PERSONNEL 

SECURITY 

CLEARANCES

Plans Needed to Fully 

Implement and 

Oversee Continuous 

Evaluation of 

Clearance Holders

Report to Congressional Requesters

November 2017

GAO-18-117

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-117, a report to 

congressional requesters

November 2017

PERSONNEL SECURITY CLEARANCES

Plans Needed to Fully Implement and Oversee 

Continuous Evaluation of Clearance Holders

What GAO Found

In October 2016, the Office of the Director of National Intelligence (ODNI) took 

an initial step to implement continuous evaluation—a process to review the 

background of clearance holders and individuals in sensitive positions at any 

time during the eligibility period—across the executive branch, but it has not yet 

determined key aspects of the program, and it lacks plans for implementing, 

monitoring, and measuring program performance. For the first phase, agencies 

are to conduct certain continuous evaluation record checks against a portion of 

their national security population by the end of fiscal year 2017. However, ODNI 

has not formalized its policy on what continuous evaluation encompasses, 

determined what the future phases will entail or when they will occur, or 

developed an implementation plan. According to all seven agencies GAO 

interviewed, this uncertainty has affected their ability to plan for the program and 

estimate its costs. Without a continuous evaluation policy and a fully developed 

plan, full implementation—which has been delayed since 2010—may be further 

delayed. Moreover, ODNI lacks a plan to monitor and measure program 

performance, including for the first phase, which is underway. Without 

developing such a plan, ODNI cannot ensure that the program is being 

implemented consistently across the executive branch or that it is effectively 

identifying risks to national security.

The Department of Defense (DOD) and the Department of State (State) have 

designed, piloted, and evaluated continuous evaluation. Their approaches have 

varied in scope, size, and duration, as they pre-date ODNI’s efforts to implement 

continuous evaluation executive branch-wide. DOD’s pilot involves the most 

record checks and the largest population. DOD had 500,000 employees enrolled 

in December 2016, and it plans to enroll 1 million by the end of calendar year 

2017 and all clearance holders by the end of fiscal year 2021. 

Executive branch agencies meeting established timeliness goals for completing 

periodic reinvestigations decreased from fiscal years 2012 through 2016, and the 

potential effects of continuous evaluation, including on reinvestigations and 

resources, are unknown. While 84 percent of the executive branch agencies 

reviewed by GAO reported meeting the executive branch’s 195-day timeliness 

goal for at least three of four quarters in fiscal year 2012, only 22 percent did so 

in fiscal year 2016. Also, a 2008 report outlined a plan to replace reinvestigations 

with continuous evaluation, but ODNI documentation indicates that this is no 

longer the intent. While agencies expressed varying views about changes to 

reinvestigations—such as modifying their scope—officials from five agencies 

stated that the continuous evaluation program will increase their workloads and 

costs if no other changes are made to the requirements. DOD officials said they 

cannot afford to conduct both continuous evaluation and reinvestigations, as 

DOD estimates that more frequent reinvestigations for certain clearance holders 

will cost $1.8 billion for fiscal years 2018 through 2022. Although agencies have 

identified increased resources as a risk of the program, ODNI has not assessed 

the program’s potential effects on agency resources. Without assessing the 

potential effects once ODNI has further defined the program, implementing 

continuous evaluation could lead to further delays and backlogs in 

reinvestigations, and could increase agency costs.

View GAO-18-117. For more information, 

contact Brenda S. Farrell at (202) 512-3604 or 

farrellb@gao.gov

Why GAO Did This Study

Continuous evaluation is a key 

executive branch initiative to more 

frequently identify and assess securityrelevant information, such as criminal 

activity. Implementing a continuous 

evaluation program has been a longstanding goal, with implementation 

milestones as early as 2010 and DOD 

pilots dating back to the early 2000’s.

GAO was asked to review efforts to 

implement continuous evaluation. This 

report assesses the extent to which (1) 

ODNI has implemented an executive 

branch-wide program and developed 

plans to monitor and measure its 

performance; (2) DOD and other 

agencies have designed, piloted, and 

evaluated continuous evaluation and 

(3) agencies completed timely periodic 

reinvestigations from fiscal years 2012-

2016, and the potential effects of 

continuous evaluation on 

reinvestigations. GAO reviewed 

documentation, analyzed timeliness 

data, and interviewed officials from 

ODNI and other agencies. This is a 

public version of a sensitive report that 

is being issued concurrently. 

Information that ODNI and State 

deemed sensitive has been omitted.

What GAO Recommends

GAO is making six recommendations, 

including that ODNI formalize its policy 

on continuous evaluation, develop an 

implementation plan as well as a plan 

to monitor and measure program 

performance, and assess the potential

effects of continuous evaluation on 

agency resources. ODNI concurred 

with the recommendations, but 

disagreed with aspects of GAO’s 

conclusions. GAO continues to believe 

the conclusions are valid, as discussed 

in the report.
Page i GAO-18-117 Continuous Evaluation

Letter 1

Background 5

ODNI Has Taken an Initial Step to Implement Continuous 

Evaluation across the Executive Branch but Has Not 

Determined Key Program Aspects or How it Will Monitor and 

Measure Performance 12

DOD and State Have Designed, Piloted, and Evaluated 

Continuous Evaluation to Varying Extents 24

Number of Agencies Meeting Periodic Reinvestigation Timeliness 

Goals Decreased from Fiscal Years 2012-2016, and Potential 

Continuous Evaluation Effects Are Unknown 29

Conclusions 37

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 40

Appendix I Comments from the Office of the Director of National Intelligence 46

Appendix II GAO Contact and Staff Acknowledgments 49

Related GAO Products 50

Figures

Figure 1: Milestones for the Issuance of Continuous Evaluation 

Policy and Implementation of the Program 18

Figure 2: Overview of the Department of Defense’s (DOD) 

Continuous Evaluation Process 27

Contents
Page ii GAO-18-117 Continuous Evaluation

Abbreviations

DOD Department of Defense

NBIB National Background Investigations Bureau 

ODNI Office of the Director of National Intelligence 

OMB Office of Management and Budget

OPM Office of Personnel Management

PAC Security, Suitability and Credentialing Performance 

Accountability Council

PERSEREC Defense Personnel and Security Research Center 

State Department of State

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Page 1 GAO-18-117 Continuous Evaluation

441 G St. N.W.

Washington, DC 20548

November 21, 2017

Congressional Requesters

Continuous evaluation—a process to review the background of an 

individual who has been determined to be eligible for access to classified 

information or to hold a sensitive position at any time during the period of 

eligibility—is a key executive branch initiative to more frequently identify 

and assess security-relevant information between periodic 

reinvestigations.1 Implementing a continuous evaluation program has 

been a long-standing goal of security clearance reform efforts, with 

implementation milestones set by the government-wide reform effort 

dating back to the 4th quarter of fiscal year 2010 and Department of 

Defense (DOD) pilot studies dating back to the early 2000’s. Specifically, 

since 2001, DOD’s Defense Personnel and Security Research Center 

(PERSEREC) has conducted a number of studies related to continuous 

evaluation, such as the usefulness of various data sources, the technical 

capability to conduct automated record checks, and the value and utility 

of such checks.

Following the September 2013 shooting at the Washington Navy Yard, 

the Office of Management and Budget (OMB) conducted a 120-day 

review of the government’s security clearance procedures. OMB’s 

February 2014 Suitability and Security Processes Review Report to the 

President, resulting from that review, highlighted 37 recommendations to 

improve, among other things, the federal government’s processes for 

granting security clearances, including the acceleration of the 

implementation of continuous evaluation across all agencies and security 

levels. The report also included a milestone for the Office of the Director 

of National Intelligence (ODNI) to develop an initial continuous evaluation 

capability for certain clearance holders by September 2014. However, in 

April 2015, we found, among other things, that the milestone for 

implementing continuous evaluation had been adjusted to December 

2016, and that executive branch agencies faced challenges in 

 1

As part of the security clearance process, individuals granted security clearances are 

investigated periodically—for as long as they remain in a position requiring access to 

classified information—to ensure their continued eligibility.

Letter
Page 2 GAO-18-117 Continuous Evaluation

establishing a continuous evaluation policy and implementing the 

process.2

You asked us to review executive branch efforts to implement a 

continuous evaluation program for personnel security clearances. Our 

objectives were to assess the extent to which: (1) ODNI has implemented 

an executive branch-wide continuous evaluation program and developed 

plans for monitoring and measuring the performance of the program; (2) 

DOD and other executive branch agencies, if any, have designed, piloted, 

and evaluated continuous evaluation; and (3) executive branch agencies 

completed periodic reinvestigations in accordance with established 

timeliness goals from fiscal year 2012 through fiscal year 2016, and the 

potential effects of continuous evaluation on periodic reinvestigations. 

This report is a public version of a sensitive report that we issued in 

November 2017.3 ODNI and State deemed some of the information in our 

November report to be sensitive, which must be protected from public 

disclosure. Therefore, this report omits sensitive information about

ODNI’s continuous evaluation program and State’s pilot. Although the 

information provided in this report is more limited, the report addresses 

the same objectives as the sensitive report and uses the same 

methodology.

For our first objective, we reviewed relevant Executive Orders identifying 

ODNI’s responsibilities for developing a continuous evaluation program.4

 2

We recommended that the Office of Management and Budget (OMB) develop long-term 

funding estimates for changes to investigation practices, including continuous evaluation, 

resulting from the implementation of the 2012 Federal Investigative Standards. OMB 

concurred with our recommendation. We also recommended that the Director of National 

Intelligence take three actions; (1) develop, implement, and report to Congress on 

investigation quality measures; (2) develop procedures to require information sharing 

between executive branch agencies concerning incomplete investigations or 

adjudications; and (3) develop government-wide baseline data on required reciprocity 

determinations. The Office of the Director of National Intelligence did not state whether it 

concurred with these recommendations, and all four recommendations remained open as 

of May 2017. GAO, Personnel Security Clearances: Funding Estimates and GovernmentWide Metrics Are Needed to Implement Long-Standing Reform Efforts, GAO-15-179SU

(Washington, D.C.: Apr. 23, 2015). 

3

GAO, Personnel Security Clearances: Additional Planning Needed to Implement and 

Oversee Continuous Evaluation of Clearance Holders, GAO-18-159SU (Washington, 

D.C.: Nov. 21, 2017).

4

See Exec. Order No. 12,968, § 3.5, amended by Exec. Order No. 13,764, 82 Fed. Reg. 

8115, 8128 (Jan. 17, 2017). Prior to 2017, continuous evaluation responsibilities were in 

section 3.5 of Executive Order 12968 as amended by Executive Order 13467, 73 Fed. 

Reg. 38,103, 38,107 (June 30, 2008).
Page 3 GAO-18-117 Continuous Evaluation

We also analyzed ODNI memorandums and other documents describing 

continuous evaluation and conducted interviews with ODNI officials 

managing the program about the status of the program and any plans to 

monitor and measure its performance.5 We compared the status of the 

continuous evaluation program against recommendations resulting from 

the February 2014 120-day review. We also conducted interviews with 

officials from DOD, the Department of State (State), the Department of 

Homeland Security, U.S. Customs and Border Protection, the Department 

of Justice, the U.S. Bureau of Alcohol, Tobacco, Firearms, and 

Explosives, and the Federal Bureau of Investigation to determine the 

extent to which those agencies have developed plans to implement 

continuous evaluation and determined potential costs. We selected these 

seven agencies based on their management of the data sources to be 

checked as part of continuous evaluation and because they are among 

those subject to ODNI’s continuous evaluation requirements. We 

compared ODNI program documentation against relevant program 

management criteria for developing project management plans,6 key 

attributes of successful performance measures identified in our prior 

work, and Standards for Internal Control in the Federal Government 

related to communication with external partners and monitoring activities.7

For our second objective, we reviewed pilots underway at DOD and 

State—the two agencies that have piloted continuous evaluation in 

advance of its implementation across the executive branch. Specifically, 

we analyzed DOD documentation related to its continuous evaluation 

process and reviewed PERSEREC reports on DOD’s continuous 

evaluation pilots, including lessons learned. We also interviewed officials 

 5

Office of the Director of National Intelligence Memorandum, Implementation of 

Continuous Evaluation (June 30, 2015); and Office of the Director of National Intelligence 

Memorandum, Continuous Evaluation Phased Implementation and Options for Automated 

Records Checks (Dec. 22, 2016). 

6 Project Management Institute, Inc. A Guide to the Project Management Body of 

Knowledge (PMBOK® Guide), Fifth Edition, 2013. PMBOK is a trademark of Project 

Management Institute, Inc. 

