PERSONNEL 

SECURITY 

CLEARANCES

Additional Actions 

Needed to Ensure

Quality, Address 

Timeliness, and 

Reduce Investigation 

Backlog 

Report to Congressional Addressees

December 2017

GAO-18-29

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-29, a report to 

congressional addressees

December 2017

PERSONNEL SECURITY CLEARANCES

Additional Actions Needed to Ensure Quality,

Address Timeliness, and Reduce Investigation 

Backlog 

What GAO Found

Executive branch agencies have made progress reforming the security clearance 

process, but long-standing key initiatives remain incomplete. Progress includes 

the issuance of common federal adjudicative guidelines and updated strategic 

documents to help sustain the reform effort. However, agencies face challenges 

in implementing certain aspects of the 2012 Federal Investigative Standards—

criteria for conducting background investigations—including establishing a 

continuous evaluation program, and the issuance of a reciprocity policy to guide 

agencies in honoring previously granted clearances by other agencies remains

incomplete. Executive branch agencies have taken recent steps to prioritize over 

50 reform initiatives to help focus agency efforts and facilitate their completion. In 

addition, while agencies have taken steps to establish government-wide 

performance measures for the quality of investigations, neither the Director of 

National Intelligence (DNI) nor the Security, Suitability, and Credentialing

Performance Accountability Council (PAC) have set a milestone for their 

completion. Without establishing such a milestone, completion may be further 

delayed and agencies will not have a schedule against which they can track 

progress or to which they are accountable. 

The number of executive branch agencies meeting established timeliness 

objectives for initial security clearances decreased from fiscal years 2012 

through 2016, and reporting has been limited. For example, 59 percent of the

executive branch agencies reviewed by GAO reported meeting investigation and 

adjudication timeliness objectives for initial top secret clearances in fiscal year 

2012, compared with 10 percent in fiscal year 2016. The Intelligence Reform and 

Terrorism Prevention Act of 2004 (IRTPA) required the executive branch to 

submit an annual report, through 2011, to appropriate congressional committees 

on, among other things, the time required to conduct investigations, adjudicate 

cases, and grant clearances. Since the requirement ended, reporting has been 

limited to a portion of the intelligence community. Without comprehensive 

reporting, Congress will not be able to monitor agencies’ progress in meeting 

timeliness objectives, identify corrections, or effectively execute its oversight role. 

The National Background Investigations Bureau (NBIB), within the Office of 

Personnel Management (OPM), has taken steps to improve the background 

investigation process, but it faces operational challenges in addressing the 

investigation backlog and increasing investigator capacity. While NBIB has taken 

positive steps to improve its oversight of background investigation contracts, it 

faces operational challenges in reducing the investigation backlog—which grew 

from 190,000 cases in August 2014 to more than 709,000 in September 2017. 

To increase capacity NBIB has hired additional federal investigators and 

increased the number of its investigative fieldwork contracts, but it has not 

developed a plan for reducing the backlog or established goals for increasing 

total investigator capacity. Without such a plan and goals, the backlog may 

persist and executive branch agencies will continue to lack the cleared personnel 

needed to help execute their respective missions. The bill for the National 

Defense Authorization Act for Fiscal Year 2018, passed by Congress in 

November 2017, would authorize DOD to conduct its own background 

investigations. 

View GAO-18-29. For more information, 

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

farrellb@gao.gov.

Why GAO Did This Study

A high-quality personnel security 

clearance process is necessary to 

minimize the risks of unauthorized 

disclosures of classified information 

and to help ensure that securityrelevant information is identified and 

assessed. The passage of IRTPA 

initiated an effort to reform the security 

clearance process government-wide. 

This report assesses the extent to 

which (1) executive branch agencies 

made progress reforming the security 

clearance process; (2) executive 

branch agencies completed timely

initial clearances from fiscal years 

2012-2016, and reported on timeliness;

and (3) NBIB has taken steps to 

improve the background investigation 

process and address the backlog. 

GAO reviewed documentation; 

analyzed timeliness data; and 

interviewed officials from the four PAC 

Principals and NBIB. This is a public 

version of a sensitive report that GAO

issued in December 2017. Information 

that the DNI and OPM deemed 

sensitive has been omitted.

