WMATA operates the nation’s second largest heavy rail transit system (Metrorail) and fifth largest bus system (Metrobus), accounting for about 1.1 million passenger trips per weekday. Metrorail runs 6 train lines connecting the District of Columbia to various locations in Maryland and Virginia. A portion of the latest addition, the Silver Line, was opened in 2014. WMATA was created in 1967 through an interstate compact— matching legislation passed by the District of Columbia, the state of Maryland, and the Commonwealth of Virginia, and then ratified by Congress—to plan, develop, finance, and operate a regional transportation system in the National Capital area. A board of eight voting directors and eight alternate directors governs WMATA. The directors are appointed by the District of Columbia, Virginia, Maryland, and the federal government, with each appointing two voting and two alternate directors. WMATA’s operating revenues from rider fares, parking fees, and paid advertisements, do not cover its annual costs, so it relies on year-to-year funding commitments from Maryland, Virginia, and the District of Columbia, and various forms of federal funding to cover gaps in its capital and operating budgets. WMATA’s operating budget covers personnel costs and contracted services; in fiscal year 2017 about 75 percent of its $1.8 billion operating budget went to personnel costs. WMATA’s capital budget, which covers short-term maintenance and long-term capital projects, totaled $1.2 billion in fiscal year 2017. In 2018, Maryland, Virginia, and the District of Columbia each passed legislation to provide additional recurring annual funding to WMATA generally for capital purposes, totaling $500 million annually across the 3 jurisdictions. In recent years, WMATA added new rail service while also experiencing declines in ridership. From fiscal years 2006 through 2017, WMATA increased Metrorail service about 23 percent as measured in total railcar revenue service miles, or the miles traveled when the vehicle is in revenue service; WMATA increased Metrobus service slightly, by about 4 percent. Over this same time, ridership declined—by about 17 percent on Metrorail and 12 percent on Metrobus. (See fig. 1). WMATA attributes this ridership decline to multiple factors, including growth in telecommuting, the expansion of alternative transportation options, and a decline in service quality and reliability. In addition, between June 2016 and June 2017, WMATA completed SafeTrack, a large-scale accelerated maintenance program that suspended service on portions of Metrorail, resulting in delays and additional ridership declines. WMATA’s workforce is composed of bus and rail operations staff, as well as managers, administrators, law enforcement, and others. In September 2017, after reducing its workforce by eliminating 6 percent of its 13,000 positions, WMATA reported that it had 12,217 employee positions across 6 different employee groups, of which 11,341 were filled. Most WMATA employees—83 percent—are represented by one of WMATA’s five unions, depending on the employees’ positions. The Amalgamated Transit Union Local 689 is the largest union, representing 67 percent of WMATA employees (see table 1). Each union negotiates its own terms on wages, salaries, hours, working conditions, and pensions or retirement, and generally documents these terms in its collective bargaining agreement. WMATA provides a defined benefit pension for almost all of its represented employees and for non-represented employees hired before January 1, 1999. In these pension plans, the benefit a retiree receives is generally based on the retiree’s age and/or years of service and compensation, which may include overtime wages for represented employees. WMATA’s annual contributions to its pension plans are invested in portfolios that include stocks, bonds, and real estate to fund future pension benefits. The Local 689 pension plan is WMATA’s largest, and covered 80 percent of all WMATA pension plan members in fiscal year 2017. Each of the five pension plans is governed by a separate group of trustees responsible for administering the plan. The trustees are composed of a mix of members selected by WMATA and by the respective union or employee group. For example, the trustees for the Local 689 plan include three appointed by WMATA and three by Local 689. WMATA makes payments for four defined benefit retiree health plans. These plans generally cover Local 689 employees, Local 2 employees, Metro Transit Police, and Metro Special Police, in addition to non- represented employees. According to WMATA officials, WMATA’s four retiree health plans are “pay-as-you-go,” meaning WMATA pays for benefits as they become due each year, and funds necessary for future benefits are not accumulated. WMATA’s total workforce costs—composed of wages, salaries, and benefits for current and retired employees—increased modestly in inflation-adjusted dollars (on average by about 3 percent annually) from fiscal years 2006 through 2017. This modest increase reflected small increases in wage and salary costs and substantial increases in employee and retiree benefit costs. In particular, WMATA’s required annual contributions to its pension plans increased by an annual average of almost 19 percent and were WMATA’s fastest growing workforce cost component from fiscal years 2006 through 2017. The possibility of further increases in the costs of WMATA’s pension plans poses significant risk to the agency’s financial operations, yet WMATA has not fully assessed these risks. WMATA’s total workforce costs increased by about 3 percent annually on average between fiscal years 2006 and 2017 in inflation-adjusted fiscal year 2017 dollars, with wages and salaries increasing an average 1.1 percent per year, from $645 million in 2006 to $728 million in 2017. These costs grew at a slower rate than the costs of contracted services (7.3 percent annually on average) and employee and retiree benefits (5.6 percent annually on average), as discussed below (see table 2). The total number of employees WMATA budgeted for each year (authorized positions) grew slightly faster than wages and salaries—about 2 percent per year on average—increasing from 10,451 in 2006 to 13,032 in 2017, with similar growth in the number of occupied positions. Wages and salaries increased at a slower rate than WMATA’s workforce in part because, according to WMATA officials, non-union employees did not receive a salary increase for several of these years. In contrast, employees represented by one of WMATA’s five unions generally received annual wage and salary increases, as laid out in their collective bargaining agreements. WMATA officials also estimated that since 2008, between about 10 and 14 percent of its annual wage and salary costs were composed of operating overtime. WMATA officials stated that operating overtime is used to fill gaps in schedules or staffing in positions that have high vacancy rates, such as Metro Transit Police. While wage and salary costs increased modestly, the cost of WMATA’s contracted services more than doubled from fiscal years 2006 through 2017. During this time contracted services costs increased more than 7 percent per year on average, from $123 million in fiscal year 2006 to $267 million in fiscal year 2017. WMATA officials reported large increases during this period in repair and maintenance, custodial services, professional and technical services such as attorneys and management consultants, and WMATA’s MetroAccess contract that provides paratransit door-to-door service for riders unable to use bus or rail. WMATA officials attributed these increases to several factors. First, they stated that paratransit service ridership and the contractor cost per trip have increased. The officials estimated that providing paratransit service currently costs WMATA about $50 per passenger trip. Second, WMATA officials said adding five new Silver Line stations resulted in increases in contract costs because some of the services already provided by contractors, including custodial services and some track work, were extended to the new stations. Third, WMATA officials said they have been using more contractors in recent years to control costs and improve efficiency. For example, they stated they may use contracts to address problems such as a backlog of track inspections because they can procure contractors to complete the work more quickly than they could with current WMATA staff who would have to be pulled away from other duties or new WMATA staff who would have to be hired