7

We selected these program management criteria based on their applicability to 

implementing new programs and our prior work. GAO, Tax Administration: IRS Needs to 

Further Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, 

D.C.: Nov. 22, 2002); and GAO, Defense Health Care Reform: Additional Implementation 

Details Would Increase Transparency of DOD’s Plans and Enhance Accountability, 

GAO-14-49 (Washington, D.C.: Nov. 6, 2013). These two reports identify key attributes of 

performance measures. GAO, Standards for Internal Control in the Federal Government, 

GAO-14-704G (Washington, D.C.: September 2014).
Page 4 GAO-18-117 Continuous Evaluation

who developed those reports and analyzed available metrics to determine 

how DOD has evaluated and tracked the results of its pilots. In addition, 

we conducted interviews with DOD officials from the Defense Security 

Service, the Defense Manpower and Data Center, the Consolidated 

Adjudications Facility, and the Office of the Under Secretary of Defense 

for Intelligence, which all have roles in the department’s continuous 

evaluation program. We also reviewed metrics and lessons learned from 

State’s pilot and conducted interviews with officials conducting the pilots 

at State’s Bureau of Diplomatic Security. Finally, we observed a 

demonstration of the information technology (IT) system that DOD is 

developing for use in conducting continuous evaluation.

For our third objective, we obtained data from ODNI on the timeliness of 

periodic reinvestigations at specific executive branch agencies from fiscal 

year 2012 through fiscal year 2016, by quarter.8 The number of agencies 

included in our review was omitted because the information was 

sensitive. We excluded the data reported by State to ODNI from our 

analysis due to a July 2017 report by the State Office of Inspector 

General, which identified a number of errors in the department’s security 

clearance timeliness data.9 As such, we report on the timeliness of the 

remaining executive branch agencies for which ODNI provided data. To 

assess the reliability of the data for the remaining executive branch 

agencies, we reviewed relevant documentation and interviewed officials 

about data quality control procedures. Based on these steps, we 

determined that the data were sufficiently reliable for the purposes of this 

report. For that reason, we did not independently test the accuracy of the 

agencies’ databases. We selected the fiscal year 2012 to 2016 timeframe 

for our analysis because the executive branch has not publicly reported 

on the timeliness of individual executive branch agencies since fiscal year 

2011. We analyzed the timeliness data to determine the extent to which 

agencies are meeting OMB-established timeliness goals for completing 

the fastest 90 percent of periodic reinvestigations within 195 days.

 8

These data are not inclusive of all executive branch agencies with employees who hold 

security clearances. As the Security Executive Agent, ODNI collects clearance timeliness 

data from executive branch agencies on a quarterly basis. ODNI provided data for the 

executive branch agencies that have responded to ODNI’s requests for clearance 

timeliness data from fiscal years 2012 through 2016. ODNI officials stated that some 

agencies do not report timeliness data to ODNI because those agencies stated it would be 

a manual and intensive process. 

9

Office of Inspector General, U.S. Department of State, Evaluation of the Department of 

State’s Security Clearance Process, July 2017. 
Page 5 GAO-18-117 Continuous Evaluation

We also conducted interviews with officials from DOD; State; ODNI; the 

Security, Suitability, and Credentialing Performance Accountability 

Council (PAC) Program Management Office; and the National 

Background Investigations Bureau (NBIB) regarding the potential risks 

and effects of continuous evaluation on periodic reinvestigation timeliness 

and plans to offset anticipated workload increases.10 We compared this 

information against relevant program management criteria for performing 

a quantitative risk analysis and Standards for Internal Control in the 

Federal Government related to defining objectives and risk tolerances.11

We conducted this performance audit from July 2016 to November 2017 

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.

ODNI estimates that, as of October 1, 2015, approximately 4.2 million 

government and contractor employees were eligible to hold a security 

clearance. Personnel security clearances are required for access to 

certain national security information. National security information may be 

classified at one of three levels: confidential, secret, or top secret.12 The 

level of classification denotes the degree of protection required for 

 10The Council was previously named the Suitability and Security Clearance Performance 

Accountability Council. The name was changed by Executive Order 13764, 82 Fed. Reg. 

8115 (Jan. 17, 2017).

11Project Management Institute, Inc. A Guide to the Project Management Body of 

Knowledge (PMBOK® Guide), Fifth Edition, 2013. GAO-14-704G.

12A top secret clearance is generally required for approval to access sensitive 

compartmented information; a secret or top secret clearance is generally required for 

approval to access special access programs. Sensitive compartmented information is 

classified intelligence information concerning or derived from intelligence sources, 

methods, or analytical processes that is required to be protected within formal accesscontrol systems established and overseen by the Director of National Intelligence. A 

special access program is a program established for a specific class of classified 

information that imposes safeguarding and access requirements that exceed those 

normally required for information at the same classification level.

Background

Overview of Personnel 

Security Clearance 

Process
Page 6 GAO-18-117 Continuous Evaluation

information and the amount of damage that unauthorized disclosure could 

reasonably be expected to cause to national security. Specifically, 

unauthorized disclosure could reasonably be expected to cause (1) 

“damage,” in the case of confidential information; (2) “serious damage,” in 

the case of secret information; and (3) “exceptionally grave damage,” in 

the case of top secret information.13 According to the Office of Personnel 

Management (OPM) Federal Investigations Notice 16-02, tier 3 

investigations are required for eligibility for access to secret and 

confidential information, or for noncritical sensitive positions, or “L”

access.14 OPM Federal Investigations Notice 16-07 indicates that tier 5 

investigations are required for eligibility for access to top secret or 

sensitive compartmented information, or for critical sensitive or special 

sensitive positions, or “Q” access.15

Once an executive branch agency determines that a position requires a 

certain level of access to classified information, the employee in that 

position completes a questionnaire for national security positions, which 

the requesting agency sends to an investigative service provider. NBIB—

the bureau within OPM with responsibility for conducting personnel 

background investigations—conducts background investigations for most 

of the federal government; however, some agencies have authority 

 13See Exec. Order No. 13,526, § 1.2, 75 Fed. Reg. 707, 707-08 (Dec. 29, 2009). 

14OPM, Federal Investigations Notice No. 16-02, Federal Investigative Standards for Tier 

3 and Tier 3 Reinvestigation (Oct. 6, 2015).

15OPM, Federal Investigations Notice No. 16-07, Implementation of Federal Investigative 

Standards for Tier 4, Tier 4 Reinvestigation, Tier 5, and Tier 5 Reinvestigation (Sept. 26, 

2016). OPM Federal Investigations Notice 15-03 states that tier 1 investigations are for 

positions designated as low-risk and non-sensitive, and are the minimum level of 

investigation for a final credentialing determination for physical and logical access. It also 

states that tier 2 investigations are for non-sensitive positions designated as moderate risk 

public trust positions. OPM, Federal Investigations Notice No. 15-03, Implementation of 

Federal Investigative Standards for Tier 1 and Tier 2 Investigations (Nov. 4, 2014). OPM 

Federal Investigations Notice 16-07 states that tier 4 investigations are required for 

positions solely designated as high risk public trust. The Department of Energy uses “L” 

access to describe a clearance level similar to secret access and “Q” access for a 

clearance level similar to top-secret access.
Page 7 GAO-18-117 Continuous Evaluation

delegated to them to conduct their own investigations.16 The investigative 

service provider then conducts a background investigation and submits 

an investigative report to the requesting agency. Adjudicators from the 

requesting agency use the information from the investigative report to 

determine whether to grant or deny the employee eligibility for a security 

clearance by considering guidelines in 13 specific areas that address (1) 

conduct that could raise security concerns and (2) factors that could allay 

those security concerns and permit granting a clearance. Individuals 

granted security clearances are investigated periodically—for as long as 

they remain in a position requiring access to classified information—to 

ensure their continued eligibility. The 2012 Federal Investigative 

Standards changed the frequency of periodic reinvestigations for certain 

clearance holders.17

 16The National Background Investigations Bureau was established by Executive Order 

13741 of September 29, 2016, 81 Fed. Reg. 68,289, and absorbed the Federal 

Investigative Services, the entity within the Office of Personnel Management that 

previously conducted background investigations for most of the federal government. ODNI 

can designate an agency as an “authorized investigative agency” pursuant to 50 U.S.C. § 

3341(b)(3), as implemented through Executive Order 13467. Alternatively, under 5 U.S.C. 

§ 1104(a)(2), OPM can redelegate any of its investigative functions subject to 

performance standards and a system of oversight prescribed by OPM under 5 U.S.C. § 

1104(b). Agencies without delegated authority rely on NBIB to conduct their background 

investigations, while agencies with delegated authority have been authorized to conduct 

their own background investigations. 

17We have developed an extensive body of work related to the personnel security 

clearance process. A listing of these reports is included in the Related GAO Products 

page at the end of this report. 
Page 8 GAO-18-117 Continuous Evaluation

According to Executive Order 13467, as amended, continuous evaluation 

is a vetting process to review the background of an individual who has 

been determined to be eligible for access to classified information or to 

hold a sensitive position at any time during the period of eligibility.18

Continuous evaluation is intended to fill the gap that exists between 

periodic reinvestigations in which issues relevant to an individual’s 

continued eligibility for a security clearance may go unreported or 

unknown. For example, while the Federal Investigative Standards have 

allowed for periodic reinvestigations to be conducted at any time following 

the completion of the previous investigation or reinvestigation, agencies 

have not been required to conduct them more frequently than every 5 

years, at most, depending on the clearance level and investigative 

standards in effect. Like periodic reinvestigations, the purpose of 

continuous evaluation is to assist agencies in evaluating an individual’s 

continued eligibility for access to classified information.

Continuous evaluation involves automated record checks conducted on a 

more frequent basis, whereas periodic reinvestigations are conducted 

less frequently and may include, among other things, subject and 

reference interviews. The types of records checked as part of continuous 

evaluation are the same as those checked for other personnel security 

purposes. Security-relevant information discovered in the course of 

continuous evaluation is to be investigated and adjudicated under the 

existing standards. According to ODNI, implementation of continuous 

evaluation will not alter clearance holders’ existing rights or 

responsibilities and it will incorporate protections for privacy and civil 

liberties.

 18Exec. Order No. 13,467, § 1.3(d), as amended by Exec. Order No. 13,764, 82 Fed. Reg. 

8115, 8119 (Jan. 17, 2017). Executive Order 13467, as amended, states that continuous 

evaluation leverages a set of automated record checks and business rules to assist in the 

ongoing assessment of an individual’s continued eligibility, and is intended to complement 

continuous vetting efforts. The order defines continuous vetting as reviewing the 

background of a covered individual at any time to determine whether that individual 

continues to meet applicable requirements. A covered individual is a person who 

performs, or who seeks to perform, work for or on behalf of the executive branch, such as 

a federal employee, military member, or contractor, or otherwise interacts with the 

executive branch such that they must undergo vetting. Certain individuals are excluded 

from the definition of “covered individual,” including the President and Vice President, 

certain of their employees, and the governors of states or territories. Exec. Order No. 

13,467, § 1.3(d), (f), (h) (as amended).

Continuous Evaluation Is 

Intended to Supplement 

the Personnel Security 

Clearance Process
Page 9 GAO-18-117 Continuous Evaluation

The enactment of the Intelligence Reform and Terrorism Prevention Act 

of 2004 initiated a reform effort including goals and requirements for 

improving the personnel security clearance process government-wide.19

In June 2008, Executive Order 13467 established the PAC as the 

government-wide governance structure responsible for driving the 

implementation of and overseeing security and suitability reform efforts.20

The PAC presently has four principal members: the Deputy Director for 

Management of OMB; the Director of National Intelligence, who is the 

Security Executive Agent; the Director of OPM, who is the Suitability 

Executive Agent; and the Under Secretary of Defense for Intelligence.21

The Executive Order also designated the Deputy Director for 

Management of OMB as the chair of the PAC. Among other things, the 

PAC is to work with agencies to implement continuous performance 

improvement programs, policies, and procedures; establish annual goals 

and progress metrics; and prepare annual reports on results. It is also to 

develop and continuously reevaluate and revise outcome-based metrics 

that measure the quality, efficiency, and effectiveness of the vetting 

enterprise.22 In April 2014, the PAC established the Program 

Management Office to implement security clearance reforms. This office 

includes subject-matter experts with knowledge of personnel security 

clearances and suitability determinations from OMB, ODNI, OPM, DOD, 

the Department of Homeland Security, the Department of Justice, the 

Department of the Treasury, and the Federal Bureau of Investigation.

 19Pub. L. No. 108-458, § 3001 (2004) (codified in relevant part at 50 U.S.C. § 3341). While 

IRTPA was a far-reaching act with many broad implications, our references to it 

throughout this report pertain solely to section 3001, unless otherwise specified. 

20See Exec. Order No. 13,467, § 2.2, 73 Fed. Reg. 38,103, 38,105 (June 30, 2008). 

Suitability refers to determinations that the executive branch uses to ensure that 

individuals are suitable, based on character and conduct, for federal employment in their 

agency or position. DOD and ODNI formed the Joint Security and Suitability Reform Team 

in 2007 to improve the security clearance process government-wide, prior to the 

establishment of the Security, Suitability, and Credentialing Performance Accountability 

Council.

21The Director of OPM is the Suitability Executive Agent, responsible for developing 

standards and procedures relating to determinations of suitability, among other things. 