What GAO Recommends

Congress should consider reinstating 

the IRTPA requirement for clearance 

timeliness reporting. GAO is also 

making six recommendations, 

including that the DNI and other PAC 

Principals set a milestone for 

establishing measures for investigation 

quality, and that NBIB develop a plan 

to reduce the backlog and establish 

goals for increasing total investigator 

capacity. NBIB concurred with the 

recommendations made to it. The DNI 

did not concur with GAO’s conclusions 

and recommendations. GAO continues 

to believe they are valid, as discussed 

in the report. 
Page i GAO-18-29 Personnel Security Clearance Reform

Letter 1

Background 7

Executive Branch Agencies Have Made Progress Reforming the 

Security Clearance Process, but Long-Standing Key Initiatives 

Remain Incomplete 15

Agencies Meeting Timeliness Objectives for Initial Clearances 

Decreased Since Fiscal Year 2012; a Government-wide 

Approach Has Not Been Developed to Improve Timeliness; and 

Reporting Has Been Limited 30

NBIB Has Taken Steps to Improve the Background Investigation 

Process but Faces Operational Challenges in Addressing the 

Investigation Backlog and Workforce Planning 41

Conclusions 63

Matter for Congressional Consideration 65

Recommendations for Executive Action 65

Agency Comments and Our Evaluation 66

Appendix I Status of Prior GAO Personnel Security Clearance Recommendations 

to Executive Branch Agencies as of November 2017 76

Appendix II Overview of Selected Personnel Security Clearance Provisions in the 

Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) 81

Appendix III GAO Work on Personnel Security Clearance Quality and Executive 

Branch Efforts to Establish Government-wide Measures for the 

Quality of Investigations 83

Appendix IV Timeliness of Executive Branch Periodic Reinvestigations 85

Appendix V Comments from the Office of the Director of National Intelligence 87

Contents
Page ii GAO-18-29 Personnel Security Clearance Reform

Appendix VI Comments from the Office of Personnel Management 90

Appendix VII GAO Contact and Staff Acknowledgments 94

Related GAO Products 95

Tables

Table 1: Percent of Executive Branch Agencies Meeting 

Timeliness Objectives for the Fastest 90 Percent of Initial 

Cases for at Least Three of Four Quarters from Fiscal 

Years 2012-2016 33

Table 2: Open GAO Security Clearance Recommendations as of 

November 2017 77

Table 3: Percent of Executive Branch Agencies Meeting 

Timeliness Goals for the Fastest 90 Percent of Periodic 

Reinvestigations for at Least Three of Four Quarters of 

Fiscal Years 2012-2016 85

Figures

Figure 1: Timeline of Efforts to Update Federal Investigative 

Standards 21

Figure 2: Milestones for the Issuance of Continuous Evaluation 

Policy and Implementation of the Program 22

Figure 3: Milestones Related to the Issuance of a Personnel 

Security Clearance Reciprocity Policy 24

Figure 4: Milestones Related to the Development of GovernmentWide Personnel Security Clearance Investigation Quality 

Standards, Tool, and Measures 28

Figure 5: National Background Investigation Bureau’s Backlog of 

Background Investigations, August 2014 to September 

2017 55

Figure 6: Timeline Regarding Selected GAO Work and Executive 

Branch Efforts to Establish Government-wide Measures 

for the Quality of Investigations 84
Page iii GAO-18-29 Personnel Security Clearance Reform

Abbreviations

CIO Chief Information Officer

COR contracting officer’s representative

DOD Department of Defense

FIS Federal Investigative Services

GPRA Government Performance and Results Act of 1993

IT information technology

IRTPA Intelligence Reform and Terrorism Prevention Act of 2004

ODNI Office of the Director of National Intelligence

OMB Office of Management and Budget

OPM Office of Personnel Management

NBIB National Background Investigations Bureau

NBIS National Background Investigation System

PAC Security, Suitability, and Credentialing Performance

Accountability Council

QART Quality Assessment Reporting Tool 

USIS U.S. Investigations Services, LLC

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately.
Page 1 GAO-18-29 Personnel Security Clearance Reform

441 G St. N.W.

Washington, DC 20548

December 12, 2017

Congressional Addressees

The enactment of the Intelligence Reform and Terrorism Prevention Act 

of 2004 (IRTPA) initiated a reform effort that includes goals and 

requirements for improving the personnel security clearance process 

government-wide.1 A high-quality personnel security clearance process is 

necessary to minimize the risks of unauthorized disclosures of classified 

information and to help ensure that information about individuals with 

criminal histories or other questionable behavior is identified and 

assessed. In 2014, emphasis on security clearance reform was renewed 

following high-profile events. These events included the June 2013 

disclosure of classified documents by a former National Security Agency 

contractor, and the September 2013 shooting at the Washington Navy 

Yard by an individual who had both access to the facility and a security 

clearance. However, these reform efforts immediately faced significant 

challenges. In 2014, the Office of Personnel Management (OPM) 2

experienced issues with respect to its largest background investigation 

contractor, and it did not exercise an option to extend the contract.3

According to OPM, it conducts about 95 percent of the federal 

government’s background investigations. Additionally, in 2015, OPM was 

subjected to a massive security breach of its information technology (IT) 

systems. Moreover, OPM reports that it has a significant backlog of 

background investigations, which has raised congressional concerns 

 1

Pub. 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. 

2

The National Background Investigations Bureau (NBIB) is the entity within OPM with 

responsibility for conducting personnel background investigations. It absorbed the Federal 

Investigative Services—the prior entity within OPM that conducted background 

investigations—when it became operational on October 1, 2016.

3

Specifically, OPM did not exercise an option to extend the contract for its largest 

background investigator, U.S. Investigations Services, LLC (USIS), following allegations 

related to the contractor’s completion of quality reviews of background investigations. In 

August 2015, the Department of Justice announced that USIS and its parent company 

agreed to a $30 million settlement in exchange for a release of liability under the False 

Claims Act; accordingly, the claims resolved by the settlement agreement were allegations 

only, and there was no determination of liability.

Letter
Page 2 GAO-18-29 Personnel Security Clearance Reform

about delays in processing security clearances and risks to national 

security.4

Executive Order 13467 established the Security, Suitability, and 

Credentialing Performance Accountability Council (PAC) as the 

government-wide structure responsible for driving the implementation of 

and overseeing security and suitability reform efforts.5 The Executive 

Order also designated the Deputy Director for Management of the Office 

of Management and Budget (OMB) as the Chair of the PAC, and the 

Director of National Intelligence as the Security Executive Agent 

responsible for developing consistent policy and procedures for, among 

other matters, timely investigations and adjudications.6

We have issued numerous reports highlighting issues related to 

personnel security clearances.7 For example, in 2017, we reported on 

challenges related to the implementation of an executive branch-wide 

continuous evaluation program, and in 2015 we reported on the need to 

take steps to improve the reciprocity of security clearances among 

 4

See, e.g., H.R. Rep. No. 115-251, at 19-20 (2017); S. Rep. No. 115-125, at 218-20 

(2017); H.R. Rep. No. 115-200, at 100-01 (2017); H.R. Rep. No. 115-258, at 2 (2017). 

5

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

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). 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. Credentialing refers to the process that the 

executive branch uses to issue identification used to access federally controlled facilities 

and information systems. Suitability and credentialing are not used to determine eligibility 

for access to classified information. 

6

Exec. Order No. 13,467, §§ 2.2(b), 2.3(c)(ii), 73 Fed. Reg. at 38,105-06. 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. 

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.

