; comprehensive analysis expected in spring 2028, not guaranteed complete then. · Conditional timing

recommendation · BART2608-R5

R5: By March 1, 2027, the BART Board should consider directing management to expand revenue initiatives.

County: ImplementedAudit: Addressed

Response says

Claims implemented through June 11 approvals of revenue actions including fares, parking, fiber, BayPass and station partnerships.

Audit analysis

Identifies approvals and continuing work, not verified new recurring revenue.

recommendation · BART2608-R6

R6: By March 1, 2027, the BART Board should consider directing management, during collective bargaining, to evaluate whether minimum staffing provisions tied to physical locations rather than service levels can be modified to provide greater operational flexibility in response to changing ridership demand.

County: Requires further analysisAudit: Addressed

Response says

Will evaluate bargaining flexibility and update committee by end of November 2026; says only ATU minimums affect about11% of workforce.

Audit analysis

Explains limited contract scope without promising negotiated concessions.

Extracted commitments

Provide Audit Committee an update on this recommendation and its analysis.

Responsible party
BART Board of Directors
Timing
By the end of November 2026. · Bounded timeframe

recommendation · BART2608-R7

R7: By March 1, 2027, the BART Board should consider directing management to implement analytical tools to identify, categorize, and manage the underlying drivers of overtime costs.

County: ImplementedAudit: Addressed

Response says

Claims tools and February 2 overtime reason codes implemented; video training planned by September 2026.

Audit analysis

Preserves distinction between operational tools and future wider training.

Extracted commitments

Distribute video overtime-dashboard training to a broader group of managers and analysts.

Responsible party
BART Board of Directors
Timing
By September 2026; response does not supply an exact day. · Bounded timeframe

recommendation · BART2608-R8

R8: By March 1, 2027, the BART Board should consider directing management to develop and implement a comprehensive workforce strategy informed by the analytical tools directed under R7, to evaluate whether changes to staffing levels, hiring practices, scheduling practices, or work rules could reduce reliance on overtime as a recurring element of BART’s workforce deployment.

County: Will be implementedAudit: Addressed

Response says

Workforce strategy work is underway through dashboards, leave reduction, overtime audits and FY2027 bargaining.

Audit analysis

Target dates range through FY2027; no independently stated single strategy-completion date.

Extracted commitments

Continue analysis-based alignment of staffing, overtime and schedules, including audit actions and bargaining.

Responsible party
BART Board of Directors
Timing
Targets range through FY2027; no single strategy-completion date stated. · Bounded timeframe

recommendation · BART2608-R9

R9: By March 1, 2027, the BART Board should consider directing management to develop a plan to integrate projected Measure revenues with long-term cost reduction strategies in the event the Measure passes as part of a comprehensive financial plan to achieve structural balance across the forecast horizon.

County: Will be implementedAudit: Addressed

Response says

Will update ten-year Short Range Transit Plan starting fall 2026, with draft to MTC by May 2027; revenue integration depends on measure.

Audit analysis

Bounded plan deliverable and conditional measure scenario; does not guarantee passage or structural balance.

Extracted commitments

Update ten-year Short Range Transit Plan and submit a draft to MTC.

Responsible party
BART Board of Directors
Timing
Begin fall 2026; draft by May 2027. Revenue integration depends on measure outcome and available review recommendations. · Bounded timeframe

recommendation · BART2608-R10

R10: By March 1, 2027, the BART Board should consider directing management to fully implement the outstanding Office of the Inspector General (OIG) recommendations from the 2024 span of control audit and 2025 overtime management audit.

County: Will be implementedAudit: Addressed

Response says

Will continue OIG updates until span-of-control/overtime actions complete; says two overtime items closed, three progressing through FY2027.

Audit analysis

Detailed actions and dates remain management claims; not independent confirmation of all recommendations completed.

Extracted commitments

Continue updates to OIG on outstanding span-of-control and overtime actions until completion.

Responsible party
BART Board of Directors
Timing
Until all actions completed; target dates range through FY2027. · Conditional timing

recommendation · BART2608-R11

R11: By April 1, 2027, the BART Board should consider restructuring Internal Audit’s reporting to establish a direct reporting relationship between Internal Audit and the Audit Committee— meaning the Committee approves the audit plan, receives engagement results, and exercises oversight of the internal audit function—consistent with IIA Standards 6.1 and 7.1 and GAGAS Section 3.56.

County: Requires further analysisAudit: Addressed

Response says

Claims functional reporting already exists; broader authority changes require District Act analysis; update by end of November 2026.

Audit analysis

Explains existing review versus proposed approval authority and commits to an update, not completed restructuring.

Extracted commitments

Provide Audit Committee an update on this recommendation and its analysis.

Responsible party
BART Board of Directors
Timing
By the end of November 2026. · Bounded timeframe

recommendation · BART2608-R12

R12: By April 1, 2027, the BART Board should consider amending the Audit Committee Charter to grant the Audit Committee authority to approve the Internal Audit Charter, the annual risk-based audit plan, and audit resources consistent with IIA Standards 6.1 (Organizational Positioning), 6.2 (Internal Audit Charter), and 7.1 (Organizational Independence).

County: Requires further analysisAudit: Addressed

Response says

Further analysis needed on committee approval/resource powers and District Act; update by end of November 2026.

Audit analysis

Distinguishes review role, Board budget authority and possible expanded committee powers.