and trained. From fiscal years 2006 through 2017, WMATA’s annual costs for its employee and retiree benefits increased substantially in inflation-adjusted fiscal year 2017 dollars. Employee and retiree benefit costs—which include benefits for current employees, such as health care and vacation, and benefits for retired employees such as pensions and health care— increased at an average annual rate of 5.6 percent, from $327 million to $593 million (see table 2 above). These cost increases are reflective of substantial increases in the amount WMATA contributed to its pension plans. These costs increased by an average of 18.9 percent annually, from $25 million in fiscal year 2006 to $168 million in fiscal year 2017. WMATA payments for retiree health benefits increased less dramatically, on average 2.7 percent per year from fiscal years 2008 through 2017($39 million to $49 million). (See fig. 2). WMATA officials attributed increases in employee and retiree benefit contributions to multiple factors including market losses to pension assets incurred after the 2007–2009 financial crisis and an increase in the cost of providing healthcare benefits. Despite paying more for its retiree pension and health plans since 2006, in fiscal year 2017 WMATA had large unfunded retiree health and pension liabilities. Unfunded liabilities are the estimated value of the amount of additional assets, beyond any existing plan assets, that would be required to fully fund accrued liabilities of a plan. The assets of WMATA’s pensions largely consist of investments in stocks, bonds, and real estate. Unfunded liabilities are similar to other kinds of debt because they constitute a promise to make a future payment or provide a benefit. According to WMATA’s fiscal year 2017 Comprehensive Annual Financial Report, WMATA’s pension plans were underfunded by $1.1 billion for fiscal year 2017, of which $814 million was attributed to WMATA’s largest pension plan—Local 689. In contrast, WMATA’s four retiree health plans were pay-as-you-go during fiscal years 2006 through 2017, meaning WMATA’s annual plan contributions were benefit payments for retirees each year in that period. Since WMATA did not make contributions to prefund retiree health benefits, funds necessary for future benefits were not accumulated as assets. As a result, the entire accrued liability was an unfunded liability, and WMATA’s four retiree health plans were unfunded by over $1.8 billion in fiscal year 2017. WMATA officials said they have made several changes to reduce unfunded pension and retiree health liabilities through negotiations with WMATA’s unions. For example, in 2014, Local 689 employees began contributing a portion of their compensation (1 percent) to the Local 689 pension plan. This amount increased to 3 percent in 2015. Local 689 employee contributions reported for fiscal year 2017 were about $22 million, which was about 17 percent of the $127.5 million reported for WMATA’s contribution to their pension plan for that year. In addition, according to WMATA’s fiscal year 2017 Comprehensive Annual Financial Report, non-represented and Local 2 employees hired on or after January 1, 1999 are not eligible for the defined benefit pension plan. WMATA also reported that Local 689 and Local 2 employees hired on or after January 1, 2010, Metro Special Police hired after February 25, 2016, and non- represented employees hired after January 1, 2017 are not eligible for retiree health benefits. Most recently, WMATA created a trust to fund WMATA’s retiree health benefits and invested $3 million in the trust. WMATA’s pension plans, due to their relative size and maturity and investment decisions, pose a particular risk to WMATA’s financial operations: Relative size and maturity: The size of WMATA’s pension plans and the overall maturity of the plans’ participants pose a combined financial risk to WMATA. WMATA’s pension plans assets and liabilities are large relative to its business operations. For example, in fiscal year 2017, WMATA’s pension assets ($3.6 billion) were about 5 times more, and its pension liabilities ($4.7 billion) about 6.5 times more than its annual wages and salaries ($728 million). Because of their relative size, changes in the value of these assets or liabilities— for example, as a result of underperforming investments or revisions to actuarial assumptions—could significantly affect WMATA’s operations. In addition, WMATA’s pension plans are considered “mature” by actuarial measures, meaning, for example, that they have a high proportion of retirees compared to active members. A 2017 WMATA Board of Directors Pension Subcommittee report indicated that if WMATA’s assumed rate of return across all five plans decreased from 7.66 percent to 7 percent, WMATA’s required annual pension contribution would increase $42 million, a 26 percent increase, from 22 percent of wages and salaries ($160.7 million) to about 28 percent of wages and salaries ($203 million). Investment decisions: WMATA’s pension plans assume higher rates of return than state and local pension plans generally do, according to a recent National Association of State Retirement Administrators report. For the 2017 plan year, WMATA’s largest pension plan had an assumed rate of return of 7.85 percent per year, and the weighted average assumed rate of return for WMATA’s five plans combined was 7.66 percent. The average assumed rate of return among the largest state and local government plans was 7.52 percent in 2017, and dropped to a planned 7.36 percent for fiscal year 2018. If WMATA’s pension plan assets return significantly less than assumed, WMATA’s unfunded liabilities will be higher than anticipated, potentially resulting in a spike in required contributions, as occurred in the years following the 2007-2009 financial crisis (see fig. 2 above). WMATA’s pension plans are largely invested in the stock market, which also poses risk. For example, according to a November 2017 report to WMATA’s Board of Directors Pension Subcommittee, 69 percent of WMATA’s plan assets across all five pension plans were invested in the stock market, and only 18 percent in fixed income or cash. Investing in assets such as stocks may increase expected investment returns, but it also increases risk because stock returns are more volatile than investments in high quality bonds that provide a more stable rate of return. In addition, with its mature plans, WMATA faces a shorter time horizon before benefits for its retirees and older workers will become due, leaving less time to recover from investment shortfalls. According to literature on challenges facing U.S. pension plans, plans should take on less risk as they become more mature. This is because investment losses—and corresponding required increases in contributions—can potentially be a high percentage of wage and salary costs, with less time to make adjustments. As described above, WMATA’s pension plans are considered mature, yet they still have a high percentage allocated to risky assets. Although WMATA recently hired a consultant to complete a high-level review of its pensions, it has not fully assessed the risks of its five pension plans to the agency’s financial operations. In 2016 and 2017 WMATA hired a consultant to provide an overview of its five pension plans, including reviewing the plans’ funding strategies and performance. However, the stated purpose of these reports did not include an assessment of risk, and the reports included only limited analysis of the various risks facing WMATA from the plans, for example forecasting WMATA’s pension contributions over the next 10 years, but only under one scenario. In addition, WMATA provided us with analyses conducted by an actuary for each of its five pension plans, which included some limited risk analysis for three of the five pension plans, and no risk analysis for the other two plans, including the Local 689 plan—WMATA’s largest. Neither WMATA nor the trustees for the Local 689 plan have fully assessed the risks of that plan. WMATA’s Office of Internal Compliance has developed a process to periodically assess risks across the agency, known as an Enterprise Risk Management Program, and reported that pension risks could be assessed within this framework. However, WMATA has not yet assessed the fiscal risks from its pension plans within this program. WMATA officials said they are in the process of identifying risks to include in this program for 2019. The internal control standards WMATA follows state that organizations should identify, analyze, and respond to risks related to