7

A listing of these reports is included in the Related GAO Products page at the end of this 

report.
Page 3 GAO-18-29 Personnel Security Clearance Reform

executive branch agencies.8 Appendix I provides the status of 

recommendations we have made to improve the personnel security 

clearance process. Moreover, in our 2015 and 2017 updates to our HighRisk series, we identified the Department of Defense’s (DOD) personnel 

security clearances as a previous high-risk area that we continue to 

monitor to determine whether the improvements we have noted are 

sustained and whether any new issues have emerged.9

We began our work under the authority of the Comptroller General to 

conduct evaluations on his own initiative. The Ranking Member of the 

Senate Committee on Homeland Security and Governmental Affairs, the 

Vice Chairman of the Senate Select Committee on Intelligence, and 

Senator Jon Tester subsequently submitted requests to be addressees 

for this review. Additionally, Senate Report 114-280 included a provision 

that we review the transition, oversight, and operation of the newly 

established National Background Investigations Bureau (NBIB), within 

OPM.10 This report assesses the extent to which: (1) executive branch 

agencies have made progress in reforming the security clearance 

 8

Continuous evaluation is 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. GAO, Personnel Security Clearances: 

Plans Needed to Fully Implement and Oversee Continuous Evaluation of Clearance 

Holders, GAO-18-117 (Washington, D.C.: Nov. 21, 2017). Generally, 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. GAO, Personnel Security Clearances: Funding Estimates and 

Government-Wide Metrics Are Needed to Implement Long-Standing Reform Efforts, 

GAO-15-179SU (Washington, D.C.: Apr. 23, 2015) (FOUO/LE/INVESTIGATORY FILES 

PRIVILEGED).

9

In 2005, we designated the Department of Defense’s (DOD) personnel security clearance 

program a high-risk area because of delays and backlogs in the personnel security 

clearance process. We continued that designation in the 2007 and 2009 updates to our 

High-Risk list because delays continued and we found problems with the quality of OPMproduced investigation reports and DOD adjudication documentation. In our 2011 HighRisk report, we removed DOD’s personnel security clearance program from the High-Risk 

list because DOD took actions to improve the timeliness of clearance processing, issue 

guidance on adjudication standards, and develop and implement quality assessment tools 

for background investigations and adjudications. GAO, High-Risk Series: Progress on 

Many High-Risk Areas, While Substantial Efforts Needed on Others, GAO-17-317 

(Washington, D.C.: Feb. 15, 2017); and GAO, High-Risk Series: An Update, GAO-15-290 

(Washington, D.C.: Feb. 11, 2015). 

10S. Rep. No. 114-280, at 99 (2016) (accompanying the Financial Services and General 

Government Appropriations Bill, 2017, S. 3067); see also 163 Cong. Rec. H3782 (daily 

ed. May 3, 2017) (Joint Explanatory Statement, accompanying the Consolidated 

Appropriations Act, 2017, Pub. L. No. 115-31 (2017)).
Page 4 GAO-18-29 Personnel Security Clearance Reform

process; (2) executive branch agencies met established timeliness 

objectives for initial personnel security clearances from fiscal year 2012 

through fiscal year 2016, and reported on their timeliness; and (3) NBIB 

has taken steps to improve the background investigation process and 

address the investigation backlog.

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

December 7, 2017.11 ODNI and OPM deemed some of the information in 

our December report to be sensitive, which must be protected from public 

disclosure. Therefore, this report omits sensitive information. 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.

To address our first objective, we compared the PAC’s strategic 

framework for fiscal years 2017 through 2021 and quarterly progress 

updates against recommendations from the PAC’s 120-day and 90-day 

reviews and PAC-identified reform milestones. Additionally, we 

interviewed PAC Program Management Office officials as well as officials 

from OMB, OPM, the Office of the Director of National Intelligence 

(ODNI), and DOD, due to their roles as principal members of the PAC. 

We also interviewed officials from the Departments of Homeland Security, 

Justice, and State with regard to their plans to implement continuous 

evaluation—a key reform effort. We compared this information against 

Standards for Internal Control in the Federal Government related to the 

identification of risks and monitoring activities; criteria for assessing highrisk areas, such as leadership commitment; and best practices for 

comprehensive and effective IT strategies identified in our prior work.12

We also reviewed the executive branch’s guide for quality standards and 

tools, and we identified and applied criteria developed from our body of 

 11GAO, Personnel Security Clearances: Additional Actions Needed to Address Quality, 

Timeliness, and Investigation Backlog, GAO-18-26SU (Washington, D.C.: Dec. 7, 2017)

(FOUO).

12GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). GAO-17-317. Best practices for comprehensive and 

effective IT strategies are identified in GAO, Information Technology: FDA Has Taken 

Steps to Address Challenges but Needs a Comprehensive Strategic Plan, GAO-16-182 

(Washington, D.C.: Dec. 17, 2015); and GAO, Library of Congress: Strong Leadership 

Needed to Address Serious Information Technology Management Weaknesses, 

GAO-15-315 (Washington, D.C.: March 31, 2015).
Page 5 GAO-18-29 Personnel Security Clearance Reform

work on using results-oriented management tools to help achieve desired 

program outcomes.13

To address our second objective, we reviewed relevant statutes and 

ODNI guidance addressing the timeliness of background investigations 

and adjudications as well as reporting requirements. We also reviewed 

available executive branch reports on timeliness. We obtained data from 

ODNI on the timeliness of initial personnel security clearances for fiscal 

years 2012 through 2016 for specific executive branch agencies.14 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.15 As such, we reported 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 through 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 data to determine the extent to which agencies are meeting 

IRTPA timeliness objectives for completing the fastest 90 percent of initial 

secret clearance determinations within 60 days (40 days to investigate 

 13See, for example, GAO, Managing for Results: Critical Issues for Improving Federal 

Agencies’ Strategic Plans, GAO/GGD-97-180 (Washington, D.C.: September 1997); Major 

Management Challenges and Program Risks: A Governmentwide Perspective, 

GAO-03-95 (Washington, D.C.: January 2003); and Military Transformation: Clear 

Leadership, Accountability, and Management Tools Are Needed to Enhance DOD’s 

Efforts to Transform Military Capabilities, GAO-05-70 (Washington, D.C.: December 

2004).

14The number of agencies included in our review was omitted because the information is 

sensitive. 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 for fiscal years 2012 through 2016. ODNI officials stated that some 

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

would be a manual and intensive process.