The Under Secretary of Defense for Intelligence became the fourth principal member of 

the PAC in 2016 with the issuance of Executive Order 13741, 81 Fed. Reg. 68,289 (Sept. 

29, 2016) (amending Executive Order 13467).

22Exec. Order No. 13,467, § 2.4(d)(iv), (xii), as amended through Exec. Order No. 13,764, 

82 Fed. Reg. at 8122-23. 

Continuous Evaluation Is a 

Key Initiative of the 

Personnel Security 

Clearance Reform Effort
Page 10 GAO-18-117 Continuous Evaluation

In March 2014, OMB established Insider Threat and Security Clearance 

Reform as a government-wide, cross-agency priority goal to improve 

interagency coordination and implementation within the area of personnel 

security clearances.23 Through this goal, the PAC and executive-branch 

agencies are to work to improve oversight to ensure that investigations 

and adjudications meet government-wide quality standards. Included 

among the goal’s key milestones are implementing a continuous 

evaluation policy for the executive branch that regularly assesses trusted 

insiders who have been granted, or are eligible for, access to classified 

national security information, and overseeing the establishment of 

continuous evaluation capabilities. ODNI is identified as the lead agency 

for achieving both of these milestones. In addition, continuous evaluation 

is identified as a key initiative in the PAC’s strategic framework for fiscal 

years 2017 through 2021 as part of an effort to modernize the vetting 

process.24

While the PAC is responsible for driving the implementation of and 

overseeing the overall government-wide reform effort, individual agencies 

are responsible for various aspects of the effort. For example, as the 

Security Executive Agent, ODNI is responsible for developing and issuing 

uniform and consistent policies and procedures to ensure the effective, 

efficient, timely, and secure completion of investigations, polygraphs, and 

adjudications relating to determinations of eligibility for access to 

classified information or eligibility to hold a sensitive position.25 In 

addition, Executive Order 12968, as amended, indicates that ODNI is 

responsible for setting the standards for continuous evaluation of those 

 23The GPRA Modernization Act of 2010 requires OMB to report through a website—

www.performance.gov—on long-term cross-agency priority goals to improve the 

performance and management of the federal government, one of which is Insider Threat 

and Security Clearance Reform. See Pub. L. No. 111-352, § 5 (2011) (codified at 31 

U.S.C. § 1120). The performance planning and reporting framework originally put into 

place by the Government Performance and Results Act of 1993, Pub. L. No. 103-62 

(1993), was updated by the GPRA Modernization Act of 2010. There were 16 of these 

goals as of June 2017.

24Security, Suitability, and Credentialing Performance Accountability Council, Strategic 

Intent Fiscal Years 2017-2021 (July 2016); Security, Suitability, and Credentialing 

Performance Accountability Council, Enterprise Information Technology Strategy Fiscal 

Years 2017-2021 (October 2016); and Security, Suitability, and Credentialing 

Performance Accountability Council, Strategic Intent and Enterprise IT Strategy 

Implementation Plan Fiscal Years 2017-2021.

25Exec. Order No. 13,467, § 2.5(e)(iii), as amended by 82 Fed. Reg. at 8125. 
Page 11 GAO-18-117 Continuous Evaluation

individuals who have access to classified information.26 According to 

ODNI, under these Executive Orders, it has responsibility for and 

oversight of continuous evaluation, as it is an investigative activity that 

supports eligibility determinations. As such, ODNI established a program 

office within the National Counterintelligence and Security Center to, 

among other things, establish policy, guidance, and standards for the 

implementation of continuous evaluation across the executive branch.

DOD has been piloting aspects of continuous evaluation for more than a 

decade—with pilot tests of automated record checks conducted as early 

as 2002. Specifically, PERSEREC has conducted several studies dating 

back to 2001 that have informed and evaluated DOD’s continuous 

evaluation pilots, including the utility of and costs associated with various 

data sources. These studies have focused on the technical capability to 

conduct automated record checks from over 40 government and 

commercial databases, the value and utility of automated record checks 

in tier 5 investigations, and investigative alternatives to the traditional 

periodic reinvestigation, among other things. The studies have also 

included recommendations to further improve DOD’s continuous 

evaluation program, as well as areas for future research. PERSEREC 

noted that it undertook these studies to identify ways to make the 

personnel security system more efficient, fair, and effective. According to 

PERSEREC, starting in 2004 with the formation of the government-wide 

security clearance reform effort, it began to plan for a broader application 

of its research beyond the department.

Using this body of knowledge, DOD has incrementally improved its 

automated record check capabilities and therefore its ability to implement 

a continuous evaluation program, which it did in 2014 at the 

recommendation of the Secretary of Defense. Specifically, following the 

September 2013 shooting at the Washington Navy Yard, the Secretary of 

Defense directed concurrent internal and independent reviews to identify 

and recommend actions to address any gaps or deficiencies in DOD 

programs, policies, and procedures regarding, among other things, the 

 26Specifically, as amended, Executive Order 12968 provides that an individual who has 

been determined to be eligible for or who currently has access to classified information 

shall be subject to continuous evaluation as further defined by and under standards 

(including, but not limited to, the frequency of such evaluation) as determined by the 

Director of National Intelligence. See Exec. Order No. 12,968, § 3.5, as amended by Exec. 

Order No. 13,764, 82 Fed. Reg. at 8128. 

DOD Has Conducted 

Research on Continuous 

Evaluation for More Than 

a Decade
Page 12 GAO-18-117 Continuous Evaluation

granting and renewing of security clearances for department and 

contractor personnel. In March 2014, the Secretary of Defense identified 

four key recommendations based on the findings and recommendations 

from those reviews. One of those recommendations was to implement 

continuous evaluation to provide automated record checks of personnel 

with access to DOD facilities or classified information.27 In addition, DOD 

Instruction 5200.02, which was also issued in March 2014, states that all 

personnel in national security positions shall be subject to continuous 

evaluation.28 Consistent with the recommendation and the DOD 

Instruction, the department implemented a continuous evaluation pilot in 

October 2014, the details of which are discussed later in the report.

In October 2016, ODNI took an initial step to implement continuous 

evaluation across the executive branch in a phased approach, but as of 

May 2017, it had not yet formalized the program in policy. The seven 

agencies we spoke with have been limited in their abilities to plan for the 

implementation of continuous evaluation, including developing estimated 

costs, in accordance with ODNI’s phased approach. This is due, in part, 

to the fact that ODNI has not yet determined key aspects of the program, 

such as when the future phases of implementation will occur or what they 

will entail, and none of the agencies has completed implementation plans. 

Further, ODNI lacks plans for monitoring and measuring the performance 

of continuous evaluation across the executive branch.

 27The three other recommendations did not involve continuous evaluation and were more 

broadly focused on insider threat management and DOD’s personnel security program. 

28Department of Defense Instruction 5200.02, DOD Personnel Security Program (PSP), 

encl. 3, para. 6 (Mar. 21, 2014) (incorporating change 1, effective Sept. 9, 2014). 

ODNI Has Taken an 

Initial Step to 

Implement 

Continuous 

Evaluation across the 

Executive Branch but 

Has Not Determined 

Key Program Aspects 

or How it Will Monitor 

and Measure 

Performance
Page 13 GAO-18-117 Continuous Evaluation

ODNI has taken an initial step to implement continuous evaluation across 

all executive branch agencies in a phased approach, but it has not yet 

formalized the program in policy. Specifically, in October 2016, ODNI 

initiated the first phase of continuous evaluation and outlined 

requirements for this phase in interim guidance distributed to 

implementing agencies in December 2016.29 For the first phase of 

implementation, executive branch agencies are to conduct certain 

continuous evaluation record checks against a portion of their national 

security population. Specific details of the requirements were omitted 

from this report because the information is sensitive. According to OPM 

Federal Investigations Notice 17-03, the first phase of continuous 

evaluation is to be implemented by the end of fiscal year 2017.30 These 

checks are conducted in addition to any initial investigations or periodic 

reinvestigations occurring in fiscal year 2017. ODNI provided agencies 

with prioritization guidance to help them select individuals for continuous 

evaluation. Nearly 80 executive branch agencies are subject to the 

requirements for this first phase of implementation.

ODNI has taken steps to establish the executive branch-wide continuous 

evaluation program in coordination with key stakeholders. For example, in 

June 2013, ODNI established a Continuous Evaluation Working Group—

consisting of 12 core voting member agencies—as a mechanism to 

effectively coordinate continuous evaluation implementation among 

executive branch departments and agencies.31 According to the group’s 

charter, it meets on at least a quarterly basis and is responsible for 

coordinating the development of continuous evaluation standards, 

policies, and procedures, among other things. Since January 2015, ODNI 

has also issued interim guidance to executive branch agencies that are 

subject to its continuous evaluation requirements informing them about 

the purpose of continuous evaluation and providing them with some 

details of the program. Further, to inform the establishment of the 

 29Office of the Director of National Intelligence Memorandum, Continuous Evaluation 

Phased Implementation and Options for Automated Records Checks (Dec. 22, 2016). 

30NBIB, Federal Investigations Notice No. 17-03, Continuous Evaluation Special 

Agreement Check (Feb. 3, 2017). 

31The 12 core voting member agencies of the Continuous Evaluation Working Group are 

as follows: Office of the Director of National Intelligence, Central Intelligence Agency, 

Defense Intelligence Agency, Department of Energy, Department of Homeland Security, 

Department of State, Federal Bureau of Investigation, National Geospatial-Intelligence 

Agency, National Reconnaissance Office, National Security Agency, Office of the Under 

Secretary of Defense for Intelligence, and Office of Personnel Management. 

ODNI Has Taken an Initial 

Step to Implement 

Continuous Evaluation 

across Executive Branch 

Agencies, but Has Not Yet 

Formalized the Program in 

Policy
Page 14 GAO-18-117 Continuous Evaluation

executive branch-wide program, ODNI itself began a 1-year continuous 

evaluation pilot in September 2016, according to ODNI officials. Specific 

details of ODNI’s pilot were omitted from this report because the 

information is sensitive.

In addition to developing standards for continuous evaluation and its 

oversight role, ODNI is also developing a system that agencies can use to 

conduct continuous evaluation. According to ODNI, its system is under 

development and will be available to all executive branch agencies with a 

full suite of continuous evaluation data sources. Agencies may opt to: (1) 

use ODNI’s system, (2) develop their own technical solution, (3) partner 

with another agency to fulfill their continuous evaluation requirements, or 

(4) some combination of the above options.32 ODNI asked agencies in 

December 2016 to provide a preliminary determination as to how they will 

satisfy future automated records checks requirements to allow ODNI’s 

continuous evaluation program to adequately plan for system enrollee 

volume and data usage. Specific details regarding the response of 

executive branch agencies to this request were omitted from this report 

because the information is sensitive. Some executive branch agencies 

stated the following:

• Department of Justice and State officials stated that they plan to use 

ODNI’s system once its development is complete;

• DOD officials stated that they plan to use their own internal system 

that they are developing to conduct continuous evaluation, but that 

they may use ODNI’s system to conduct certain checks; and

• Department of Homeland Security officials noted that they plan to use 

a combination of existing internal agency systems and ODNI’s 

system.

 32As an investigative service provider, NBIB issued a Federal Investigations Notice in 

February 2017 offering to conduct continuous evaluation checks for agencies (the third 

option ODNI presented to agencies) to satisfy ODNI’s requirements for the first phase of 

continuous evaluation for a fee of $45. NBIB, Federal Investigations Notice No. 17-03, 

Continuous Evaluation Special Agreement Check (Feb. 3, 2017). NBIB officials stated that 

the service also includes a financial activity record check, which is in addition to ODNI’s 

requirements for the first phase, and that as of June 2017, a few agencies had elected to 

use the service. According to the Notice, agencies are responsible for adjudicating the 

results of the completed checks, and NBIB officials stated that if an agency determines 

that additional investigative work is required to adjudicate the results, NBIB will charge 

agencies an additional fee. 
Page 15 GAO-18-117 Continuous Evaluation

Standards for Internal Control in the Federal Government states that 

management should externally communicate the necessary information to 

achieve an entity’s objectives.33 Effective information and communication 

are vital for enabling an entity to achieve its objectives, which can be 

accomplished through written guidance.

While ODNI has provided some details of the program to implementing 

executive branch agencies through interim guidance, it has not yet 

formalized the continuous evaluation program through a Security 

Executive Agent Directive. Specifically, in May 2017, ODNI officials stated 

that ODNI had not yet issued a Security Executive Agent Directive for 

continuous evaluation, but that a draft directive was undergoing 

interagency coordination.34 ODNI officials stated that the directive will 

contain a definition of continuous evaluation that is consistent with, but 

expands upon, the definition contained in the relevant Executive Order.35

These officials stated that the expanded definition will help to clarify 

continuous evaluation and ensure that agencies have a common 

understanding of the program. In addition, ODNI officials stated that they 

have developed draft implementation guidelines, which they plan to issue 

after the directive is finalized. ODNI officials stated that the interim 

guidance will remain in effect until the Security Executive Agent Directive 

or follow-on interim guidance is issued.