achieving their objectives. Further, a Society of Actuaries Blue Ribbon Panel reported that it is important for stakeholders—such as trustees, funding entities, plan members, union officials, and, in WMATA’s case, its Board of Directors—to have comprehensive information about the current and expected future financial position of pension plans and the extent of risks facing pension plans. According to the Blue Ribbon Panel, this information should include, among other things, “stress testing,” which projects a plan’s financial outcomes under adverse scenarios. WMATA officials told us that WMATA has not fully assessed pension risks because WMATA’s management does not have control over decisions related to the risks its pension plans take. For example, WMATA officials told us that given that both asset-allocation and investment-return assumptions are the purview of plan trustees who are required to act independently, WMATA has left the decision to determine if risk analysis is necessary to the individual plans’ trustees. WMATA officials stated that even if they were to identify risks, there are not many actions WMATA management could take to change them because trustees have ultimate control over the plans’ investment decisions. However, the investment risks taken by the pension plans’ trustees ultimately affect the amount that WMATA is required to contribute, and assessing those risks could help WMATA better anticipate its required future pension contributions. Without a comprehensive assessment of these risks, WMATA and its stakeholders—such as its Board of Directors—are limited in their ability to prepare for economic scenarios that could ultimately increase the amount WMATA is required to contribute to its pension plans. In addition, if disappointing market returns were the result of a broader economic downturn, WMATA’s revenues—such as those from local jurisdictions— could decline at the same time as higher pension contributions were required. For example, as noted earlier, if WMATA’s pension plans’ assets of $3.6 billion return significantly less than assumed, WMATA could experience a spike in required contributions, as it did in the years following the 2007–2009 financial crisis. Such a spike would further constrain WMATA’s operating budget, and potentially jeopardize its ability to pay for pension contributions or provide transit service. Moreover, without a comprehensive assessment of these risks under various scenarios, WMATA may lack useful information to develop risk mitigation efforts and to inform its collective bargaining negotiations about pay and benefits. Such information would also be useful to WMATA to inform its Board of Directors, and the jurisdictions that fund WMATA, about the impact that adverse economic scenarios could have on WMATA’s ability to provide future service at anticipated funding levels. WMATA identifies the staffing levels it needs each year through its annual budgeting process, but does not have a strategic process to identify and address its long-term workforce needs to meet the agency’s goals. For example, in preparing the annual budget request for the Board of Directors, WMATA officials identify the number of staff needed in individual departments the following fiscal year. However, WMATA does not have a process for identifying and addressing agency-wide workforce needs beyond one year or in relation to agency-wide goals, contrary to leading practices. In addition, WMATA has some workforce development programs, including some that are piloted or planned, but these programs are not based on an agency-wide assessment of the skills the agency needs to meet its strategic goals. Instead, WMATA’s workforce development programs are directed to short-term needs such as filling vacancies. WMATA officials identify staffing levels needed by individual departments annually, in preparation for WMATA’s annual budget. The annual budget, once approved by WMATA’s Board of Directors, sets a ceiling for the number of positions WMATA can employ in the next fiscal year. For example, in fiscal year 2016, WMATA was authorized to fill up to 13,032 positions in fiscal year 2017. WMATA officials told us that each department, such as Rail Services or Bus Services, estimates the number of positions they will need to meet their mission the following fiscal year. According to WMATA officials, this estimation is based in large part on the number of positions allotted to them in the previous fiscal year. WMATA officials said the budget office assembles this department-level data into WMATA’s agency-wide budget request for the board of directors. WMATA’s recent restructuring of its workforce was also guided by the annual budget process. Beginning in June 2016 in preparation for the fiscal year 2018 budget proposal, WMATA eliminated 800 positions, most of which were vacant. To identify these positions, WMATA’s General Manager directed department heads to help identify any positions that were redundant or obsolete. WMATA officials reported that 637 of the 800 positions eliminated were already vacant, and of the 163 occupied positions most were reassigned to other existing positions. Ultimately, WMATA terminated 62 employees during this time for an estimated savings of $7.3 million (about $116,000 per employee in salary and benefits). Although WMATA estimates departmental staffing needs annually, WMATA officials said the agency does not have a process for identifying the agency’s long-term workforce needs. Instead, officials said that each department typically completes a 3-year business plan through which it may identify the number of employees needed over that period. However, none of the 8 department business plans that we reviewed for calendar years 2017 through 2019 identified the number of employees needed. Further, WMATA’s Chief Operating Office business plan identified the lack of long-term workforce planning as a risk to the office’s ability to meet its core organizational goals. WMATA’s four organizational goals are creating a safety culture and system, delivering quality service, improving regional mobility, and ensuring financial stability and investing in people. According to leading human capital practices we have previously identified, agencies should have a strategic workforce planning process that identifies the workforce, including full-time, part-time, and contracts, needed to meet the agency’s strategic goals now and in the future. Strategic workforce planning helps an agency align its human capital program with its current and emerging mission and ensures that it will have the workforce it needs to accomplish its goals. According to these leading practices, the first step of strategic workforce planning is for top management to set a strategic direction for the agency’s workforce planning efforts, and to involve employees and other stakeholders in the development and communication of these efforts. WMATA does not have a strategic workforce planning process that would address its workforce needs beyond the next fiscal year because it has not prioritized that effort. WMATA officials told us they were interested in creating a strategic workforce plan, and had made previous plans to do so. Specifically, WMATA’s 2013–2025 Strategic Plan reported that the agency was creating a “Strategic Human Capital Plan” that would have developed long-term workforce planning strategies. However, WMATA officials told us that the Strategic Human Capital Plan was never completed due to other, competing priorities such as filling vacant positions and addressing other workforce issues in the upcoming budget. Without a strategic workforce planning process to establish a long-term direction for its workforce, WMATA does not have a clear plan for how it will acquire, develop, and retain the workforce needed to achieve its strategic goals of creating a safety culture, delivering quality service, improving regional mobility, and financial stability. Further, without such a process, WMATA lacks reasonable assurance that its short-term annual budget requests for staff, including the recent restructuring, will move the agency toward these strategic goals. WMATA officials told us they have some established workforce development programs, and others piloted or planned. For example, WMATA currently has three specialized recruitment programs to identify qualified veterans, Latinos, and persons with disabilities for WMATA positions. WMATA also provides targeted training for employees such as “principles of supervision” for all new supervisors. WMATA officials told us the