15Office of Inspector General, U.S. Department of State, Evaluation of the Department of 

State’s Security Clearance Process, July 2017.
Page 6 GAO-18-29 Personnel Security Clearance Reform

and 20 days to adjudicate).16 Appendix II provides additional details on 

IRTPA as it relates to personnel security clearances. We also analyzed 

the extent to which agencies are meeting ODNI revised timeliness 

objectives for completing the fastest 90 percent of initial top secret 

clearance determinations. In addition, we reviewed relevant ODNI and 

PAC reports for information regarding the timeliness of investigations and 

compared it against criteria for assessing high-risk areas such as 

monitoring and demonstrated progress.17 Finally, we interviewed PAC, 

ODNI, and NBIB officials regarding timeliness challenges, efforts to 

improve timeliness, and the reporting of timeliness information.

To address our third objective, we analyzed studies, organizational 

charts, plans, and other documents related to the establishment, 

transition, oversight, and operation of NBIB. We compared these 

documents against key principles of strategic workforce planning that we 

have identified in prior work, such as determining the critical skills and 

competencies needed to achieve current and future programmatic results 

and developing strategies that are tailored to address gaps in numbers of 

people, skills and competencies, and deployment of the workforce; 

selected OPM workforce planning best practices; OMB policy that 

requires agencies to take actions to ensure that they have sufficient 

internal capability to maintain control over functions that are core to the 

agency’s mission and operations; and criteria for assessing high-risk 

areas such as leadership commitment, capacity, action plans, monitoring, 

and demonstrated progress.18 Additionally, given the OPM data breach in 

2015 and a decision to shift security clearance IT functions to a new 

DOD-developed and -operated National Background Investigation

System (NBIS), we examined efforts to operationalize the new system 

 16IRTPA required the development of a plan to reduce the length of the personnel security 

clearance process. To the extent practical, the plan was to require that each authorized 

adjudicative agency make a determination on at least 90 percent of all applications for a 

personnel security clearance within an average of 60 days after receipt of the completed 

application by an authorized investigative agency, including not longer than 40 days to 

complete the investigative phase and not longer than 20 days to complete the adjudicative 

phase. Pub. L. No. 108-458, § 3001(g) (2004) (codified at 50 U.S.C. § 3341(g)).

17GAO-17-317.

18GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003). OPM, Migration Planning Guidance 

Information Documents: Workforce Planning Best Practices (Washington, D.C.: Oct. 7, 

2011). OMB, Office of Federal Procurement Policy, Policy Letter 11-01, Performance of 

Inherently Governmental and Critical Functions, 76 Fed. Reg. 56,227, 56,228 (Sept. 12, 

2011). GAO-17-317.
Page 7 GAO-18-29 Personnel Security Clearance Reform

and leveraged our recent work examining IT security at OPM.19 Further, 

we reviewed and analyzed current and former NBIB/ Federal Investigative 

Services (FIS) background investigation fieldwork services contracts to 

determine investigative capacity and steps taken to improve timeliness. 

FIS is the prior entity within OPM that conducted background 

investigations for the federal government. We interviewed NBIB officials 

to determine how NBIB was providing oversight of investigative contracts 

and how that process changed in the wake of the 2014 issues related to a 

major investigative service provider. We also interviewed NBIB, PAC, and 

DOD officials regarding the transition, oversight, and operation of NBIB.

The performance audit upon which this report is based was conducted 

from July 2016 through December 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. We subsequently worked with ODNI and OPM from November 

2017 to December 2017 to prepare this report for public release. This 

public version was also prepared in accordance with these standards.

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.20 The level of 

classification denotes the degree of protection required for information 

and the amount of damage that unauthorized disclosure could reasonably 

 19GAO, Information Security: OPM Has Improved Controls, but Further Efforts are 

Needed, GAO-17-614 (Washington, D.C.: Aug. 3, 2017).

20A 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

Personnel Security 

Clearances
Page 8 GAO-18-29 Personnel Security Clearance Reform

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.21 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. As of October 1, 2015, 

the latest date for which data are available, approximately 4.2 million 

government and contractor employees, at nearly 80 executive branch 

agencies, were eligible to hold a security clearance.22

IRTPA. As noted earlier, IRTPA initiated a reform effort that includes 

goals and requirements for improving the personnel security clearance 

process government-wide. For example, IRTPA established specific

objectives for the timeliness of security clearance processing.23 It also 

required that all security clearance background investigations and 

determinations completed by an authorized investigative agency or 

authorized adjudicative agency be accepted by all agencies (known as 

reciprocity), subject to certain exceptions.24 Appendix II provides 

additional details on IRTPA as it relates to personnel security clearances.

Relevant Executive Orders. The personnel security clearance process 

and reform efforts are governed by various executive orders. Key 

executive orders affecting personnel security clearance reform include 

Executive Orders 12968, 13467, 13741, and 13764, which, among other 

things, provide definitions, processes, responsibilities, and authorities 

related to eligibility for access to classified information, suitability and 

fitness for government employment, and security clearance reform.25

 21See Exec. Order No. 13,526, § 1.2, 75 Fed. Reg. 707, 707-08 (Dec. 29, 2009). 

22ODNI, 2015 Annual Report on Security Clearance Determinations. As of July 2017, 

ODNI had not yet issued its Annual Report on Security Clearance Determinations for fiscal 

year 2016.

23See Pub. L. No. 108-458, § 3001(g) (2004) (codified at 50 U.S.C. § 3341(g)). The 

timeliness objectives were included in a provision requiring the development of a plan to 

reduce the length of the personnel security clearance process. 

24Pub. L. No. 108-458, § 3001(d) (codified at 50 U.S.C. § 3341(d)).

25See generally Exec. Order No. 12,968, 60 Fed. Reg. 40,245 (Aug. 2, 1995); Exec. Order 

No. 13,467, 73 Fed. Reg. 38,103 (June 30, 2008); Exec. Order No. 13,741, 81 Fed. Reg. 

68,289 (Sept. 29, 2016); Exec. Order No. 13,764, 82 Fed. Reg. 8115 (Jan. 17, 2017).

IRTPA, Executive Orders, 

and Recent Legislation
Page 9 GAO-18-29 Personnel Security Clearance Reform

Aspects of the reform effort covered by the Executive Orders include the 

establishment of the PAC and NBIB, the transfer of IT responsibilities to 

DOD, the definition of continuous evaluation, and the addition and 

amendment of certain roles and responsibilities.