DOD’s continuous evaluation program—which it began in October 2014, 

in advance of implementation of continuous evaluation executive branchwide by ODNI—identified, in a requirements document for its continuous 

evaluation IT system, that the most important gap in the development of 

the department’s program was the lack of a national or DOD-level policy. 

Specifically, the requirements document notes the lack of a policy that 

fully describes the continuous evaluation process or purpose, or the end 

uses of data. The requirements document further notes that there are 

multiple definitions of continuous evaluation and, due to the lack of policy, 

 33GAO-14-704G. 

34According to ODNI, the Security Executive Agent Directive for continuous evaluation 

completed informal agency coordination and received endorsement from the former 

Director of National Intelligence in December 2016. Due to the change in presidential 

administrations, ODNI was unable to begin the formal interagency coordination process 

until April 2017. As of August 2017, the directive was still undergoing interagency 

coordination. 

35As noted above, continuous evaluation is defined in Executive Order 13467, as 

amended.
Page 16 GAO-18-117 Continuous Evaluation

there is not a common lexicon of terms used in the continuous evaluation 

program, thereby creating an additional gap.

While ODNI reports that the policy is under review, it has not prioritized 

the implementation of continuous evaluation and, as a result, has missed 

numerous milestones in issuing the policy since 2014. Specifically, the 

original Insider Threat and Security Clearance Reform cross-agency 

priority goal milestone for ODNI to issue a continuous evaluation policy 

was July 2014. This milestone was not attained, and it was adjusted to 

September 2016, a milestone that was also missed. The current 

milestone for issuing the policy is October 2017. Additionally, ODNI has 

missed other milestones for implementing a continuous evaluation 

program, as discussed later in the report.

Furthermore, ODNI has initiated the first phase of continuous evaluation 

without a government-wide issued policy or an expanded definition of 

continuous evaluation. As a result, agencies may develop inconsistent 

approaches to implementing continuous evaluation. For example, DOD 

officials stated that DOD has developed its own path for continuous 

evaluation from ODNI’s limited guidance and that in the absence of a 

government-wide policy, DOD is developing its own internal guidance. As 

a result, the approach to continuous evaluation taken by DOD—the 

executive branch agency with the majority of security clearance holders—

may differ from that of other executive branch agencies once fully 

implemented. Ultimately, such inconsistent approaches to continuous 

evaluation could affect reciprocity among agencies—another key 

objective of government-wide security clearance reform efforts.36 Without 

issuing a Security Executive Agent Directive in advance of the next phase 

of implementation—the timeframe for which ODNI has not yet 

determined—that includes, among other things, an expanded definition of 

continuous evaluation, agencies may develop inconsistent approaches to 

continuous evaluation, resulting in an uneven and perhaps ineffective 

implementation across the federal government.

 36Generally, personnel security clearance reciprocity refers to the decision of an agency to 

accept a background investigation or clearance determination completed by another 

authorized investigative or adjudicative agency.
Page 17 GAO-18-117 Continuous Evaluation

ODNI has not yet determined key aspects of its continuous evaluation 

program, which has limited the ability of executive branch agencies to 

plan for implementation in accordance with ODNI’s phased approach. For 

example, while ODNI has initiated the first phase of continuous evaluation 

in coordination with implementing executive branch agencies, it has not 

yet determined what the future phases of implementation will entail, or 

when they will occur. Specifically, ODNI officials stated that they have not 

set any further timeframes for implementing continuous evaluation or 

determined agency requirements for future phases.

Moreover, the timeframes for the implementation of continuous evaluation 

across the executive branch have been extended over time. For example, 

the original milestone set by the government-wide reform effort for 

implementing continuous evaluation was the 4th quarter of fiscal year 

2010, and it was not attained. The PAC subsequently set an Insider 

Threat and Security Clearance Reform cross-agency priority goal 

milestone for developing an initial continuous evaluation capability for the 

most sensitive top secret clearance holders by September 2014—which 

was extended to December 2014—and a milestone for implementing the 

capability for additional clearance holders by December 2016. These 

milestones were also missed. As of May 2017, continuous evaluation had 

not yet been fully implemented, and ODNI had not set a milestone for 

when it would occur.

Although ODNI is one of the goal leaders for the Insider Threat and 

Security Clearance Reform cross-agency priority goal, a senior ODNI 

official stated that the milestones were arbitrarily set, and that 

implementing continuous evaluation has proven to be challenging as a 

result of several technical and legal issues that need to be resolved. 

Further, ODNI officials highlighted the complexities associated with 

developing a whole-of-government continuous evaluation program and 

noted that a number of challenges have come to light as they have been 

developing the program, which have contributed to missed milestones. 

However, ODNI has not prioritized the setting of internal milestones for 

the future phases of implementation that it considers to be reasonable. 

ODNI officials stated that because continuous evaluation is a new 

initiative, no realistic timeline for full implementation will be set until the 

initial results of implementation are analyzed and technical capabilities 

have matured. Further, they stated that although they are unable to 

develop a timeline for full implementation at this time, they are actively 

working to implement the program. In addition, as previously discussed, 

ODNI’s milestone for issuing a continuous evaluation policy has also 

been adjusted over time. Figure 1 shows the adjusted executive branch 

ODNI Has Not Yet

Determined Key Aspects 

of the Continuous 

Evaluation Program, and 

Executive Branch 

Agencies Have Been 

Limited in Their Ability to 

Plan for Implementation
Page 18 GAO-18-117 Continuous Evaluation

milestones for issuing a continuous evaluation policy and implementing a 

continuous evaluation program, including developing a technical 

capability.

Figure 1: Milestones for the Issuance of Continuous Evaluation Policy and Implementation of the Program

The uncertainty regarding the requirements and timeframes for the future 

phases of the program has affected the ability of executive branch 

agencies to plan to implement continuous evaluation and estimate the 

associated costs. First, although OPM Federal Investigations Notice 17-

03 notes that the first phase of continuous evaluation is to be 

implemented by the end of fiscal year 2017, none of the seven executive 

branch agencies we spoke with has completed an agency-specific 

implementation plan.37 While some agencies, such as DOD and State—

both of which have established continuous evaluation programs in 

advance of implementation across the executive branch—have 

developed concepts of operations or standard operating procedures for 

continuous evaluation, all seven agencies we spoke with stated that they 

are waiting for additional information from ODNI before completing their 

implementation plans. Department of Homeland Security officials stated 

 37NBIB, Federal Investigations Notice No. 17-03, Continuous Evaluation Special 

Agreement Check (Feb. 3, 2017). 
Page 19 GAO-18-117 Continuous Evaluation

that they are waiting for ODNI to define and schedule the future phases of 

implementation and to finish developing its continuous evaluation IT 

system, because there could be unknown policy implications that would 

affect the Department’s planning efforts. In August 2017, ODNI officials 

described plans to distribute information to executive branch agencies 

regarding continuous evaluation requirements for fiscal year 2018.

Specific details of these plans were omitted from this report because the 

information is sensitive.

Second, six of the seven agencies we spoke with noted challenges 

associated with estimating the costs of implementation. For example, 

while the Federal Bureau of Investigation has developed some cost 

estimates for implementing continuous evaluation, officials noted that it is 

challenging to estimate the full costs of the program until they receive 

additional information from ODNI, such as the requirements for future 

phases of implementation, as well as information about record check, 

technology, and personnel requirements. DOD officials stated that the 

number of individuals enrolled in continuous evaluation directly relates to 

the amount of agency resources required, for example, to validate, 

respond to, and adjudicate alerts. Two agencies we spoke with stated 

that they had not yet taken any steps to estimate costs because they are 

waiting for additional information from ODNI. In August 2017, ODNI 

officials stated that they plan to leverage an upcoming OMB budget data 

request, administered through the PAC, to obtain agency funding 

estimates for expenses related to conducting continuous evaluation from 

fiscal years 2017 through 2019.

We have previously identified weaknesses associated with estimating the 

costs of personnel security clearance reform. Specifically, in April 2015 

we found, among other things, that long-term costs of implementing the 

2012 Federal Investigative Standards—including the implementation of 

continuous evaluation—were not addressed in personnel security 

clearance background investigation reform planning documentation. 

Further, we found that OMB did not have current and detailed costestimate information from executive-branch agencies, because it did not 

begin to solicit the information from the agencies until almost 2 years after 

the updated standards were approved. As such, we recommended in 

April 2015, among other things, that the Deputy Director for Management 

of OMB, in the capacity as Chair of the PAC, develop long-term funding 

estimates for changes to the federal government’s investigation practices 

resulting from the implementation of the standards, including but not 

limited to costs related to: (1) information technology adjustments to 

enable government-wide data sharing; (2) implementation of continuous 
Page 20 GAO-18-117 Continuous Evaluation

evaluation of clearance holders; and (3) additional personnel resources 

for twice-as-frequent reinvestigations. OMB concurred with the 

recommendation. However, as of October 2017, this recommendation 

remained open.38 We continue to believe that this recommendation is 

valid and should be implemented.

In addition, the seven executive branch agencies we spoke with identified 

other areas related to agency expectations for which they need 

information from ODNI. For example, officials from the Department of 

Justice; the Bureau of Alcohol, Tobacco, Firearms, and Explosives; and 

the Federal Bureau of Investigation stated that while they would like to 

use ODNI’s IT system to conduct all or at least some of the record checks 

that will be required, they will need to develop an interface with ODNI’s 

system to do so. However, these officials stated that they were unaware 

of ODNI’s technical requirements for that interface. These officials further 

stated that without information related to the technical requirements, they 

are unable to sufficiently plan or budget for continuous evaluation. ODNI 

officials stated that although ODNI’s IT system remains under 

development, information on technical interface requirements is available 

to all stakeholders and that they meet with agencies to discuss agencyspecific IT requirements. According to ODNI, several executive branch 

agencies have expressed an interest in using ODNI’s IT system to 

conduct at least some, if not all, of the checks that will be required once 

continuous evaluation is fully implemented. ODNI officials acknowledged 

that agencies will need to develop an interface to use the system, and 

that agencies will be responsible for the associated costs.

The Project Management Institute’s Guide to the Project Management 

Body of Knowledge (PMBOK® Guide) provides guidelines for managing 

individual projects, including developing a project management plan—in 

advance of executing the project—that describes how the project will be 

executed, monitored, and controlled. The plan should include, among 

other things, project schedules and stakeholder roles and responsibilities. 

The guide notes that updates may be made to the project management 

plan as changes may occur as the project progresses.39

 38GAO-15-179SU. 

39PMBOK is a trademark of Project Management Institute, Inc. Project Management 

Institute, Inc. A Guide to the Project Management Body of Knowledge (PMBOK® Guide), 

Fifth Edition, 2013. 
Page 21 GAO-18-117 Continuous Evaluation

ODNI officials managing the continuous evaluation program stated that 

they have not developed a project management plan for the 

implementation of continuous evaluation, to include an implementation 

schedule, because they are still in the planning stage. However, ODNI 

has already started to implement the program. Without a plan that, among 

other things, identifies reasonable milestones for the future phases of 

implementation, ODNI does not have a schedule against which it can 

track its progress or to which it is accountable. Further, without a plan for 

implementing continuous evaluation executive branch-wide that includes 

a schedule and agency requirements for future implementation phases, 

full implementation—which has been delayed for almost 7 years—may be 

further delayed.

While a phased approach to implementation provides agencies time to 

adapt their personnel security clearance programs to changing 

requirements, without an implementation plan outlining ODNI’s 

expectations of agencies’ roles and responsibilities, agencies are unable 

to sufficiently plan for the implementation of continuous evaluation, 

including identifying required resources and estimating potential costs. 

Further, without clearly defining expectations for agencies—including 

information such as the planned requirements for future phases of 

implementation—continuous evaluation may not be fully implemented 

across the executive branch. Incomplete implementation could potentially 

prevent the federal government from identifying security-relevant 

information in a timely manner, thereby exposing it to further national 

security risks, such as unauthorized disclosures of classified information. 

Limited planning, both by ODNI and at the agency level, ultimately puts 

the success of the continuous evaluation program—a key aspect of the 

security clearance reform effort—at risk.

ODNI lacks a plan to monitor and measure the performance of continuous 

evaluation across executive branch agencies. Specifically, ODNI officials 

stated that ODNI has not developed a plan to monitor or assess the 

performance of continuous evaluation across the executive branch, 

including for the first phase of implementation, which is underway. ODNI 

officials stated that, ideally, agencies will report that they have met the 

fiscal year 2017 requirements for the first phase of implementation, and 

that ODNI will follow up with agencies that do not report. The officials 

added that, in the long term, ODNI would like to incorporate continuous 

evaluation into its Security Executive Agent National Assessment 

Program, through which it conducts oversight of the security clearance 

process at executive branch agencies, but that continuous evaluation is 

ODNI Lacks Plans for 

Monitoring and Measuring 

Continuous Evaluation 

Program Performance
Page 22 GAO-18-117 Continuous Evaluation

not currently included in the oversight program. As previously discussed, 

according to Executive Order 13467, ODNI, as the Security Executive 

Agent, is to direct the oversight of investigations, reinvestigations, 

adjudications, and, as applicable, polygraphs for individuals’ eligibility for 

access to classified information, or eligibility to hold a sensitive position 

made by any agency.40 Similarly, Executive Order 12968, as amended, 

indicates that ODNI is responsible for determining standards for 

continuous evaluation.41 According to ODNI, its authorities under the 

Executive Orders include responsibility for and oversight of continuous 

evaluation as it is an investigative activity that supports eligibility 

determinations.