agency is also developing a “People Strategy,” which will include multiple workforce development programs for certain entry-level workers and managers to improve their skills and help them to advance in the agency. One component of the People Strategy will be to establish a program to identify and train “high-potential” staff for leadership positions. Although WMATA has some limited workforce development programs, these programs are not based on an agency-wide assessment of skill and competency gaps. According to the COSO internal control standards and leading practices we have previously identified, once an organization’s leadership sets a strategic direction for workforce planning efforts, it needs to conduct a “workforce gap analysis”—a data-driven assessment of the critical skills and competencies the agency will need to achieve its current and future goals. Agencies can use different approaches for this analysis. One example is using information on retirements and attrition to identify future gaps in staffing or skills. Another is “scenario planning” in which an agency identifies how its activities might change in scope and volume in the next 5 years, and then identifies gaps in skills and competencies needed to fill the likely scenarios, rather than planning to meet the needs of a single view of the future. An agency can then develop strategies that are tailored to address any gaps between the skills and competencies they need and the ones they already have. WMATA officials reported that they identify workforce gaps by tracking vacancy rates (percentage of budgeted positions that are vacant) and consulting department leaders about employees departing or retiring. However, WMATA officials said they do not monitor trends in agency- wide retirements and had not projected the number of employees eligible to retire in the future—essential components of a data-driven workforce gap analysis. In comparison, officials from four of the five similar transit agencies we interviewed project the percentage of staff who are eligible to retire in the future, ranging from 3 to 10 years. WMATA officials said the agency has not conducted an agency-wide assessment of its skill and competency needs because it has been more reactive than proactive in response to attrition and retirements and relied on promoting staff to higher-level positions to fill vacancies. For example, until 2017, WMATA had a Superintendent Succession Planning Program, which was designed to prepare bus and rail employees for management roles. WMATA officials reported that this program was initiated in 2009 but is currently on hold as the agency develops its People Strategy. WMATA officials said they plan to implement a different succession planning program, which will offer financial incentives for some managers to transfer knowledge to staff before they retire, as part of the People Strategy. However, without conducting a data-driven assessment of the critical skills and competencies WMATA needs to fill any gaps and achieve its strategic goals, WMATA lacks complete information on where the gaps in its workforce lie, and if its workforce development programs are addressing those gaps or ultimately moving the agency closer to its strategic goals. WMATA has implemented two performance management systems to cover its various employee groups, but these systems lack some key elements of an effective performance management system. Specifically, WMATA has linked employee performance to pay for some employees; however, WMATA’s performance management systems do not (1) consistently align employee and agency goals or assign responsibilities, (2) make meaningful distinctions in performance, or (3) consistently use competencies to identify the behaviors individual employees need to contribute to strategic goals. In addition, WMATA does not have sufficient controls to ensure that performance reviews are complete, accurate, and submitted within established timeframes and does not use performance management information to track progress towards strategic goals. WMATA has implemented two performance management systems that cover all employees: PERFORMetro for non-represented staff and staff represented by Local 2, Fraternal Order of Police, or Local 639; and Performance Conversations for staff represented by Local 689 or Teamsters Local 922. The features of the PERFORMetro and Performance Conversations systems vary somewhat in terms of the frequency of performance reviews, the use of objectives to assess performance, and other characteristics (see table 3). WMATA links pay increases to positive performance for some employees under PERFORMetro, a key element of effective performance management. For example, Metro Special Police must earn a solid performer or better rating to be eligible for salary increases. We have previously noted that high-performing organizations seek to create pay systems that clearly link to employee contributions. WMATA does not link pay to performance for employees who fall under Performance Conversations. Pay increases for these employees—who are represented by two of the largest unions at WMATA—are determined by years of service as described in the collective bargaining agreements. WMATA officials said they had considered linking some pay to performance in the past, but had not pursued this since they believe any changes to how pay is awarded would have to be negotiated between WMATA and each respective bargaining unit. Although WMATA has linked individual performance to pay for some employees, the design of WMATA’s performance management systems lacks three additional key elements of an effective performance management system as identified in our prior work and internal control standards followed by WMATA. Those key elements are: aligning employee and agency goals and identifying responsibilities making meaningful distinctions in performance, and using tailored competencies to define needed skills and behaviors. Aligning employee and agency goals and identifying responsibilities: PERFORMetro is not designed to align individual employee performance with all of its strategic goals. While Performance Conversation forms guide supervisors to discuss the employees’ performance in relation to each of WMATA’s four strategic goals, supervisors under PERFORMetro are required to evaluate employees on individual performance objectives that are aligned with three of these goals. Supervisors under PERFORMetro are not required to evaluate employees on a performance objective aligned with WMATA’s fourth strategic goal—improving regional mobility. WMATA officials told us it is up to individual supervisors to determine whether to evaluate an employee on the fourth strategic goal. Of the 50 performance reviews we assessed, we observed one that aligned an employee’s performance objectives with the organizational goal of improving regional mobility. According to leading performance management practices we previously identified, aligning individual performance objectives with organizational goals helps individuals see the connection between their daily activities and the organization’s goals. Without a mechanism in place to do this for PERFORMetro staff, WMATA may not know how these employees are contributing to increasing regional mobility, and employees may not know how they are performing relative to this goal. In addition, WMATA has not consistently identified how its performance management systems support its overarching strategic goals or assigned responsibilities for implementing these systems. While WMATA issued a staff memo in April 2016 that identified a goal for Performance Conversations—to ensure that employees understand how their performance supports Metro’s strategic goals—WMATA has not done so for PERFORMetro. In addition, none of the performance management documents we reviewed clearly assigned authority or defined responsibilities for implementing either PERFORMetro or Performance Conversations. According to the COSO internal control standards, setting program goals is a key part of the management process, and program- level goals should cascade from agency-level goals. Additionally, these standards include establishing policies and procedures that effectively document a program’s design, delegation of authorities, and assignments of responsibilities. Making meaningful distinctions: WMATA’s performance management systems are not designed to make meaningful distinctions in performance. According to leading performance management practices, the organization’s leadership should make meaningful distinctions