Recent legislation. Section 951 of the National Defense Authorization 

Act for Fiscal Year 2017 requires, among other things, the Secretary of 

Defense to develop an implementation plan for the Defense Security 

Service to conduct background investigations for certain DOD 

personnel—presently conducted by OPM—after October 1, 2017.26 The 

Secretary of Defense was to submit the plan to the congressional defense 

committees by August 1, 2017. DOD provided the plan to the 

congressional defense committees on August 25, 2017. Section 951 also 

requires the Secretary of Defense and the Director of OPM to develop a 

plan by October 1, 2017, to transfer investigative personnel and 

contracted resources to DOD in proportion to the workload if the plan for 

the department to conduct background investigations were 

implemented.27

In November 2017, after the conclusion of our audit work, Congress 

passed a bill for the National Defense Authorization Act for Fiscal Year 

2018. The bill includes a provision that, among other things, would 

authorize DOD to conduct its own background investigations and would 

require DOD to begin carrying out the implementation plan required by 

section 951 of the National Defense Authorization Act for Fiscal Year 

2017 by October 1, 2020. It would also require the Secretary of Defense, 

in consultation with the Director of OPM, to provide for a phased 

transition.28

 26Specifically, the implementation plan would cover background investigations for DOD 

personnel whose investigations are adjudicated by the DOD Consolidated Adjudications 

Facility. See Pub. L. No. 114-328, § 951(a) (2016). According to the Consolidated 

Adjudications Facility, its mission is to determine security clearance eligibility of nonintelligence agency DOD personnel, with a customer base including all military service 

members, military applicants, civilian employees, and consultants affiliated with DOD.

27§ 951(a)(2). 

28See H.R. Rep. No. 115-404, at 245-46 (2017) (Conf. Rep., relaying section 925 of the 

bill, as passed by the Senate on November 16 and the House of Representatives on 

November 14).
Page 10 GAO-18-29 Personnel Security Clearance Reform

To help guide the personnel security clearance reform effort, in June 

2007, the Director of National Intelligence and the Under Secretary of 

Defense for Intelligence established the Joint Reform Team through a 

memorandum of agreement to execute joint reform efforts to achieve 

IRTPA timeliness objectives and improve the processes related to 

granting security clearances and determining suitability for government 

employment. The team consisted of cognizant entities within OMB, OPM, 

ODNI, and DOD. The team worked on improving the security clearance 

process governmentwide, including providing progress reports on the 

reform effort, recommendations for research priorities, and oversight of 

the development and implementation of an information technology 

strategy, among other things.

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.29

Its specific responsibilities include ensuring the enterprise-wide alignment 

of suitability, security, credentialing, and, as appropriate, fitness 

processes; working with agencies to implement continuous performance 

improvement programs, policies, and procedures; establishing annual 

goals and progress metrics; and preparing annual reports on results.30 In 

addition, the PAC is to develop and continuously reevaluate and revise 

outcome-based metrics that measure the quality, efficiency, and 

effectiveness of the vetting enterprise, among other things.31 As noted 

above, the Deputy Director for Management of OMB serves as the Chair 

of the PAC and has authority, direction, and control over its functions.

In addition to the Deputy Director for Management of OMB, the PAC has 

three additional principal members: the Director of National Intelligence, 

the Director of OPM, and the Under Secretary of Defense for Intelligence.

• Director of National Intelligence: The Director of National 

Intelligence serves as the Security Executive Agent and is responsible 

 29See Exec. Order No. 13,467, § 2.2, 73 Fed. Reg. 38,103, 38,105 (June 30, 2008).

30Fitness is the level of character and conduct determined necessary for an individual to 

perform work for or on behalf of a federal agency as an employee in the excepted service 

(other than a position subject to suitability), as a contractor employee, or as a nonappropriated fund employee. 

31Exec. Order No. 13,467, § 2.4(d)(i), (iv), (xii), as amended through Exec. Order No. 

13,764, 82 Fed. Reg. 8115, 8122-23 (Jan. 17, 2017). 

Governance Structure for 

Security Clearance 

Reform Effort
Page 11 GAO-18-29 Personnel Security Clearance Reform

for, among other things, developing and issuing uniform and 

consistent policies and procedures to ensure the effective, efficient, 

timely, and secure completion of investigations, polygraphs, and 

adjudications related to determinations of eligibility for access to 

classified information or eligibility to hold a sensitive position.32 In this 

role, the Director of National Intelligence is also to direct the oversight 

of such investigations, reinvestigations, and adjudications.

• Director of OPM: The Director of OPM serves as the Suitability and 

Credentialing Executive Agent and is responsible for, among other 

things, prescribing suitability standards and minimum standards of 

fitness for employment.33

• Under Secretary of Defense for Intelligence: The Under Secretary 

of Defense for Intelligence became the fourth principal member of the 

PAC with the issuance of Executive Order 13741 in September 

2016.34 Additionally, Executive Order 13467, as amended, assigns 

DOD responsibility for designing, developing, operating, defending, 

and continuously updating and modernizing, as necessary, IT 

systems that support all background investigation processes 

conducted by NBIB.35

In addition, in April 2014, the PAC established the Program Management 

Office to implement personnel 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. 

Prior to the establishment of the Program Management Office, the PAC 

was supported by the Joint Reform Team as well as various 

subcommittees that addressed specific tasks, such as investigator and 

adjudicator training and the development of performance measures.

 32Exec. Order No. 13,467, § 2.5(e)(iii), as amended by 82 Fed. Reg. at 8125.

33Exec. Order No. 13,467, § 2.5(b)(i), as amended by 82 Fed. Reg. at 8123.

3481 Fed. Reg. 68,289 (Sept. 29, 2016) (amending Executive Order 13467). 

35Exec. Order No. 13,467, § 2.6(b), as amended through Exec. Order No. 13,764, 82 Fed. 

Reg. at 8126. 
Page 12 GAO-18-29 Personnel Security Clearance Reform

Since 2014, there have been a number of key efforts to reform the 

personnel security clearance process. For example, following the 

September 2013 shooting at the Washington Navy Yard, the PAC 

conducted a 120-day interagency review to assess risks inherent in the 

federal government’s security, suitability, and credentialing processes. 