Standards for Internal Control in the Federal Government emphasizes the 

importance of assessing performance over time, noting that ongoing 

monitoring should be built into operations, performed continually, and 

responsive to change.42 The PMBOK® Guide also states that project 

management includes monitoring and controlling work to meet 

performance objectives.43

Without developing a plan to monitor continuous evaluation—including 

assessing continuous evaluation at various phases of implementation—

ODNI cannot ensure that continuous evaluation is being conducted 

consistently across the executive branch, and it may experience 

challenges in identifying any needed modifications to the program. 

Further, ODNI cannot ensure that continuous evaluation is effectively 

meeting its critical purpose of filling the information gap between 

investigative cycles to identify risks to national security.

Additionally, we reported in 2012 that federal agencies engaging in large 

projects can use performance measures to determine how well they are 

 40Exec. Order No. 13,467, § 2.5(e)(i), as amended by Exec. Order No. 13,764, 82 Fed. 

Reg. 8115, 8125 (Jan. 17, 2017). 

41See Exec. Order No. 12,968, § 3.5, as amended by Exec. Order No. 13,764, 82 Fed. 

Reg. at 8128.

42GAO-14-704G. 

43Project Management Institute, Inc. A Guide to the Project Management Body of 

Knowledge (PMBOK® Guide), Fifth Edition, 2013. 
Page 23 GAO-18-117 Continuous Evaluation

achieving their goals and to identify any areas for improvement.44

Reporting on these measures can help key decision makers within 

agencies, as well as stakeholders, to obtain feedback for improving both 

policy and operational effectiveness. Moreover, performance measures 

need to provide managers and other stakeholders with timely, actionoriented information in a format that helps them make decisions that 

improve program performance. Throughout our body of work on leading 

performance management practices we have identified several attributes 

of successful performance measures, which include, among other things, 

measures that are clear, quantifiable, and objective, and that are linked to 

measurable goals.45

However, ODNI has not developed and distributed to executive branch 

agencies performance measures to assess the effectiveness of 

continuous evaluation once it is implemented executive branch-wide. 

ODNI officials stated that they would like to collect metrics in order to 

determine the potential effects of continuous evaluation, in particular on 

agency resources. Although these officials stated that they have had 

some discussions with DOD about the types of metrics it might want to 

collect, such as the number of false positives and the resources required 

to address the workload, ODNI has not prioritized the development of 

performance measures. In February 2017, ODNI officials stated that they 

had not developed—or distributed to DOD or other agencies conducting 

continuous evaluation—any performance measures for continuous 

evaluation. These officials stated that once continuous evaluation has 

matured, ODNI plans to identify appropriate measures and determine a 

mechanism to collect and analyze them. In August 2017, ODNI officials 

stated that they had developed a draft list of metrics for fiscal year 2017. 

 44GAO, Streamlining Government: Questions to Consider When Evaluating Proposals to 

Consolidate Physical Infrastructure and Management Functions, GAO-12-542 

(Washington, D.C.: May 23, 2012).

45GAO-03-143. In this review, we identified attributes of performance measures from 

various sources, such as earlier GAO work, Office of Management and Budget Circular 

No. A-11, the Government Performance and Results Act of 1993, and the IRS’s handbook 

on Managing Statistics in a Balanced Measures System. In addition, we drew on previous 

GAO work, including: GAO, Executive Guide: Effectively Implementing the Government 

Performance and Results Act, GAO/GGD-96-118, (Washington, D.C.: June 1996); and 

GAO, The Results Act: An Evaluator’s Guide to Assessing Agency Annual Performance 

Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 1998). Further, we identified important 

key attributes of performance measures in GAO, Defense Health Care Reform: Additional 

Implementation Details Would Increase Transparency of DOD’s Plans and Enhance 

Accountability, GAO-14-49 (Washington, D.C.: Nov. 6, 2013). 
Page 24 GAO-18-117 Continuous Evaluation

Once the metrics are finalized, these officials stated that they would issue 

guidance to agencies requesting them to report these metrics to ODNI.

However, since ODNI initiated the first phase of continuous evaluation in 

October 2016, without developing and distributing performance measures 

to executive branch agencies, it is unclear whether agencies are 

positioned to collect and report the information to ODNI for fiscal year 

2017. Developing performance measures before the program fully 

matures could help it to identify potential program modifications needed 

prior to the next phase of implementation, as well as prior to full 

implementation. Further, without developing clear, quantifiable, and 

objective performance measures that are linked to measurable goals for 

agencies to track, and without determining a process and schedule for 

agencies to regularly report those measures, ODNI cannot ensure that 

the first phase of the program it has already initiated is effective or 

achieving similar results at all agencies, which could ultimately affect 

reciprocity.

DOD and State have designed, piloted, and evaluated continuous 

evaluation, although their respective approaches have varied in scope, 

size, and duration—with DOD’s pilot involving the most record checks, 

the largest population, and the longest duration. As previously discussed, 

DOD’s efforts to design, pilot, and evaluate continuous evaluation have 

been ongoing for more than a decade, and they pre-date efforts at ODNI 

to develop and implement an executive branch-wide continuous 

evaluation program. According to ODNI officials, as of February 2017, 

DOD and State were the only agencies, other than ODNI, that had piloted 

continuous evaluation. ODNI officials stated that DOD and State’s pilots 

were conducted at the discretion of those agencies, and that while ODNI 

did not oversee them, the results of the pilots have helped inform ODNI’s 

development of an executive branch-wide program. These pilots were 

ongoing prior to ODNI’s December 2016 interim guidance outlining the 

fiscal year 2017 continuous evaluation requirements for executive branch 

agencies, and as a result, both DOD and State have taken different 

approaches to developing their programs.

In October 2014, consistent with the Secretary of Defense’s March 2014 

recommendation to implement continuous evaluation and DOD 

Instruction 5200.02, DOD initiated a continuous evaluation pilot that 

included approximately 100,000 military, civilian, and contractor clearance 

holders, using a limited set of trusted commercial and government data 

DOD and State Have 

Designed, Piloted, 

and Evaluated 

Continuous 

Evaluation to Varying 

Extents

DOD’s Continuous 

Evaluation Pilot
Page 25 GAO-18-117 Continuous Evaluation

sources. DOD has conducted this pilot in a phased approach, increasing 

the number of cleared individuals enrolled over time, in accordance with 

enrollment milestones set as part of the Insider Threat and Security 

Clearance Reform cross-agency priority goal. Specifically, the department 

expanded enrollment to 225,000 DOD clearance holders in December 

2015 and 500,000 in December 2016, and it plans to increase the 

enrolled population to 1 million by the end of calendar year 2017.46 The 

department has also set an internal goal to enroll all clearance holders 

department-wide by the end of fiscal year 2021.

DOD has developed its own continuous evaluation IT system—which is 

called Mirador, and is separate from the IT system that ODNI is 

developing—to conduct automated record checks of commercial and 

government data sources on the enrolled population, with the goal of near 

real-time identification of adverse information to be considered in the 

evaluation of an individual’s continued eligibility for access to classified 

information. DOD officials developing the system stated that while they 

are currently using Mirador to conduct automated record checks for 

continuous evaluation, the system remains under development, and they 

are integrating additional data sources and user requirements as those 

are identified. As of February 2017, the department had implemented 

seven data sources in Mirador, which provide information about 

suspicious financial and criminal activity, among other things. Another 

nine sources were undergoing testing or were otherwise in progress. The 

department expects Mirador to reach initial operating capacity in fiscal 

year 2018. DOD officials stated that aspects of Mirador are still manual, 

such as enrolling individuals, but that they plan to take steps to automate 

them.

DOD officials stated that, depending on the data source, they run record 

checks on enrolled individuals daily, monthly, quarterly, or annually. 

According to DOD officials, if a record check results in an alert, such as 

for criminal activity, Mirador forwards the alert to DOD’s continuous 

evaluation validation cell—within the Defense Security Service, which 

manages the department’s continuous evaluation program—to ensure 

that: (1) the alert applies to the correct individual; (2) the issue was not 

previously known; and (3) the issue is adjudicatively relevant. DOD 

officials stated that if an analyst determines that an alert is valid—

 46DOD officials stated that General Officers and Senior Executive Service employees 

were not part of the pilot population, but that they will be included when DOD increases its 

enrollment to 1 million by the end of calendar year 2017. 
Page 26 GAO-18-117 Continuous Evaluation

meaning that all three of the above statements are believed to be true—

then the analyst generates a report and forwards it to the individual’s 

designated security manager. Alerts are prioritized for analyst review 

according to business rules designed around the severity of the alert, and 

according to DOD officials, all alerts are reviewed by a supervisor 

following an analyst’s initial determination. The officials stated that 

currently, if additional investigative work is required based on the alert, 

the results of that investigation are forwarded to an adjudicator to make a 

determination as to whether the alert affects the individual’s continued 

eligibility for a security clearance. The officials added that the due process 

safeguards in place for periodic reinvestigations are also in place for 

continuous evaluation. Figure 2 provides an overview of DOD’s 

continuous evaluation process.
Page 27 GAO-18-117 Continuous Evaluation

Figure 2: Overview of the Department of Defense’s (DOD) Continuous Evaluation Process
Page 28 GAO-18-117 Continuous Evaluation

DOD has collected and analyzed metrics on the results of its current pilot. 

For example, according to DOD data, as of February 2017, continuous 

evaluation had identified 12,400 alerts. Of those alerts, 2,064—pertaining 

to 1,816 individuals—were determined to be valid, meaning that they 

were adjudicatively relevant and not previously known. According to 

DOD, action has been completed on 1,307 of those cases. Specifically, 

859 cases were closed with a favorable decision, but context was added 

to the individuals’ records; in 375 cases the subject separated and/or no 

longer needed access; and 62 cases involved a clearance revocation, 

condition, or warning. For DOD’s secret-eligible population, continuous 

evaluation helped to identify risk, on average, 6 years 7 months sooner 

than the traditional 10-year periodic reinvestigation model, and 1 year 5 

months earlier for the top secret-eligible population, which is to be 

reinvestigated every 5 years. DOD officials stated that these metrics are 

presently tracked manually by the Consolidated Adjudications Facility, 

and they identified a need to automate the process, going forward.

In addition, DOD officials stated that they have shared the results of the 

pilot and lessons learned with ODNI through the Continuous Evaluation 

Working Group. For example, DOD identified lessons learned related to 

identifying the right data sources, eliminating duplicate alerts, the 

frequency of record checks, methods for achieving identity resolution, and 

the need for operational access to reporting data. Most recently, DOD 

issued Department of Defense Manual 5200.02 in April 2017, which 

includes continuous evaluation among the responsibilities and procedures 

of the DOD Personnel Security Program.47

State began its continuous evaluation pilot in January 2015 to evaluate 

the coverage and reliability of public records information, using a public 

records service provider. Specifically, it compared information received 

from public record checks, such as criminal and financial activity, against 

information contained in personnel security files for approximately 8,600 

personnel. State found, among other things, that while public records can 

provide coverage beyond the traditional scope of investigations, the 

quality of the information varies, and not all jurisdictions participate. State 

continued its pilot in 2016 and expanded the enrolled population to 

include its entire tier 5 population. Additionally, the focus of the pilot 

 47See Department of Defense Manual 5200.02, Procedures for the DOD Personnel 

Security Program (PSP), § 11 (Apr. 3, 2017); see also id. paras. 2.1.q, 2.10.n, 7.6.b(1). 

State’s Continuous 

Evaluation Pilot
Page 29 GAO-18-117 Continuous Evaluation

shifted from evaluating the usefulness of public records information to 

evaluating the alerts received. State officials stated that the results of the 

public record checks are reviewed by the department’s continuous 

evaluation team, which determines whether the information is new, 

accurate, and relevant, and if so, whether it needs further review and 

investigation. These officials stated that because State has authority to 

conduct its own investigations, it is easy to conduct investigative followup. According to officials, minor issues, such as traffic violations, are 

added to personnel files for consideration during the individual’s next 

periodic reinvestigation.

According to State officials, as of March 2017, they had not revoked any 

clearances as a result of the identification of derogatory information 

through continuous evaluation. As of April 2017, State had invested 

approximately $2.4 million in its continuous evaluation pilot for contract 

costs and personnel to administer the program, and, according to State 

officials, ODNI provided approximately one-third of that funding. State 

officials stated that because ODNI provided funding, State has voluntarily 

shared some lessons learned with ODNI, although it was not tasked to do 

so. Some details of State’s pilot were omitted because the information is 

sensitive.