Extracted commitments

Provide Audit Committee an update on this recommendation and its analysis.

Responsible party
BART Board of Directors
Timing
By the end of November 2026. · Bounded timeframe

recommendation · BART2608-R13

R13: By April 1, 2027, the BART Board should consider directing management to align the Internal Audit Charter, Audit Committee Charter, and organizational chart to consistently reflect Internal Audit’s reporting relationships and the Audit Committee’s authority, as required by IIA Standards 6.1 and 7.1.

County: Requires further analysisAudit: Addressed

Response says

Will review charters/charts with committee, GM and District Secretary, propose revisions and update committee by end of November 2026.

Audit analysis

Still excludes Board-committee relationships from organizational charts; alignment review is not an unconditional chart-redesign promise.

Extracted commitments

Provide Audit Committee an update on this recommendation and its analysis.

Responsible party
BART Board of Directors
Timing
By the end of November 2026. · Bounded timeframe

Collaboratively review charters and appropriate organization charts and present recommended revisions to Audit Committee.

Responsible party
BART Board of Directors
Timing
No timeframe stated

recommendation · BART2608-R14

R14: By April 1, 2027, the BART Board should consider requiring Internal Audit to develop and implement a documented policy governing the form, content, and timing of its communications to the Audit Committee, consistent with IIA Standard 15.1, and to report to the Audit Committee on the topics defined in the Internal Audit Charter at each scheduled Committee meeting.

County: Will not be implementedAudit: Addressed

Response says

Declines a separate communications policy and mandatory reporting at every meeting, citing May 2026 manual and IIA15.1.

Audit analysis

Explains discretion and current-guidance alternative; no independent standards ruling.

recommendation · BART2608-R15

R15: By April 1, 2027, the BART Board should consider requiring that full Internal Audit reports be provided on a timely basis to the Audit Committee, OIG, and Board without restriction consistent with GAGAS Section 9.57.

County: Will not be implementedAudit: Addressed

Response says

Declines unrestricted full-report distribution, citing May 2026 manual and GAGAS9.57 disclosure-risk assessment.

Audit analysis

Refusal directly engages unrestricted distribution while preserving intended-recipient qualifications.

recommendation · BART2608-R16

R16: By April 1, 2027, the BART Board should consider directing Internal Audit to expand the Internal Audit webpage to include the annual audit plan, completed audit reports, and the status of recommendation implementation, consistent with the public availability requirements of GAGAS Section 9.56.

County: Requires further analysisAudit: Addressed

Response says

Requires public-release risk/legal analysis and will update committee by end of November 2026.

Audit analysis

Engages plans, reports and status posting without promising publication of all materials.

Extracted commitments

Provide Audit Committee an update on this recommendation and its analysis.

Responsible party
BART Board of Directors
Timing
By the end of November 2026. · Bounded timeframe

recommendation · BART2608-R17

R17: By April 1, 2027, the BART Board should consider requiring Internal Audit to formalize and document its risk assessment methodology, including scoring, weighting, and prioritization criteria.

County: Will be implementedAudit: Addressed

Response says

Intends documented risk methodology by April 1, 2027 for FY2028 assessment.

Audit analysis

Specific deliverable and intended date; completion not verified.

Extracted commitments

Formalize documented risk methodology for FY2028 assessment.

Responsible party
BART Board of Directors
Timing
2027-04-01 · Exact date

recommendation · BART2608-R18

R18: By April 1, 2027, the BART Board should consider directing Internal Audit to implement a formal, documented process to obtain and incorporate input from the Audit Committee and Board into the annual risk assessment process, ensuring alignment with the IIA Standards and GAGAS.

County: Will be implementedAudit: Addressed

Response says

Intends Board/committee input by April 1, 2027 for FY2028 risk assessment.

Audit analysis

Explicit input/timing commitment; no independent evidence of completion.

Extracted commitments

Obtain Audit Committee and Board input for FY2028 risk assessment.

Responsible party
BART Board of Directors
Timing
2027-04-01 · Exact date

recommendation · BART2608-R19

R19: By April 1, 2027, the BART Board should consider clarifying and formalizing the Audit Committee’s authority and role in external auditor procurement within the Audit Committee Charter, including defined responsibilities for participation in request for proposal development, evaluation criteria, and selection.

County: Will be implementedAudit: Addressed

Response says

CFO, OIG and Procurement staff are drafting committee-charter revisions for committee review and recommendation to Board in January 2027.

Audit analysis

Deliverable is revised governance language/recommendation, not independently verified adoption.

Extracted commitments

Draft committee-charter revisions clarifying external-auditor procurement role for committee review and recommendation to Board.

Responsible party
BART Board of Directors
Timing
January 2027 committee/Board process; no exact day supplied. · Bounded timeframe

recommendation · BART2608-R20

R20: By April 1, 2027, the BART Board should consider requiring the Audit Committee to conduct and document biennial reviews of the Employee Code of Conduct as required by the Audit Committee’s Charter.

County: ImplementedAudit: Partially addressed

Response says

Claims implemented because charter already requires biennial review, but promises updated code for January 2027 meeting.

Audit analysis

Existing requirement does not establish conducted/documented reviews. Retain implemented label alongside future review commitment.

Extracted commitments

Provide updated Employee Code of Conduct for committee review and discussion.

Responsible party
BART Board of Directors
Timing
January 2027 Audit Committee meeting; implemented label does not establish completed review. · Bounded timeframe