between acceptable and outstanding performance of individuals. However, both of WMATA’s performance management systems lack clear definitions for supervisors and employees to use in assessing performance. For example, WMATA leaves it up to employees and their supervisors to identify and define many of the objectives on which employees under PERFORMetro are evaluated. WMATA officials said this provides supervisors some flexibility to account for the responsibilities of employees in different positions. However, the result is that two employees performing the same functions may be evaluated on different objectives, making it difficult to distinguish their performance. Further, under PERFORMetro supervisors are required to rate employees on each objective as “met,” “did not meet,” and “exceeded,” but WMATA does not provide definitions for these categories for each objective. As a result, two employees rated under PERFORMetro could receive different ratings for comparable performance. In addition, for employees under the Performance Conversations system, WMATA does not require supervisors to rate employee performance. Rather, officials told us that WMATA implemented Performance Conversations as a way to encourage more positive, performance-based interactions between employees and management that expanded beyond discipline. WMATA has a discipline-based program for most employees under Performance Conversations (Local 689 bus and rail operations employees and Local 922 bus operators) that establishes standards of conduct these employees must adhere to, and identifies penalties if they do not. This discipline-based program lays out the penalties for violations of employee standards of conduct such as speeding or failing to stop at a red signal. The penalties for conduct violations range from written warnings, to suspensions, to termination. Using competencies tailored to each position: WMATA’s performance management systems do not consistently use competencies to identify the behaviors individual employees are expected to contribute to strategic goals. Although WMATA has established competencies as part of its PERFORMetro system, these competencies are defined in a uniform manner that does not reflect the varied job responsibilities of its employees. Inclusion of such competencies tailored to each position’s responsibilities is a leading practice for an effective performance management system. Competencies, which define the skills and supporting behaviors that individuals are expected to exhibit to carry out their work effectively can provide a fuller picture of an individual’s performance. WMATA defines four competencies for all employees under PERFORMetro—”focuses on safety,” “serves customers,” “accountability,” and “teamwork.” However, these competencies are defined in the same way for all employees under PERFORMetro and are not based on the job responsibilities of each position. For example, WMATA assesses the performance of individuals performing different job functions—such as administrative staff and police officers—by the same competencies and without consideration for how skills and behaviors vary by job function. As such, some portions of the competency descriptions are not applicable to all employees. For example, all PERFORMetro employees are evaluated on the extent that they wear required personal protective equipment and/or clothing, but this may not apply to someone in accounting or human resources. WMATA officials said they are aware of this, and that supervisors choose which portions of the competency descriptions to apply to their employees. Finally, WMATA officials said they do not include competencies for employees under Performance Conversations because Performance Conversations are intended to promote performance discussions, not to evaluate employee performance. However, without competencies tailored to employees’ positions, supervisors are limited in their ability to assess employee performance. WMATA’s performance management systems lack key elements of an effective performance management system in part because the agency has not established comprehensive policies and procedures, as called for by COSO, for its performance management systems. Instead, the agency relies on piecemeal documents—such as staff memos and training—and individual supervisors to define and carry out performance management. By establishing comprehensive policies and procedures that document key elements, such as defined objectives and rating categories, WMATA would be better positioned to assess staff performance and ensure performance management is consistently implemented across supervisors. Additionally, WMATA would be better positioned to use its performance management systems to move employees toward achieving its strategic goals. We found that, in implementing its most recent performance evaluation cycle, WMATA’s reviews of employee performance were often incomplete, inaccurate, or untimely. First, officials said that they do not routinely collect or retain the forms for its Performance Conversations and that accordingly, WMATA does not know the extent to which these reviews were completed. Second, in our review of a non-generalizable sample of 50 PERFORMetro performance evaluations for fiscal year 2016, we found that WMATA supervisors frequently submitted evaluations that were incomplete, inaccurate, or not submitted within established timeframes. Specifically: 25 of the 50 selected files we reviewed were missing either the employee’s or supervisor’s signature required on the initial expectations setting portion of the form; 3 of those 25 files were also missing a required signature on the final review portion of the evaluation form, which provides assurance that the performance evaluation was completed; 10 of the 50 selected files we reviewed were scored incorrectly and thus assigned a performance rating inconsistent with the supporting review. WMATA determines an employee’s final rating based on scores tabulated by supervisors for an employee meeting his or her objectives and demonstrating competencies. Specifically, employees receive separate ratings for objectives and competencies, which are then combined together to yield a final overall rating of “role model,” “solid performer,” or “improvement required”. We found tabulation errors in 10 of the files where, for example, a “solid performer” was given a “role model” rating. Without accurate information about employee performance, WMATA may not be able to recognize employees’ achievements or address potential performance challenges. 22 of the 50 selected files we reviewed were not submitted on time according to timeframes established in a 2016 WMATA staff notice and a 2017 agreement between WMATA and one of its unions. This includes 9 files of employees not represented by a union, 5 law enforcement staff files, and 8 Local 2 staff files. Local 2 officials told us they filed a grievance following delayed performance reviews for its members. Pursuant to the grievance, Local 2 officials signed an agreement with WMATA that if a supervisor does not submit a scheduled performance evaluation within 30 calendar days of a Local 2 employee’s anniversary date, that employee will receive an automatic solid performer rating and any associated pay or step increase. COSO internal control standards state that management should establish control activities, such as policies and procedures, to achieve its goals. Examples of control activities include management reviews and controls over information processing, among other things. A specific type of control activity is a “transaction control,” which helps management ensure that all transactions (in this case, performance reviews) are completely captured, accurate, and timely. Transaction controls may include authorizations or approvals by a higher level of management, or verifications to compare transactions to a policy and then follow-up if the transaction is not consistent with the policy. In the case of WMATA’s performance reviews, this could include comparing a list of employees who should have received a performance review per WMATA policy to a list of the reviews that were submitted to the human resources office. We found that WMATA does not have sufficient controls in place to ensure that supervisors accurately complete performance reviews and submit them to the human resources department within established timeframes. WMATA human resources officials said that for the 2016 review cycle, they emailed a report to supervisors listing year-end performance reviews that were