The February 2014 report resulting from that review highlighted 37 

recommendations to improve, among other things, the federal 

government’s processes for granting security clearances.36 Some of the 

recommendations address longstanding issues of the reform effort—such 

as improving data sharing between local, state, and federal law 

enforcement; and others are consistent with previous GAO 

recommendations—such as reporting measures for the quality of 

background investigations.37 The status of the implementation of these 

recommendations is discussed later in this report.

In addition, in March 2014, OMB established Insider Threat and Security 

Clearance Reform as a government-wide, cross-agency priority goal in 

part to improve interagency coordination and implementation within the 

area of personnel security clearances.38 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. From the second quarter of fiscal year 2014 to the fourth 

quarter of fiscal year 2016, the PAC has reported quarterly on, among 

 36OMB, February 2014 Suitability and Security Processes Review—Report to the 

President (February 2014).

37In May 2009, we found that the executive branch’s annual reports to Congress on the 

personnel security clearance process provided decision makers with limited data on 

quality. We recommended that the Deputy Director for Management of OMB, in the 

capacity as Chair of the PAC, include metrics on quality in future versions of the IRTPArequired annual report to Congress on personnel security clearances. OMB concurred 

with the recommendation; however, the 2010 report to Congress did not include quality 

metrics, and the IRTPA reporting requirement expired in 2011. GAO, 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). 

38The 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 July 2017.

Key Efforts to Reform the 

Personnel Security 

Clearance Process
Page 13 GAO-18-29 Personnel Security Clearance Reform

other things, the status of key milestones and the timeliness of initial 

investigations and periodic reinvestigations for the executive branch as a 

whole. As part of the cross-agency priority goal, the PAC identified 

various sub goals on which to focus its work. The sub goals were 

originally based on recommendations from the 120-day review and, 

according to PAC Program Management Office officials, were later 

updated to reflect the PAC’s strategic plans. The current sub goals are as 

follows: trusted workforce, modern vetting, secure and mission-capable 

IT, and continuous process improvement.

Further, in 2015, in response to the OPM data breach and at the request 

of the President, the PAC conducted a second review—a 90-day 

review—of the government’s suitability and security processes. In the 

January 2016 summary of the review, the administration identified four 

actions to create a more secure and effective federal background 

investigations infrastructure. Specifically, it identified the need to: (1) 

establish NBIB as the new federal entity to strengthen how the 

government performed background investigations; (2) leverage IT 

expertise at DOD for processing background investigations and protecting 

against threats; (3) update governance authorities, roles, and 

responsibilities; and (4) drive continuous performance improvement to 

address evolving threats. The status of these actions is discussed later in 

this report.

NBIB maintains an in-house federal investigator workforce, but according 

to NBIB, as of July 2017, it relied on contract investigators to conduct 

about 60 percent of the background investigations it provides to customer 

agencies, such as DOD. In 2011, OPM awarded three indefinite 

delivery/indefinite quantity contracts to three contractors to conduct 

investigation fieldwork services—CACI Premier Technology, Inc., 

KeyPoint Government Solutions, Inc., and U.S. Investigations Services, 

LLC (USIS).39 According to NBIB, USIS was responsible for about 65 

percent of the contractor workload.

 39Indefinite delivery/indefinite quantity contracts are used when the exact quantities and 

timing for products or services are not known at the time of award. An indefinite 

delivery/indefinite quantity contract provides for the issuance of orders, which are used to 

procure specific products or services during the period of the contract. Under an indefinite 

delivery/indefinite quantity contract, the government must order, and the contractor must 

provide, a minimum agreed-upon quantity. In addition, the contractor must provide any 

other quantities ordered, up to a stated maximum.

NBIB’s Use of Contract 

Investigators to Conduct 

Background Investigations
Page 14 GAO-18-29 Personnel Security Clearance Reform

In September 2014, OPM decided not to exercise the option for the USIS 

contract for fiscal year 2015. Eleven months prior, in October 2013, the 

Department of Justice had announced that the government would 

intervene in a civil suit against USIS, filed by a former employee under 

the False Claims Act. The government alleged that the contractor had 

circumvented contractually required quality reviews of completed 

background investigations to increase the company’s revenues and 

profits.40 In August 2015, the Department of Justice announced that USIS 

and its parent company had agreed to a $30 million settlement in 

exchange for a release of liability under the False Claims Act; 

accordingly, the claims resolved by the settlement agreement were 

allegations only, and there was no determination of liability. In June 2015, 

OPM conducted a review of USIS cases and found that the investigations 

for which USIS did not conduct the quality review were generally less 

complex cases. In addition, these cases had a lower return rate from 

OPM reviewers.

In September 2016, OPM awarded new indefinite delivery/indefinite 

quantity contracts for investigation fieldwork services to four companies—

CACI Premier Technology, Inc., KeyPoint Government Solutions, Inc., 

CSRA LLC, and Securitas Critical Infrastructure Services, Inc. The 2-year 

base period for these contracts runs to the end of fiscal year 2018, and 

OPM may exercise three 1-year option periods for each contract, with the 

first beginning on October 1, 2018.

 40Under the 2011 fieldwork contracts, each contractor was required to perform a presubmission quality review of all its investigations prior to releasing them to OPM. USIS 

also had a support contract with OPM to provide final closing reviews before the cases 

were sent to customer agencies. 
Page 15 GAO-18-29 Personnel Security Clearance Reform

Executive branch agencies have made progress in reforming the 

personnel security clearance process by, for example, issuing guidance, 

such as Quality Assessment Standards to guide background 

investigations, updated strategic documents to sustain the momentum of 

the reform effort, and adjudicative guidelines to establish single, common 

adjudicative criteria for security clearances. However, agencies face 

challenges in implementing certain aspects of the 2012 Federal 

Investigative Standards, including full implementation of continuous 

evaluation, and the issuance of a reciprocity policy remains incomplete. In 

addition, while the executive branch has taken steps toward establishing 

performance measures for the quality of government-wide personnel 

security clearance investigations, there is no milestone for their 

completion.

The PAC has made progress in reforming the personnel security 

clearance process, as demonstrated through actions taken in response to 

recommendations and milestones outlined in four key reform effort 

documents: (1) the February 2014 120-day review; (2) the 2015 90-day 

review; (3) the Insider Threat and Security Clearance Reform crossagency priority goal quarterly progress updates; and (4) the PAC’s 

strategic framework for fiscal years 2017 through 2021.

