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Chief auditor flags gaps in civil works certification oversight at High-Speed Rail Authority

California High-Speed Rail Authority Finance and Audit Committee · April 29, 2026
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Summary

An internal audit found the Authority largely follows documented certification procedures but identified unmapped technical contract requirements, poor interoffice communication, unapproved policies, and no staff contingency plan; management plans quarterly follow-ups to implement recommendations.

Chief Auditor Paula Rivera told the Finance and Audit Committee that an audit of the Authority's civil works certification process for construction package 4 (November 2021'July 2024) found adherence to some written procedures but several significant weaknesses in documentation and oversight.

"We performed an audit to determine whether the civil works certification oversight practices and procedures were documented, followed and supported," Rivera said, describing scope and method. The testing observed review comment logs provided by the PCM team and did not evaluate the substantive content of Quality Milestone Data Pack (QMDP) submittals.

Rivera said auditors found that "technical contract requirements in the existing design-build contracts are not mapped to the system requirements relevant to the final revenue service certification." The audit noted design-build contracts contained overlapping and non-U.S. requirements and that the Authority lacks a holistic continuous-improvement process to pare those requirements to what the Federal Railroad Administration requires.

The audit also documented gaps in communication and role clarity between delivery functions. Rivera cited a rail-operations handover management plan developed in May 2020 that had not been reviewed or approved by the construction office, and a May 2023 chief engineer memorandum on responsibility and ownership that was not maintained in an accessible location for new staff. "Anyone who joined that office after May of 2023 didn't understand the division of responsibility," she said.

Auditors identified 13 documents embedded in the draft system certification management plan that had not gone through the Authority's policies and procedures approval process and therefore were not reviewed by legal nor posted for staff access. Rivera said the draft plan was outdated and lacked clarity on the certification committee's acceptance and recommendation process.

On oversight practices, the report found certain practices were undocumented or unsupported and recommended the delivery functions implement a consistent internal control framework. Rivera also raised an operational observation: the rail operations quality-audit role changed several times during the audit and the office lacks a staff contingency plan to preserve institutional knowledge when employees rotate off the program.

Vice Chair Nancy Miller noted management had provided a response. Rivera confirmed management intends to meet quarterly to implement the recommendations and said some processes audited had changed over the course of the engagement, which began years ago. Chair Tom Richards asked that Rivera return if quarterly updates disclose any untoward developments.

The committee did not take formal action at the meeting; Rivera's briefing closed with recommendations that the chief of rail operations, the chief of planning and engineering, and the chief of construction collaborate to implement a continuous-improvement process, route certification-related policies through the Authority approval process, and develop an employee contingency plan for rail operations.

The committee recorded the item for follow-up and asked the chief auditor to bring substantive updates as management works through the recommendations.