due within 90 days, but did not subsequently ensure that they were completed correctly and on time. Officials said that once supervisors emailed these reviews to the human resources department, human resources staff manually recorded these reviews into WMATA’s personnel information system. WMATA officials told us that human resources staff examined the performance reviews for completion and accuracy. Despite this process, WMATA officials could not provide us reliable information on the number of 2016 performance reviews that were completed, and as previously mentioned, said they did not routinely collect or retain Performance Conversations forms. WMATA officials said they have plans to upgrade their current performance management information technology system, but descriptions of the upgrade that WMATA provided to us do not identify how the upgrade will address the issues we identified. Without controls to ensure that supervisors submit complete, accurate, and timely performance reviews, WMATA lacks information on the performance of its workforce, and employees lack information needed to improve performance. WMATA officials told us that they do not have a process to use information from their performance management systems to identify performance gaps, or pinpoint improvement opportunities. We have previously identified that routinely using performance information to track individual contributions to organizational priorities, and then requiring follow-up actions to address gaps, are key performance management practices. This approach allows an agency to use its employee performance information to monitor progress towards its strategic goals. Officials from two transit agencies we spoke to told us they use information from their performance management systems to track performance gaps related to strategic goals. For example, Chicago Transit Authority officials told us that they evaluate employees on competencies related to the organization’s strategic goals of safety, customer service, and teamwork, and then aggregate performance review information to assess the organization’s performance on these goals. WMATA does not make use of employee performance information in part because it has not developed a process to do so. Without a documented process to use employee performance management information to monitor progress on its strategic goals, WMATA may miss opportunities to identify and follow-up on performance gaps and to make full use of the information collected through its performance management systems. WMATA transports more than 1 million passengers each weekday, making it central to the mobility and productivity of the nation’s capital. Recent safety incidents and declines in ridership place additional pressure on WMATA to effectively manage its most expensive resource— its workforce. If increases in WMATA’s workforce pension costs continue to outpace increases in WMATA’s other workforce costs, WMATA will be under greater pressure to manage its costs and balance competing priorities. A comprehensive assessment of the fiscal risks these pension investments could pose to WMATA could help it prepare for various economic scenarios and ensure that it can continue to provide benefits to its employees without having to compromise future service to riders to pay for these benefits. Effective workforce planning could also help WMATA by ensuring that WMATA has the people and skills it needs to achieve its goals of safety, customer service, financial stability, and regional mobility now and in the future. Establishing a strategic workforce planning process that involves employees and other stakeholders, and that uses data on WMATA’s workforce to assess competency and skill gaps would provide WMATA with critical information that could help it address any identified gaps and ultimately move it closer to its strategic goals. With effective employee performance management, WMATA also would be better positioned to achieve its goals by explicitly aligning them with the daily tasks of its employees. By establishing comprehensive policies and procedures for its performance management systems that align employee performance objectives with WMATA’s strategic goals and define performance objectives, rating categories, and competencies, WMATA will be better able to steer employees towards behaviors that support the agency’s goals and away from behaviors that do not. Further, establishing controls for supervisors to submit complete, accurate, and timely performance reviews would help ensure that staff receive information needed to improve their performance. Finally, a documented process to make use of the performance information WMATA collects could help it track progress in meeting its organizational goals and identify and address performance gaps. In light of WMATA’s uncertain financial future, improvements in WMATA’s workforce planning and performance management could better position WMATA to navigate that future. We are making the following five recommendations to WMATA: 1. WMATA’s General Manager should conduct a comprehensive assessment of the financial risks to which WMATA is exposed from its pension plans and communicate the results to its pension plan trustees and other stakeholders, such as its Board of Directors. This assessment should include information about WMATA’s current and potential future required payments and unfunded liabilities, including under potentially adverse economic scenarios. (Recommendation 1) 2. WMATA’s General Manager should develop a strategic workforce planning process that (1) sets a strategic direction for WMATA’s workforce planning and involves employees and other stakeholders in developing and communicating the process, and (2) includes a data- driven assessment of the critical skill and competencies WMATA needs to fill any gaps. (Recommendation 2) 3. WMATA’s General Manager should establish comprehensive policies and procedures for both of its performance management systems that document the goals of the systems and individuals’ responsibilities for implementing these systems; align employee performance objectives with all of WMATA’s strategic goals; and define performance objectives, rating categories, and competencies tailored to individual positions’ responsibilities. (Recommendation 3) 4. WMATA’s General Manager should establish controls to ensure supervisors fully and accurately complete employee performance reviews and submit them to human resources within established timeframes. (Recommendation 4) 5. WMATA’s General Manager should develop a documented process to use employee performance management information to monitor progress toward WMATA’s strategic goals. (Recommendation 5) We provided a draft of this report to WMATA and DOT for review and comment. WMATA provided written comments, which we have reprinted in appendix II, and technical comments, which we incorporated as appropriate throughout our report. Regarding our first recommendation that WMATA conduct a comprehensive assessment of the financial risks to which it is exposed from its pension plans, WMATA concurred but stated that the agency has already completed such an assessment and does not believe that any additional assessment would add value. As stated in our report, WMATA hired a consultant in 2016 and 2017 to provide an overview of its five pension plans, including reviewing the plans’ funding strategies and performance. However, the stated purpose of these reports did not include an assessment of risk, and the reports included only limited analysis of the various risks WMATA is facing from the plans, and only considered a single scenario for estimating WMATA’s future pension obligations. As such we concluded that these reports did not constitute a comprehensive assessment of risks facing WMATA from its pension plans. Given the plans’ large size relative to WMATA’s business operations, high proportion of retirees compared to active members, high percentage allocation to risky assets, and high assumed rates of return, WMATA’s pension plans pose significant risk to its financial operations. Without a comprehensive risk assessment, WMATA and its Board of Directors are limited in their ability to prepare for economic scenarios that could compromise WMATA’s ability to provide future service. Thus, we continue to believe that our recommendation is valid and that WMATA should fully implement it. Regarding our second recommendation that WMATA develop a strategic workforce planning process, WMATA concurred and described actions it has underway to address the recommendation. Regarding