The number of executive branch agencies meeting established timeliness 

goals for completing periodic reinvestigations decreased from fiscal years 

2012 through 2016. Additionally, while executive branch agencies have 

already initiated the first phase of continuous evaluation, the potential 

effects of continuous evaluation on periodic reinvestigations and agency 

resources are unknown, as they have not been assessed.

Number of Agencies 

Meeting Periodic 

Reinvestigation 

Timeliness Goals 

Decreased from 

Fiscal Years 2012-

2016, and Potential 

Continuous 

Evaluation Effects Are 

Unknown
Page 30 GAO-18-117 Continuous Evaluation

Our analysis of timeliness data for specific executive branch agencies 

showed that the percent of agencies meeting timeliness goals decreased 

from fiscal year 2012 through 2016. As part of the Insider Threat and 

Security Clearance Reform cross-agency priority goal, since the second 

quarter of fiscal year 2014, the PAC has reported quarterly on agency 

timeliness. Among other things, the PAC reports on the average number 

of days taken, for the executive branch as a whole, to complete the endto-end process for periodic reinvestigations, as compared with the 

following goals for the fastest 90 percent of periodic reinvestigations: 15 

days to initiate a case, 150 days to conduct the investigation, and 30 days 

to adjudicate—totaling 195 days to complete the end-to-end processing of 

the periodic reinvestigation.

For fiscal year 2016, the PAC reported that the executive branch as a 

whole:

• did not meet the goal of conducting the investigative portion of 

periodic reinvestigations within 150 days for the fastest 90 percent of 

cases for any quarter. The average number of days ranged from 175 

days to 192 days.

• did not meet the goal of completing periodic reinvestigations—the 

end-to-end goal—within 195 days for any quarter of fiscal year 2016. 

The average ranged from 209 days to 227 days.

Our analysis of timeliness data for specific executive branch agencies 

showed that the percent of agencies that reported meeting timeliness 

goals decreased from fiscal year 2012 through 2016. Specifically,

• while 84 percent of the executive branch agencies met the 150-day 

investigative goal for at least three of four quarters for the fastest 90 

percent of periodic reinvestigations in fiscal year 2012, only 18 

percent of the agencies met the investigative goal in fiscal year 

2016.48

• while 84 percent of the executive branch agencies met the end-to-end 

processing goal of 195 days for at least three of four quarters for the 

fastest 90 percent of periodic reinvestigations in fiscal year 2012, only 

22 percent of the agencies completed their fastest 90 percent of 

 48Agencies without delegated authority rely on OPM to conduct their background 

investigations, while agencies with delegated authority have been authorized to conduct 

their own background investigations. As such, timeliness data for agencies without 

delegated authority is a reflection of OPM’s timeliness. 

Executive Branch 

Agencies Meeting 

Established Timeliness 

Goals for Completing 

Periodic Reinvestigations 

Decreased from Fiscal 

Years 2012 through 2016
Page 31 GAO-18-117 Continuous Evaluation

periodic reinvestigations within 195 days for at least three of four 

quarters in fiscal year 2016.

Of the agencies we reviewed, we found that agencies which use NBIB as 

their investigative service provider and agencies with delegated authority 

to conduct their own investigations both experienced challenges in 

meeting established timeliness goals for periodic reinvestigations in fiscal 

years 2015 and 2016.49 For example, 50 percent of the agencies with 

delegated authority completed investigations for at least three of four 

quarters for the fastest 90 percent of periodic reinvestigations within 150 

days in fiscal year 2015, and 44 percent of agencies with delegated 

authority met the timeliness goal in fiscal year 2016. Of the executive 

branch agencies for which we obtained timeliness data from ODNI and 

which use NBIB as their investigative service provider, NBIB completed 

the investigative portion within 150 days for 0 percent of the agencies in 

fiscal year 2015, and completed it within that timeframe for 6 percent of 

the agencies in fiscal year 2016 for at least three of four quarters for the 

fastest 90 percent of reinvestigations. Of the executive branch agencies 

we reviewed, 67 percent met the adjudication timeliness goal of 30 days 

in fiscal year 2016 for at least three of four quarters for the fastest 90 

percent of reinvestigations. Specific details on the timeliness of individual 

executive branch agencies’ periodic reinvestigations were omitted from 

this report because the information is sensitive.

According to NBIB officials, as of June 2017, NBIB’s investigation backlog 

totaled approximately 673,000 cases—about 183,000 of which were 

periodic reinvestigations for both tier 3 and tier 5 clearances.50 NBIB cited 

the September 2014 decision to not exercise the option of one of its 

investigative fieldwork contracts—which led to a loss in capacity and an 

increase in the program’s contract costs—and difficulties attracting and 

retaining investigative resources as two main challenges to timeliness. 

NBIB officials stated that they are taking steps to address the backlog for 

background investigations, including periodic reinvestigations. These 

steps include hiring additional federal and contract investigators, 

implementing a number of workload management initiatives, and 

conducting a business process reengineering review to identify potential 

process efficiencies. Additionally, executive branch agencies noted the 

increased requirements stemming from the 2012 Federal Investigative 

 49The data provided by ODNI identified the agencies with delegated authority to conduct 

their own investigations. 

50NBIB officials stated that these figures include a baseline inventory of 6 weeks of work. 
Page 32 GAO-18-117 Continuous Evaluation

Standards, such as continuous evaluation and more frequent periodic 

reinvestigations for certain clearance holders, as additional challenges to 

meeting timeliness goals.51

In 2008, the Joint Security and Suitability Reform Team issued Security 

and Suitability Process Reform, a report to the President that, among 

other things, includes OMB-issued interim government-wide processing 

goals for security clearances for calendar year 2008.52 The calendar year 

2008 government-wide goal for the fastest 90 percent of periodic 

reinvestigations is the same as the goal currently in place: 195 days to 

complete the end-to-end processing of the periodic reinvestigation.53 The 

report states that OMB issued the interim goal to assist agencies in 

projecting workload and resource requirements.

However, the timeliness goals on which the PAC currently reports for 

periodic reinvestigations are the same as those identified by OMB as 

interim goals for calendar year 2008. Unlike initial investigations, for 

which timeliness objectives are established by statute, the 195-day goal 

for the end-to-end timeliness of periodic reinvestigations was an interim 

goal set by OMB for calendar year 2008.54 The 2008 report to the 

President does not detail how the goals were developed or what data, if 

any, were used to establish them. ODNI officials initially stated that they 

did not know how the 195-day goal was developed or where it was 

documented, and did not know whether subsequent, finalized goals were 

ever established, but they later provided a copy of the 2008 report. A 

senior NBIB official stated that OMB’s interim calendar year 2008 

timeliness goals were developed based on the average timeliness of the 

 51We discuss actions that the executive branch is taking to improve timeliness in a report 

on overall security clearance reform efforts that will be issued later this year. 

52The Joint Security and Suitability Reform Team, Security and Suitability Process 

Reform, December 2008. 

53The report also included an interim goal for 2008 for the fastest 90 percent of initial 

investigations: 15 days to initiate, 65 days to conduct the investigation, and 25 days to 

adjudicate, totaling 105 days to complete the end-to-end processing of the initial 

investigation. 

54The Intelligence Reform and Terrorism Prevention Act of 2004 established an objective 

for each authorized adjudicative agency to make a determination on at least 90 percent of 

all applications for a personnel security clearance within an average of 60 days after the 

date of receipt of the completed application—40 days to investigate, and 20 days to 

adjudicate. See Pub. L. No. 108-458, § 3001 (2004) (codified in relevant part at 50 U.S.C. 

§ 3341). 
Page 33 GAO-18-117 Continuous Evaluation

fastest 90 percent of periodic reinvestigations at that time. Since the 

establishment of OMB’s interim goals, the executive branch has 

measured periodic reinvestigation timeliness against those goals, and it 

has not conducted an evidence-based review to ensure that 195 days—

and the associated goals of the different phases of periodic 

reinvestigations—are realistic goals for periodic reinvestigations.

Standards for Internal Control in the Federal Government states that 

management evaluates and, if necessary, revises defined objectives so 

that they are consistent with requirements and expectations.55 Without 

conducting an evidence-based review of the goals, the executive branch 

will continue to compare the timeliness of its periodic reinvestigations 

against goals that it established almost a decade ago and that may no 

longer be appropriate. Further, without ensuring that 195 days, along with 

the associated goals of the different phases of periodic reinvestigations, 

are appropriate goals, agencies may not be adequately planning for the 

amount of time and resources actually required to conduct periodic 

reinvestigations, and, as a result, they may experience further timeliness 

delays. Moreover, if an agency does not plan for sufficient time to conduct 

periodic reinvestigations, it may allow individuals to retain access to 

sensitive documents when it has not yet confirmed those individuals’

continued eligibility, which could have potential repercussions for national 

security.

The potential effects of continuous evaluation on periodic 

reinvestigations, such as possible changes to their frequency or scope, 

remain unknown. In addition, the executive branch’s plans for replacing 

periodic reinvestigations with continuous evaluation have evolved over 

time. For example, the 2008 Security and Suitability Process Reform

report to the President outlined plans to replace the periodic 

reinvestigation model with continuous evaluation, conducting continuous 

evaluation annually or at least once every 5 years, depending on an 

individual’s security clearance level.56 The report identified a June 2009 

milestone to develop an implementation plan to transition from periodic 

 55GAO-14-704G. 

56The 2008 report described continuous evaluation as including an electronic review of 

scheduled updates of a subject’s application information, automated record checks, and 

an electronic assessment of the information acquired, as compared with more continuous 

automated record checks. The Joint Security and Suitability Reform Team, Security and 

Suitability Process Reform, December 2008.

Potential Effects of 

Continuous Evaluation on 

Periodic Reinvestigations 

Are Unknown
Page 34 GAO-18-117 Continuous Evaluation

reinvestigations to continuous evaluation, and as previously discussed, 

an estimated operational date of the fourth quarter of fiscal year 2010 

(see figure 1). The purpose of the change was to reveal security-relevant 

information earlier and to provide increased scrutiny on populations that 

could potentially represent risk to the government because they already 

have access to classified information. However, ODNI documentation 

states that continuous evaluation supplements and enhances, but does 

not replace, established personnel security processes.

Executive branch agencies have expressed varying views about potential 

changes to the periodic reinvestigation model. For example, DOD officials 

stated that with workload and funding issues, they see no alternative but 

to replace periodic reinvestigations for certain clearance holders with 

continuous evaluation, as the record checks conducted are the same for

both processes. In addition, DOD officials stated that they believe 

continuous evaluation will not only result in the more timely identification 

of security-relevant information, but will also help to change individuals’

behaviors—for example, that individuals will be more likely to self-report 

such information once they are enrolled in the program. DOD officials 

also noted that if changes are not made to the periodic reinvestigation 

process, the investigation backlog will persist, because continuous 

evaluation alerts will continue to add to the investigative workload.

In addition, in September 2016, PERSEREC issued a report on a study it 

conducted on the effectiveness, timeliness, and cost of various 

automated record checks-based investigative strategies as compared 

with traditional periodic reinvestigations. The analysis found that some of 

the automated record checks strategies were effective, improved the 

timeliness of issue detection, and lowered costs. However, DOD officials 

noted that because ODNI is the Security Executive Agent, it must 

approve the change to the investigative process. These officials stated 

that they hope to influence this change by demonstrating the 

effectiveness of continuous evaluation at DOD. Additionally, NBIB officials 

stated that continuous evaluation will increase their workload and costs, 

since it is an additional layer to the personnel security clearance process. 

Accordingly, they hope that ODNI will identify efficiencies that can be 

made to the process. Further, PAC Program Management Office officials 

stated that there may be changes to the periodic reinvestigation model in 

the future, but that any changes to the model will be determined by data 

and will be made under the authority of ODNI and OPM as the Security 

Executive Agent and the Suitability Executive Agent, respectively.
Page 35 GAO-18-117 Continuous Evaluation

Other agencies, such as State, do not share DOD’s view. For example, 

State officials stated that although a reduction in costs would result from 

replacing periodic reinvestigations with continuous evaluation, they have 

concerns that relevant information, such as state and local law 

enforcement records that are not yet automated, would be missed if they 

did not conduct periodic reinvestigations. Similarly, officials from the 

Department of Justice and the Department of Homeland Security stated 

that they do not intend to replace periodic reinvestigations, and that 

continuous evaluation is to be a supplement to the personnel security 

clearance process. However, officials from all three of these agencies 

stated that it may be possible to change the frequency or scope of 

periodic reinvestigations at some point in the future. ODNI officials stated 

that, at this time, they have no intention of replacing periodic 

reinvestigations with continuous evaluation, and that the Security 

Executive Agent Directive for continuous evaluation, once issued, will 

clarify that continuous evaluation is intended to supplement and not 

replace periodic reinvestigations.