120-day review. According to PAC documentation, as of August 2017, 

the PAC had implemented 73 percent of the 120-day review 

recommendations. For example, in response to a recommendation from 

the review, ODNI and OPM jointly issued Quality Assessment Standards 

in January 2015, which establish federal guidelines for assessing the 

quality of national security and suitability investigations. The 

establishment of the standards is intended to facilitate the measurement 

and continued improvement of investigative quality across the executive 

branch. In response to another related recommendation, ODNI developed 

the Quality Assessment Reporting Tool (QART), through which agencies 

will report on the completeness of investigations. According to ODNI 

officials, the QART was implemented in October 2016, and full 

implementation is expected by the end of calendar year 2017.

90-day review. By January 2017, the PAC had taken steps to implement 

all of the actions identified in the January 2016 summary of the 90-day 

review. Specifically, Executive Order 13741, issued in September 2016, 

established NBIB, within OPM, to replace FIS as the primary executive 

branch service provider for background investigations. It also identified 

DOD as the entity responsible for designing, developing, operating, and 

Executive Branch 

Agencies Have Made 

Progress Reforming 

the Security 

Clearance Process, 

but Long-Standing 

Key Initiatives 

Remain Incomplete

The PAC Has Made 

Progress Reforming the 

Personnel Security 

Clearance Process
Page 16 GAO-18-29 Personnel Security Clearance Reform

securing IT systems that support NBIB’s background investigations. 

Additionally, the Executive Order elevated the Under Secretary of 

Defense for Intelligence to a full principal member of the PAC and 

directed the PAC to review and update governance, authorities, roles, 

and responsibilities.41 Subsequently, Executive Order 13764, issued in 

January 2017, further clarified relevant authorities, roles, and 

responsibilities, among other things.42 Further, according to PAC Program 

Management Office officials, the PAC has taken steps to implement 

continuous process improvements, such as developing a research and 

innovation program through which it has undertaken a number of projects 

aimed at improving the personnel security clearance process. In addition,

the PAC established a continuous performance improvement initiative to 

develop mechanisms to improve the quality and efficiency of the end-toend security, suitability, and credentialing vetting processes. As of July 

2017, the PAC had identified seven categories of performance measures 

for the end-to-end security, suitability, and credentialing processes—such 

as timeliness, volume, and cost-efficiency—which it planned to implement 

in a phased approach.

Cross-agency priority goal. From the second quarter of fiscal year 2014 

through the fourth quarter of fiscal year 2016, the PAC reported quarterly 

on the status of key initiatives, among other things, as part of the Insider 

Threat and Security Clearance Reform cross-agency priority goal.43 For 

each initiative, the PAC reported the milestone due date, the milestone 

status—on track, complete, at risk, missed, or not started—and the 

responsible agencies. As of the PAC’s last publicly reported quarterly 

update, for the fourth quarter of fiscal year 2016, 8 of 33 initiatives were 

listed as complete. According to PAC Program Management Office 

officials, they have continued to track the status of these milestones 

 41See Exec. Order No. 13,741, § 1(d), (e), (f), 81 Fed. Reg. at 68,289-90 (amending Exec. 

Order No. 13,467) (Sept. 29, 2016); id. § 2, 81 Fed. Reg. at 68,291 (directing the PAC to 

review and update executive-level authorities across the vetting enterprise and submit 

recommendations to the President). 

42See generally Exec. Order No. 13,764, 82 Fed. Reg. 8115 (Jan. 17, 2017) (amending 

Exec. Order No. 13,467 and Exec. Order No. 12,968, among others).

43The PAC has not reported publicly on the status of the reform effort since the fourth 

quarter of fiscal year 2016 since the content on performance.gov, the vehicle through 

which the PAC has issued its quarterly updates, was being reviewed based on the 

presidential transition and, as of August 2017, was undergoing revision as agencies 

develop updated goals and objectives for release in February 2018 with the President’s 

next budget submission to Congress.
Page 17 GAO-18-29 Personnel Security Clearance Reform

internally, and almost half of the initiatives—16 of 33—were listed as 

complete as of the third quarter of fiscal year 2017. These initiatives 

include the establishment of a Federal Background Investigations Liaison 

Office within NBIB to oversee and resolve issues between federal, state, 

and local law enforcement entities when collecting criminal history record 

information for background investigations, and developing plans to 

implement improved investigator and adjudicator training.

Strategic framework. The PAC has issued three documents that serve 

as its updated strategic framework for the next 5 years.44 In July 2016, it 

issued its Strategic Intent for Fiscal Years 2017 through 2021, which 

identifies the overall vision, goals, and 5-year business direction to 

achieve an entrusted workforce. In October 2016, it issued an updated 

PAC Enterprise IT Strategy, which provides the technical direction to 

provide mission-capable and secure security, suitability, and credentialing 

IT systems.45 According to PAC Program Management Office officials, the 

third document—the PAC Strategic Intent and Enterprise IT Strategy 

Implementation Plan (Implementation Plan)—was distributed to executive 

branch agencies in February 2017. The Implementation Plan documents 

the key initiatives, targets, and measures for achieving the strategic 

vision.

In March 2009, the Joint Reform Team issued an Enterprise IT Strategy, 

but the PAC’s own February 2014 120-day review found that this strategy 

stopped short of actions needed to develop enterprise-wide IT capabilities 

to modernize, integrate, and automate agency capabilities and retire 

legacy systems. It further stated that absent a strategy for integrated IT 

capabilities, agencies created disparate tools designed only to meet their 

 44In May 2009, we found that the security clearance reform effort lacked a strategic 

framework that included important elements of a successful transformation. We 

recommended that the Deputy Director for Management of OMB, in the capacity as Chair 

of the PAC, establish a strategic framework for the reform effort. OMB partially concurred 

with the recommendation, and in February 2010, the reform effort established the Security 

and Suitability Process Reform Strategic Framework. The framework identified a mission 

statement and seven strategic goals: for reciprocity, a database, automation, timeliness, 

alignment, continuous evaluation, and quality. The framework also included a strategic 

communications plan that provided a formal communication strategy to sustain reform 

initiatives, and it discussed information technology initiatives. GAO, 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).