our third recommendation that WMATA develop comprehensive policies and procedures for both of its performance management systems, WMATA concurred and stated that it is in the process of hiring a consultant to evaluate and redesign WMATA’s performance management systems for fiscal year 2020. WMATA also noted that the agency published a performance management handbook and guide in July 2018 that, among other things, provides definitions and indicators for behaviors assessed in performance evaluations. As part of our recommendation follow up process, we will obtain and review the handbook to determine whether it fully addresses our recommendation. Regarding our fourth recommendation that WMATA establish controls to ensure that supervisors complete and submit employee performance reviews to human resources within established timeframes, WMATA concurred and described actions it plans to take in response. Regarding our fifth recommendation that WMATA develop a documented process to use employee performance management information to monitor progress towards WMATA’s strategic goals, WMATA neither agreed nor disagreed. WMATA stated that it already ties individual employee performance to the agency’s strategic goals, but is open to considering improvements through the third-party consultant it plans to hire to review its performance management systems. In our report we note that WMATA’s PERFORMetro performance management system is not designed to align individual employee performance with all of its strategic goals. Specifically, supervisors under PERFORMetro are required to evaluate employees on individual performance objectives that are aligned with three of WMATA’s strategic goals, but not with WMATA’s fourth strategic goal—improving regional mobility. Further, WMATA officials told us that they do not have a process to use information from their performance management systems to identify performance gaps, or pinpoint improvement opportunities. Thus, we continue to believe that our recommendation is valid and WMATA should fully implement it. We are sending copies of this report to the General Manager of WMATA, the Secretary of Transportation, and the appropriate congressional committees. We provided a draft of this report to WMATA and DOT for review and comment. If you or your staff have any questions about this report, please contact Mark Goldstein at (202) 512-2834 or goldsteinm@gao.gov or Frank Todisco at (202) 512-2700 or todiscof@gao.gov. Mr. Todisco meets the qualification standards of the American Academy of Actuaries to address the actuarial issues contained in this report. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Major contributors are listed in Appendix III. This report assesses (1) how the Washington Metropolitan Area Transit Authority’s (WMATA) workforce costs have changed from fiscal years 2006 through 2017 and factors contributing to those changes; (2) how WMATA identifies and addresses its current and future workforce needs; and (3) how WMATA has designed, implemented, and monitored its employee performance management systems. To assess how WMATA’s workforce costs have changed since 2006, we used data from WMATA’s annual budgets and annual audited financial statements from fiscal years 2006 through 2017 on the amounts expensed by WMATA on wages and salaries, employee and retiree benefits, contracted services, and other information on WMATA’s pension and retiree medical plans. We selected 2006 to account for any potential effects of the 2007-2009 financial crisis on pension or other costs, and because WMATA began contributing to its largest pension plan again in 2006 after a 6-year period of not contributing to this plan. To adjust WMATA’s costs for inflation, we used quarterly data on the GDP price index, which we obtained from the Bureau of Economic Analysis. Inflation adjustment factors are calculated to align with the definition of WMATA’s fiscal year, which begins on July 1 and ends on June 30 of the following calendar year. Our calculations adjust nominal values for inflation to find real values are expressed in fiscal year 2017 dollars, where fiscal year refers to WMATA’s fiscal year. We also reviewed data WMATA provided on operating and capital overtime costs, and the most recent actuarial reports for each of WMATA’s five pension plans for more information on WMATA’s pension obligations. Additionally, we analyzed characteristics of WMATA’s five pension plans in consultation with GAO’s Chief Actuary and in relation to actuarial principles and recent literature. Further, we consulted with GAO’s Chief Actuary for assistance in interpreting information about WMATA’s pension and retiree medical plans. To assess WMATA’s pension costs, we reviewed pension expense— which reports WMATA’s expense for its pension plans during a year, as measured in accordance with pension accounting standards for financial reporting purposes—and pension contributions, which reports the amount WMATA paid into its pension plans during a year. Both pension expense and pension contributions increased substantially from fiscal years 2006 through 2017. While pension expense is the pension component of WMATA’s employee and retiree benefit cost data described above, changes in pension accounting reporting standards in 2014 resulted in pension expense being reported differently before and after 2014. As such, we relied on pension contributions as our primary measure of growth of WMATA’s annual pension costs. To assess the reliability of WMATA’s budget data, and other data WMATA provided, we interviewed WMATA officials on practices used to assemble these data. We found these data to be sufficiently reliable for our purposes. To identify factors contributing to changes in workforce costs, we interviewed WMATA officials and reviewed WMATA’s annual budgets, annual financial statements, and actuarial statements for information on the total number of authorized represented and non-represented staff, changes in operating overtime costs, changes in pension-related costs, and other factors that could influence workforce cost changes since fiscal year 2006. To evaluate how WMATA identifies and addresses its workforce needs, we compared WMATA’s workforce planning and workforce development efforts to leading practices we previously identified and the Committee of Sponsoring Organizations of the Treadway Commission (COSO) internal control standards, which WMATA follows. We previously developed these leading strategic workforce planning practices based on a review of documents from (1) organizations with government-wide responsibilities for or expertise in workforce planning models and tools, such as the Office of Personnel Management and the National Academy of Public Administration, and (2) federal agencies recommended as having promising workforce planning programs. Additionally, to identify these practices we reviewed our prior reports and testimonies on human capital issues and met with officials from the aforementioned organizations concerning existing workforce planning models and lessons learned from workforce planning experiences. In addition to comparing WMATA’s workforce planning efforts to leading practices and COSO standards, we reviewed WMATA’s 2017–2019 individual department business plans and 2013–2025 strategic plan to describe how WMATA identifies its short- and long-term workforce needs. Furthermore, we obtained and reviewed WMATA information on the positions WMATA eliminated in fiscal years 2017 and 2018, including the number of positions that were vacant or occupied. Lastly, we compared WMATA’s workforce planning approach to those at a non- generalizable sample of five similar U.S. transit and rail agencies, selected based on similarity in size, age, unions representing agency staff, and stakeholder recommendations. Agency size was measured according to unlinked passenger trips and passenger miles data in the American Public Transportation Association’s 2016 Public Transportation Fact Book, the most recent issue available at the time of selection. System age and union status were determined by a review of publicly available information about each transit system such as academic papers and transit agency websites. With input from industry, federal, WMATA, and union stakeholders, we selected the following peer agencies: (1) Chicago Transit Authority, (2) Los Angeles County Metropolitan Transportation Authority, (3) San Francisco Bay Area Rapid Transit District, (4) Southeastern Pennsylvania Transportation Authority, and (5) Metropolitan Transportation