In May 2017, ODNI officials stated that ODNI is not opposed to further 

improving the security clearance process, and that once continuous 

evaluation is operational, it plans to determine the efficiencies and 

mitigation of risks associated with the approach. Specifically, these 

officials stated that once continuous evaluation is further implemented 

and ODNI has gathered sufficient data—which they estimated would take 

about a year from May 2017—they can perform analysis and research to 

determine whether any changes are needed to the periodic 

reinvestigation model.57

 57The Intelligence Authorization Act for Fiscal Year 2014 required a related analysis. 

Specifically, section 505 required the Director of National Intelligence, in consultation with 

the Secretary of Defense and the Director of OPM, to develop a plan for updating the 

process for periodic reinvestigations consistent with a continuous evaluation program. 

Among other things, the plan was to include an analysis of the costs and benefits 

associated with conducting periodic reinvestigations and associated with replacing some 

or all periodic reinvestigations with a program of continuous evaluation. Pub. L. No. 113-

126, § 505 (2014). ODNI’s October 2016 report, Strategic Plan for Improving the Periodic 

Reinvestigation Process Consistent with Continuous Evaluation, states that many of the 

planned continuous evaluation record checks align with periodic reinvestigation 

requirements and that after assessing the cost and effectiveness of continuous evaluation 

the requirements for certain clearance holders could potentially be modified. Similarly, the 

Intelligence Authorization Act for Fiscal Year 2016 required ODNI to develop and 

implement a plan to eliminate the backlog of overdue periodic reinvestigations, including 

the use of random automated record checks of covered individuals. Pub. L. No. 114-113, 

§ 306(b) (2015).
Page 36 GAO-18-117 Continuous Evaluation

While executive branch agencies have different views about potential 

changes to the periodic reinvestigation process, officials from five of the 

seven executive branch agencies we spoke with identified the potential 

expenditure of increased resources, such as workload and costs, as a 

risk associated with the implementation of continuous evaluation. 

Specifically, all five agencies stated that continuous evaluation will 

increase their workloads—and therefore costs—if no other changes are 

made to the personnel security process. For example, DOD officials 

noted that adjudicator workloads will increase as new investigative 

leads—identified through continuous evaluation—require adjudication. 

Senior DOD officials stated that DOD cannot afford to conduct both 

continuous evaluation and periodic reinvestigations. Specifically, DOD 

estimates that implementing the 2012 Federal Investigative Standards 

requirement to conduct more frequent periodic reinvestigations for certain 

clearance holders will cost approximately $1.8 billion for fiscal years 2018 

through 2022. In addition, State officials stated that they anticipate that 

continuous evaluation will increase their personnel security workload 

because alerts will have to be validated, and potentially investigated, and 

then adjudicated.

Standards for Internal Control in the Federal Government states that 

management should identify, analyze, and respond to risks related to 

achieving defined objectives. Risk assessment is the identification and 

analysis of risks related to achieving defined objectives to form a basis for 

designing risk responses.58 In addition, the PMBOK® Guide states that 

entities should perform a quantitative risk analysis to numerically analyze 

the effect of identified risks on overall project objectives. The key benefit 

of this process is that it produces quantitative risk information to support 

decision-making in order to reduce project uncertainty.59

Although executive branch agencies have identified increased resources 

as a risk associated with implementing continuous evaluation, and ODNI 

has acknowledged that risk, ODNI, in coordination with the PAC, has not 

assessed the potential effects of continuous evaluation on an agency’s 

resources. Further, ODNI has not developed a plan, in consultation with 

implementing agencies, to address such effects, to include modifying the 

scope or frequency of periodic reinvestigations or replacing periodic 

 58GAO-14-704G.

59Project Management Institute, Inc. A Guide to the Project Management Body of 

Knowledge (PMBOK® Guide), Fifth Edition, 2013.
Page 37 GAO-18-117 Continuous Evaluation

reinvestigations for certain clearance holders. While ODNI is 

implementing continuous evaluation in a phased approach, having a plan 

in place to address the increased workload once continuous evaluation is 

fully implemented is critical to ensuring the sustainability and 

effectiveness of executive branch agencies’ personnel security programs. 

Further, without assessing the potential impacts on agency resources and 

developing a plan to address them—once ODNI has further defined the 

program—implementing continuous evaluation could further increase the 

periodic reinvestigation backlog and agency costs. With delays in 

determining continued eligibility, executive branch agencies are assuming 

greater risk, which runs counter to the purpose of continuous evaluation.

Continuous evaluation has been a key and long-standing initiative of 

security clearance reform efforts, intended to assist agencies in the timely 

identification of security-relevant information that may affect an 

individual’s continued eligibility for access to classified information. 

However, ODNI has not demonstrated the leadership necessary to make 

continuous evaluation a priority. Accordingly, the program’s 

implementation has been delayed for almost 7 years. Although ODNI has 

taken an initial step to implement it in a phased approach, it has not yet 

formalized the program in policy or provided an expanded definition of 

continuous evaluation to implementing agencies. In addition, ODNI has 

not yet determined key aspects of the program, including future phases of 

implementation and agency requirements. Key executive branch 

agencies have deemed information about the future phases necessary to 

plan for the implementation of continuous evaluation and to estimate 

potential costs. The absence of this information has limited their ability to 

prepare for the next phases of implementation. This could further delay 

the full implementation of continuous evaluation executive branch-wide 

and result in inconsistencies among agencies’ approaches. Specifically, 

in the absence of ODNI policy and comprehensive guidance, DOD and 

State continue to develop their current continuous evaluation programs. 

The ultimate effects of such inconsistencies could negatively affect 

reciprocity—another key government-wide security clearance reform 

effort.

Although ODNI is to have oversight of continuous evaluation, it has not 

incorporated it into its oversight program or developed a plan to ensure 

that agencies implement it. Without a Security Executive Agent Directive 

for continuous evaluation that provides an expanded definition of 

continuous evaluation and relevant terms to help ensure consistent use; a 

plan for implementing continuous evaluation across the executive branch, 

Conclusions
Page 38 GAO-18-117 Continuous Evaluation

that includes future phases of implementation and expectations for 

agencies; and a plan for monitoring program performance throughout the 

implementation process, as well as performance measures by which to 

track and report progress, ODNI is not well-positioned to ensure the 

success and effectiveness of the continuous evaluation initiative. Further, 

ODNI does not know whether it is meeting the critical purpose of filling the 

information gap between investigative cycles to identify risks to national 

security.

Executive branch timeliness in completing periodic reinvestigations has 

declined over the past five years. Further, the executive branch does not 

know whether the timeliness goals—set nearly a decade ago—are still 

relevant and appropriate, given changes to the personnel security 

clearance process. Without conducting an evidence-based review to 

ensure that goals for the timely completion of periodic reinvestigations are 

appropriate, executive branch agencies may not be planning sufficient 

time and resources to complete periodic reinvestigations and therefore 

may be challenged to ensure the continued eligibility of the entire national 

security workforce. Finally, executive branch agencies have identified 

increased resources, such as workload and costs, as a challenge to

implementing continuous evaluation. However, the executive branch has 

not determined the potential expected effects of continuous evaluation on 

periodic reinvestigations, and agencies have varying views about what, if 

any, additional changes should be made to the personnel security 

clearance process. Without an assessment of the potential effects of 

continuous evaluation and a plan to address those effects—once ODNI 

has further defined the program—agencies may not be able to effectively 

integrate continuous evaluation into their personnel security clearance 

programs, which in turn could lead to further delays in the clearance 

process.

We are making the following six recommendations to ODNI:

• The Director of National Intelligence should issue a Security Executive 

Agent Directive for continuous evaluation to formalize the program, 

which includes, among other things, an expanded definition of 

continuous evaluation in advance of the next phase of 

implementation. (Recommendation 1)

• The Director of National Intelligence should, in coordination with the 

Continuous Evaluation Working Group, develop an implementation 

plan for continuous evaluation across the executive branch that 

Recommendations for 

Executive Action
Page 39 GAO-18-117 Continuous Evaluation

includes a schedule with timeframes and expectations for agencies, 

such as the requirements (e.g., the size of the enrolled population in 

continuous evaluation) for future phases of implementation. 

(Recommendation 2)

• The Director of National Intelligence should develop a plan for 

monitoring continuous evaluation performance, to include assessing 

continuous evaluation at various phases of implementation. 

(Recommendation 3)

• The Director of National Intelligence should develop performance 

measures for continuous evaluation that agencies must track and 

determine a process and schedule for agencies to regularly report 

those measures to ODNI. At minimum, these performance measures 

should be clear, quantifiable, objective, and linked to measurable 

goals. (Recommendation 4)

• The Director of National Intelligence should, in coordination with the 

Deputy Director for Management of the Office of Management and 

Budget in the capacity as Chair of the Security, Suitability, and 

Credentialing Performance Accountability Council, conduct an 

evidence-based review of the timeliness goal of 195 days for 

completing the fastest 90 percent of periodic reinvestigations and the 

associated goals for the different phases of periodic reinvestigations, 

and adjust the goal if appropriate, taking into consideration available 

resources, the additional workload of continuous evaluation, and the 

risks associated with individuals retaining access to classified 

information without determining their continued eligibility. 

(Recommendation 5)

• The Director of National Intelligence should, once ODNI has further 

defined the continuous evaluation program, to include issuing a 

Security Executive Agent Directive and developing an implementation 

plan, in coordination with the Deputy Director for Management of the 

Office of Management and Budget in the capacity as Chair of the 

Security, Suitability, and Credentialing Performance Accountability 

Council, assess the potential effects of continuous evaluation on 

agency resources and develop a plan, in consultation with 

implementing agencies, to address those effects, such as modifying 

the scope of periodic reinvestigations, changing the frequency of 

periodic reinvestigations, or replacing periodic reinvestigations for 

certain clearance holders. (Recommendation 6)
Page 40 GAO-18-117 Continuous Evaluation

We provided a draft of this report to ODNI, DOD, OMB, State, NBIB, the 

Department of Justice, and the Department of Homeland Security for 

review and comment. Written comments from ODNI are reprinted in their 

entirety in appendix I. DOD, OMB, NBIB, and the Department of 

Homeland Security did not provide comments. ODNI, State, and the 

Department of Justice provided technical comments, which we 

incorporated in the report as appropriate.

In its written comments, ODNI stated that it generally concurred, with 

comments, with our six recommendations. However, ODNI stated that it 

did not concur with aspects of our overall conclusions and provided 

observations in four specific areas. We continue to believe that our 

conclusions are valid, as discussed below.

First, ODNI disagreed with our conclusion that it has not demonstrated 

the leadership necessary to make continuous evaluation a priority. ODNI 

noted that it has taken recent actions to better prioritize the 

implementation of continuous evaluation. While these recent steps are 

positive and may help position ODNI for success, historically ODNI has 

not demonstrated the leadership necessary to make the implementation 

of a continuous evaluation program a priority. Specifically, while ODNI 

refers to continuous evaluation as a new initiative, the original milestone 

for implementing the program was the fourth quarter of fiscal year 2010, 

which was not attained. Since then, as discussed in the report, a number 

of revised milestones for implementing the program have been missed. 

For example, the PAC, of which ODNI is a principal member, 

subsequently set a milestone for developing an initial continuous 

evaluation capability for other clearance holders by September 2014—

which was extended to December 2014—and a milestone for 

implementing the capability for other clearance holders by December 

2016. These milestones were also missed. As of August 2017, 

continuous evaluation has not yet been fully implemented, and ODNI has 

not set a milestone for when full implementation would occur. As such, we 

recommended specific actions that are needed to better position ODNI for 

success, including issuing a Security Executive Agent Directive for 

continuous evaluation, developing plans for implementing the program 

and monitoring its performance, and developing performance measures.

Second, ODNI disagreed with our conclusion that it has not yet 

determined key aspects of the continuous evaluation program, including 

future phases of implementation and agency requirements. ODNI stated 

that the Security Executive Agent Directive for continuous evaluation is 

undergoing interagency coordination and that it has provided executive 

Agency Comments 

and Our Evaluation
Page 41 GAO-18-117 Continuous Evaluation

branch agencies with interim guidance until that process is completed, 

which we acknowledge in the report. While ODNI has provided interim 

guidance for continuous evaluation, it only details the requirements for 

fiscal year 2017 and not for the future phases of implementation. In 

August 2017, after receiving a draft of our report, ODNI officials stated 

that they planned to provide additional guidance to agencies clarifying 

that the requirements for fiscal year 2018 will be the same as those for 

fiscal year 2017. While this correspondence, once issued, will help 

agencies with their immediate program planning, ODNI officials stated 

that they have not yet determined the requirements for fiscal year 2019 or 

beyond, which limits agencies’ abilities to plan beyond the next fiscal year 

for the future phases of implementation.