Authority, Metro-North Commuter Railroad. To evaluate how WMATA designed, implemented, and monitored its performance management systems, we reviewed documentation on WMATA’s two employee performance management systems— ”PERFORMetro” for non-represented, Office and Professional Employees International Union Local 2, Fraternal Order of Police, and International Brotherhood of Teamsters Local 639 employees; and “Performance Conversation” for Amalgamated Transit Union Local 689 and International Brotherhood of Teamsters Local 922 employees. We compared these systems to leading performance management practices we have previously identified and to the COSO internal control standards. We previously identified these key practices for modern, effective, and credible performance management systems by synthesizing information contained in its previous performance management work. These practices were also provided for comments to officials from the Office of Personnel Management, the Senior Executives Association and the Center for Human Resources Management at the National Academy of Public Administration. In addition to comparing WMATA’s performance management systems to key practices and COSO internal control standards, we also reviewed WMATA’s 2013–2025 strategic plan, which outlines WMATA’s four strategic goals: (1) build and maintain a premier safety culture and system, (2) meet or exceed expectations by consistently delivering quality service, (3) improve regional mobility and connect communities, and (4) ensure financial stability and invest in our people and assets. To assess how WMATA implemented its performance management systems, including what management controls it had in place to track the completion of required annual employee performance reviews, we interviewed WMATA human resources officials and assessed the data they collected on the number of 2016 PERFORMetro year-end reviews that were required and submitted by supervisors. WMATA officials could not tell us how many PERFORMetro reviews or Performance Conversation forms were required over the period we requested. WMATA officials said that they had data on the number of 2016 PERFORMetro reviews submitted to human resources, but did not collect any data on Performance Conversation forms. As such, we requested the list of submitted 2016 PERFORMetro reviews. WMATA human resources management sent an email to all supervisors asking them to send the reviews they had conducted in the 2016 performance period if they had not already done so. While this information met our purposes for performing a non-generalizable review of selected completed performance reviews, data on the number of employees who were required to have a performance review under PERFORMetro in the 2016 performance period and the number of those employees who received a review were not reliable for reporting purposes. WMATA officials agreed with our assessment that these data were not reliable for reporting purposes. From the list of PERFORMetro reviews we received, we selected an initial non-generalizable sample of 60 files to assess based on employee group (non-represented, Local 2, and Metro Transit Police) and job title. We selected 20 files from each of the three employee groups—10 files each from the two job titles within each employee group with the highest number of identified reviews. We selected the 60 files by assigning random numbers to each file within the six selected job titles and selecting the first 10 files in the sorted, randomized list. We adjusted our random selection as needed to ensure our selection included performance reviews completed by multiple supervisors. Our final selection included the following performance review files: Non-represented employees (20 files total) Rail Operations Supervisor (10 files) Transit Field Operations Supervisor (10 files) Local 2 employees (20 files total) Training and Safety Instructor (10 files) Central Control Supervisor (10 files) METRO Transit Police Department (20 files total) METRO Police S (10 files) Special Police Series (10 files) While conducting our file review, we found that the Special Police Series evaluation forms were significantly different than the other files and did not align with the data collection instrument we had designed. As a result, we did not include these 10 files, leaving us with 50 files included in our final analysis. Lastly, as discussed in our report, we did not review any Performance Conversation files as WMATA officials told us that they do not track the completion of these forms and therefore did not have any data on the number of Performance Conversation year-end reviews that were completed in fiscal year 2017, the first year Performance Conversations were implemented. Finally, we interviewed officials from the FTA and union leadership from four of the five unions representing WMATA employees. We conducted our work from July 2017 to September 2018 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. In addition to the contacts named above, Matt Barranca (Assistant Director), Sarah Farkas (Analyst in Charge); Namita Bhatia Sabharwal; Lacey Coppage; Tom Gilbert; Josh Ormond; Steve Rabinowitz; Michelle Weathers; Hannah Weigle; and Elizabeth Wood made key contributions to this report.

Summary: WMATA transports more than 1 million rail and bus passengers each weekday in the nation's capital and surrounding areas. However, recent safety incidents and declines in ridership and revenues have focused public attention on how WMATA manages its workforce and associated costs. GAO was asked to review WMATA's workforce management. This report examines, among other things, (1) how WMATA's workforce costs have changed from fiscal years 2006 through 2017 and factors contributing to those changes, and (2) how WMATA has designed and implemented its employee performance management systems. GAO reviewed WMATA's annual financial statements and budgets from fiscal years 2006 through 2017, and compared WMATA's workforce cost and performance management efforts to leading practices and internal control and actuarial principles. GAO also reviewed a non-generalizable sample of employee performance evaluations selected to include occupations with the highest number of evaluations. The Washington Metropolitan Area Transit Authority's (WMATA) workforce costs—including wages, salaries, and benefits for employees and retirees—increased on average by about 3 percent annually from fiscal years 2006 through 2017. This increase was largely driven by the cost of employee and retiree benefits. Specifically, the amount WMATA was required to contribute to its pension plans increased by an annual average of about 19 percent during this period. Due to their relative size, proportion of retirees compared to active members, and investment decisions, these pension plans pose significant risk to WMATA's financial operations, yet WMATA has not fully assessed the risks. Without comprehensive information on the risks facing its pension plans, WMATA may not be prepared for economic scenarios that could increase its required contributions to an extent that might jeopardize its ability to provide some transit service. WMATA has implemented two employee performance management systems that cover all employees, but these systems lack some key elements of an effectively designed and implemented performance management system. For example, WMATA's performance management systems are not designed to make meaningful distinctions in performance, a key element of an effective system. This design is due in part to WMATA's lack of comprehensive policies and procedures for its performance management systems. In addition, WMATA lacks sufficient controls to ensure that supervisors complete required performance evaluations accurately and on-time. For example, in 10 of 50 performance evaluations we reviewed, we found scoring errors where employees were assigned a performance rating inconsistent with the supporting review. Without comprehensive policies and procedures or sufficient controls over its performance management systems, WMATA lacks tools and information to move employees toward achieving WMATA's strategic goals. GAO is making five recommendations to WMATA, including that it develop a comprehensive assessment of risks posed by its pension plans, comprehensive policies and procedures for its employee performance management systems, and controls to ensure supervisors complete required performance evaluations, among other actions. WMATA agreed with four recommendations and neither agreed nor disagreed with the fifth.