Additionally, ODNI stated that the technical development milestones of 

the Continuous Evaluation System it is developing are well-established, 

tracked, and shared with stakeholders. As discussed in the report, 

according to ODNI officials, they have established technical milestones 

for the development of ODNI’s Continuous Evaluation System. While this 

is an important step in implementing the program, ODNI has not 

developed similar programmatic milestones for the overall implementation 

of the program, such as when future phases of implementation will occur, 

to include full implementation. As discussed in the report, this has limited 

the ability of executive branch agencies to plan for implementation in 

accordance with ODNI’s phased approach. As a result, full 

implementation—which has been delayed for almost 7 years—may be 

further delayed.

Third, ODNI did not agree with our conclusion that although it is to have 

oversight of continuous evaluation, it has not incorporated it into its 

oversight program or developed a plan to ensure agencies implement it. 

In its response, ODNI identified its intention to take certain actions and 

future mechanisms that could position it to monitor continuous evaluation. 

Specifically, ODNI stated that continuous evaluation metrics will be 

collected and analyzed when the initial phase of continuous evaluation 

implementation ends on September 30, 2017. Additionally, ODNI stated 

that it will leverage a pending OMB budget data request and that its 

Security Executive Agent National Assessments Program will be 

responsible for analysis and oversight of agency implementation and 

operation of continuous evaluation.

However, as we note in the report, ODNI has not developed and 

distributed plans to monitor or assess the performance of continuous 

evaluation across the executive branch, including for the first phase of 
Page 42 GAO-18-117 Continuous Evaluation

implementation. As we note in our report, ODNI officials stated that ODNI 

did not oversee the pilots that were conducted by DOD and State, as they 

were performed at the discretion of those agencies. State officials noted 

that while they have shared lessons learned on their continuous 

evaluation pilot, they were not tasked to do so. While ODNI stated in its 

written comments that it has specific expertise in researching, measuring, 

analyzing, and monitoring personnel security performance across the 

executive branch, it has not yet demonstrated these actions with regard to 

continuous evaluation. For example, DOD—the executive branch agency 

with the majority of security clearance holders—has conducted research 

on continuous evaluation since 2001, piloted its program since October 

2014, and plans to increase the number of personnel enrolled in the 

program to 1 million by the end of calendar year 2017. However, ODNI, in 

the capacity as the Security Executive Agent, has not overseen DOD’s 

pilot.

Moreover, as discussed in the report, as of August 2017—10 months into 

fiscal year 2017—ODNI has not yet developed and distributed to 

executive branch agencies continuous evaluation performance measures. 

At the end of our review, in August 2017, ODNI officials stated that they 

have developed a draft list of metrics for continuous evaluation for fiscal 

year 2017 and that once the metrics are finalized, they will issue guidance 

to executive branch agencies requesting them to report these metrics to 

ODNI. While metrics can help to establish a baseline and inform aspects 

of a program’s status—and ODNI’s development of draft metrics is a 

positive step—performance measures are linked to a goal and inform how 

well an agency is doing against that goal. As ODNI has not developed 

and distributed performance measures that are clear, quantifiable, and 

objective, and that are linked to measurable goals prior to initiating, or 

earlier in the first phase of implementation, executive branch agencies 

may not be positioned to collect and report these metrics at the end of the 

fiscal year. Additionally, as discussed in the report, according to ODNI 

officials, while they would like to incorporate continuous evaluation into 

their Security Executive Agent National Assessments Program, it is not 

currently part of the program. While ODNI has identified steps that could 

position it to monitor continuous evaluation in the future, it has not yet 

implemented mechanisms to monitor and measure program performance.

Fourth, ODNI did not agree with our conclusions that it is not wellpositioned to ensure the success and effectiveness of the continuous 

evaluation initiative, and that it does not know if it is meeting the critical 

purpose of filling the information gap between investigative cycles to 

identify risks to national security. However, in its written comments, ODNI 
Page 43 GAO-18-117 Continuous Evaluation

stated that successful implementation of continuous evaluation across the 

executive branch requires formal Security Executive Agent policy 

guidance, implementation and technical guidance and milestones, 

performance measures, and a monitoring program, which we 

recommended in the report. ODNI states that it is well-postured to 

achieve these goals, and refers to its intention to apply Security Executive 

Agent National Assessments Program best practices as a mechanism to 

use to monitor and ensure compliance. Although this action could be a 

step in better positioning ODNI as continuous evaluation implementation 

further proceeds, as noted above and in our report, ODNI has not yet 

finalized, distributed, and implemented these and other actions to ensure 

that it is currently positioned to ensure success, even while it has initiated 

the first phase of continuous evaluation implementation.

As noted in our report, although ODNI has taken steps to implement 

continuous evaluation in a phased approach, executive branch efforts to 

implement continuous evaluation have been a long-standing component 

of overall security clearance reform. The actions ODNI intends to take as

it further implements continuous evaluation, as well as the mechanisms it 

identified, may better position it and the implementing agencies for 

success. However, given the challenges that the executive branch has 

faced in implementing continuous evaluation thus far and the continued 

delays it has faced, without a fully defined program in place, we believe 

that our conclusions remain valid.

Finally, in its written comments, ODNI suggested a revision to our sixth 

recommendation. Specifically, ODNI suggested adding an explicit 

timeframe for completing the action. We believe that ODNI is best 

positioned to set an appropriate timeframe for completion based on its 

familiarity with the progress of the program and, as such, did not 

incorporate this change in our report. We agree with ODNI that 

establishing such a timeframe is a positive step.

We are sending copies of this report to the appropriate congressional 

committees, the Director of National Intelligence, the Secretary of 

Defense, the Director of OMB, the Secretary of State, the Secretary of 

Homeland Security, the Director of OPM, the Director of NBIB, the 

Attorney General, the Director of the Federal Bureau of Intelligence, and 

the Director of the Bureau of Alcohol, Tobacco, Firearms, and Explosives. 

In addition, this report will also be available at no charge on the GAO 

website at http://www.gao.gov.
Page 44 GAO-18-117 Continuous Evaluation

If you or your members of your staff have any questions regarding this 

report, please contact me at (202) 512-3604 or farrellb@gao.gov. GAO 

staff who made significant contributions to this report are listed in 

appendix II.

Brenda S. Farrell

Director, Defense Capabilities and Management
Page 45 GAO-18-117 Continuous Evaluation

List of Requesters

The Honorable Mark R. Warner

Vice Chairman

Select Committee on Intelligence

United States Senate

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

United States House of Representatives

The Honorable Devin Nunes

Chairman

Permanent Select Committee on Intelligence

United States House of Representatives

The Honorable Adam Schiff

Ranking Member

Permanent Select Committee on Intelligence

United States House of Representatives

The Honorable Peter T. King

Chairman

Subcommittee on Counterterrorism and Intelligence

Committee on Homeland Security

United States House of Representatives
Appendix I: Comments from the Office of the 

Director of National Intelligence

Page 46 GAO-18-117 Continuous Evaluation

Appendix I: Comments from the Office of the 

Director of National Intelligence
Appendix I: Comments from the Office of the 

Director of National Intelligence

Page 47 GAO-18-117 Continuous Evaluation
Appendix I: Comments from the Office of the 

Director of National Intelligence

Page 48 GAO-18-117 Continuous Evaluation
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 49 GAO-18-117 Continuous Evaluation

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov

In addition to the contact named above, Kimberly C. Seay (Assistant 

Director), Chris Businsky, Molly Callaghan, Jenny Chanley, Dawn 

Godfrey, Saida Hussain, James Krustapentus, Michael Shaughnessy, 

Rachel R. Stoiko, John Van Schaik, Cheryl Weissman, and Jina Yu made 

significant contributions to this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 50 GAO-18-117 Continuous Evaluation

High-Risk Series: Progress on Many High-Risk Areas, While Substantial 

Efforts Needed on Others. GAO-17-317. Washington, D.C.: February 15, 

2017.

Personnel Security Clearances: Funding Estimates and GovernmentWide Metrics Are Needed to Implement Long-Standing Reform Efforts. 

GAO-15-179SU. Washington, D.C.: April 23, 2015.

Personnel Security Clearances: Additional Guidance and Oversight 

Needed at DHS and DOD to Ensure Consistent Application of Revocation 

Process. GAO-14-640. Washington, D.C.: September 8, 2014.

Personnel Security Clearances: Actions Needed to Ensure Quality of 

Background Investigations and Resulting Decisions. GAO-14-138T. 

Washington, D.C.: February 11, 2014.

Personnel Security Clearances: Opportunities Exist to Improve Quality 

Throughout the Process. GAO-14-186T. Washington, D.C.: November 

13, 2013.

Personnel Security Clearances: Full Development and Implementation of 

Metrics Needed to Measure Quality of Process. GAO-14-157T. 

Washington, D.C.: October 31, 2013.

Personnel Security Clearances: Further Actions Needed to Improve the 

Process and Realize Efficiencies. GAO-13-728T. Washington, D.C.: June 

20, 2013.

Managing for Results: Agencies Should More Fully Develop Priority Goals 

under the GPRA Modernization Act. GAO-13-174. Washington, D.C.: 

April 19, 2013.

Security Clearances: Agencies Need Clearly Defined Policy for 

Determining Civilian Position Requirements. GAO-12-800. Washington, 

D.C.: July 12, 2012.

Personnel Security Clearances: Continuing Leadership and Attention Can 

Enhance Momentum Gained from Reform Effort. GAO-12-815T. 

Washington, D.C.: June 21, 2012.

2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue.

GAO-12-342SP. Washington, D.C.: February 28, 2012.

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Page 51 GAO-18-117 Continuous Evaluation

Background Investigations: Office of Personnel Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Savings.

GAO-12-197. Washington, D.C.: February 28, 2012.

GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington, 

D.C.: February 17, 2011.

High-Risk Series: An Update. GAO-11-278. Washington, D.C.: February 

16, 2011.

Personnel Security Clearances: Overall Progress Has Been Made to 

Reform the Governmentwide Security Clearance Process. GAO-11-232T. 

Washington, D.C.: December 1, 2010.

Personnel Security Clearances: Progress Has Been Made to Improve 

Timeliness but Continued Oversight Is Needed to Sustain Momentum. 

GAO-11-65. Washington, D.C.: November 19, 2010.

DOD Personnel Clearances: Preliminary Observations on DOD’s 

Progress on Addressing Timeliness and Quality Issues. GAO-11-185T. 

Washington, D.C.: November 16, 2010.

Personnel Security Clearances: An Outcome-Focused Strategy and 

Comprehensive Reporting of Timeliness and Quality Would Provide 

Greater Visibility over the Clearance Process. GAO-10-117T. 

Washington, D.C.: October 1, 2009.

Personnel Security Clearances: Progress Has Been Made to Reduce 

Delays but Further Actions Are Needed to Enhance Quality and Sustain 

Reform Efforts. GAO-09-684T. Washington, D.C.: September 15, 2009.

Personnel Security Clearances: An Outcome-Focused Strategy Is 

Needed to Guide Implementation of the Reformed Clearance Process.

GAO-09-488. Washington, D.C.: May 19, 2009.

DOD Personnel Clearances: Comprehensive Timeliness Reporting, 

Complete Clearance Documentation, and Quality Measures Are Needed 

to Further Improve the Clearance Process. GAO-09-400. Washington, 

D.C.: May 19, 2009.

High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January 

2009.
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Page 52 GAO-18-117 Continuous Evaluation

Personnel Security Clearances: Preliminary Observations on Joint 

Reform Efforts to Improve the Governmentwide Clearance Eligibility 

Process. GAO-08-1050T. Washington, D.C.: July 30, 2008.

Personnel Clearances: Key Factors for Reforming the Security Clearance 

Process. GAO-08-776T. Washington, D.C.: May 22, 2008.

Employee Security: Implementation of Identification Cards and DOD’s 

Personnel Security Clearance Program Need Improvement.

GAO-08-551T. Washington, D.C.: April 9, 2008.

Personnel Clearances: Key Factors to Consider in Efforts to Reform 

Security Clearance Processes. GAO-08-352T. Washington, D.C.: 

February 27, 2008.

DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts 

to Improve Clearance Processes for Industry Personnel. GAO-08-470T. 

Washington, D.C.: February 13, 2008.

DOD Personnel Clearances: Improved Annual Reporting Would Enable 

More Informed Congressional Oversight. GAO-08-350. Washington, D.C.: 

February 13, 2008.

DOD Personnel Clearances: Delays and Inadequate Documentation 

Found for Industry Personnel. GAO-07-842T. Washington, D.C.: May 17, 

2007.

High-Risk Series: An Update. GAO-07-310. Washington, D.C.: January 

2007.

DOD Personnel Clearances: Additional OMB Actions Are Needed to 

Improve the Security Clearance Process. GAO-06-1070. Washington, 

D.C.: September 28, 2006.

DOD Personnel Clearances: Some Progress Has Been Made but Hurdles 

Remain to Overcome the Challenges That Led to GAO’s High-Risk 

Designation. GAO-05-842T. Washington, D.C.: June 28, 2005.

High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January 

2005.

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