45Security, Suitability, and Credentialing Performance Accountability Council, Strategic 

Intent Fiscal Years 2017-2021 (July 2016); and Enterprise Information Technology 

Strategy Fiscal Years 2017-2021 (October 2016). 
Page 18 GAO-18-29 Personnel Security Clearance Reform

specific requirements and recommended the development and execution 

of an enterprise reform IT strategy to ensure interoperability and improved 

sharing of relevant information. We compared the PAC’s 2016 Enterprise 

IT Strategy against leading practices for comprehensive and effective IT 

strategies and found that it generally aligns with such practices.46 For 

example, it contains results-oriented goals and strategies for agencies to 

achieve desired results, and describes interdependencies within and 

across projects.

In addition to these four key areas, PAC members noted additional 

progress in reforming the personnel security clearance process. 

Specifically, ODNI officials highlighted the development of seven Security 

Executive Agent Directives, five of which have been issued as of August 

2017, related to the use of polygraphs and social media in the 

investigative process, among other things. For example, in December 

2016, the Director of National Intelligence issued Security Executive 

Agent Directive 4, National Security Adjudicative Guidelines.47 Effective in 

June 2017, the directive is meant to establish the single, common 

adjudicative criteria for all covered individuals who require initial or 

continued eligibility for access to classified information or eligibility to hold 

a sensitive position. DOD officials stated that having standardized 

adjudicative criteria such as these guidelines constitutes an important 

step in helping to ensure reciprocity. Additionally, a senior PAC Program 

Management Office official noted that the PAC has designated eight 

executive branch-wide IT shared service capabilities, such as the 

electronic adjudication of certain background investigations and a new 

electronic questionnaire for national security positions. According to this 

official, the latter two shared services are expected to be rolled out in 

 46These leading practices are identified in GAO, Information Technology: FDA Has Taken 

Steps to Address Challenges but Needs a Comprehensive Strategic Plan, GAO-16-182 

(Washington, D.C.: Dec. 17, 2015); and GAO, Library of Congress: Strong Leadership 

Needed to Address Serious Information Technology Management Weaknesses, 

GAO-15-315 (Washington, D.C.: Mar. 31, 2015). 

47Office of the Director of National Intelligence, Security Executive Agent Directive 4: 

National Security Adjudicative Guidelines (Dec. 10, 2016) (effective June 8, 2017).
Page 19 GAO-18-29 Personnel Security Clearance Reform

2017, with the remaining six shared services being rolled out as they 

become available.48

While the PAC has reformed many parts of the personnel security 

clearance process, implementing certain key aspects of the 2012 Federal 

Investigative Standards, including changing the frequency of periodic 

reinvestigations for certain clearance holders and establishing a 

continuous evaluation program, remain incomplete. In addition, the 

issuance of ODNI’s draft reciprocity policy has been delayed.

2012 Federal Investigative Standards. These standards outline criteria 

for conducting background investigations to determine eligibility for a 

security clearance and are intended to ensure cost-effective, timely, and 

efficient protection of national interests and to facilitate reciprocal 

recognition of the resulting investigations.49 In April 2015, we reported 

that executive branch agencies with responsibilities for security 

clearances and suitability determinations had twice approved updated 

Federal Investigative Standards to replace the 1997 Standards, but that 

progress in implementing the updated standards had been limited.50

Specifically, as part of the reform effort that began after the passage of 

IRTPA, the Director of National Intelligence and the Acting Director of 

OPM, in their roles as Security and Suitability Executive Agents, signed 

new Federal Investigative Standards on December 13, 2008, and stated 

that the anticipated initial deployment of the standards was to begin in the 

third quarter of fiscal year 2009. However, the 2008 Federal Investigative 

 48According to PAC Program Management Office officials, the other six shared services 

include: (1) position designation—an automated application to help determine the 

appropriate investigation level needed for a position; (2) low-side repository—a central 

location to store investigative and adjudicative information; (3) investigation—development 

of investigative reports and advanced analytics; (4) low-side information exchange—

allows for the sharing of vetting information; (5) adjudication management—supports the 

adjudication of investigations, including case management and reporting capabilities; and 

(6) post-determination management—supports the functions that security managers, 

suitability managers, or similar resources perform once an adjudicative determination has 

been rendered (e.g., visit requests). 

49In addition to eligibility for access to classified information, the standards cover 

investigations to determine eligibility for logical and physical access, suitability for 

government employment, eligibility to hold a sensitive position, and fitness to perform work 

for or on behalf of the government as a contractor employee. 

50GAO-15-179SU.

Key Aspects of the 2012 

Federal Investigative 

Standards and the 

Development of a 

Reciprocity Policy Remain 

Incomplete
Page 20 GAO-18-29 Personnel Security Clearance Reform

Standards were not implemented, according to ODNI officials, because 

key terms were not clearly defined and required further clarification.

In December 2012, the Director of National Intelligence and Director of 

OPM approved updated Federal Investigative Standards. Among other 

things, the 2012 Federal Investigative Standards identify five investigative 

tiers. According to 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.51 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.52 The updated standards also changed 

the frequency of periodic reinvestigations for certain clearance holders. 

The Federal Investigative Standards milestone for full operating capability 

is the end of fiscal year 2017. Specific details on this topic were omitted 

because the information is sensitive. See figure 1 for a timeline of efforts 

made since 1997 to implement updated Federal Investigative Standards.

 51OPM, Federal Investigations Notice No. 16-02, Federal Investigative Standards for Tier 

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

52OPM, 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). 
Page 21 GAO-18-29 Personnel Security Clearance Reform

Figure 1: Timeline of Efforts to Update Federal Investigative Standards

a

While the milestone for full operating capability of the 2012 Federal Investigative Standards is 

September 30, 2017, the standards were not fully implemented by that date due to delays in 

implementing the change in frequency for periodic reinvestigations for certain clearance holders and 

in the full implementation of continuous evaluation. A revised date for full operating capability has not 

been determined.

The 2012 standards include continuous evaluation as a new requirement 

for certain clearance holders. This is a key executive branch initiative to 

more frequently identify and assess security-relevant information between 

periodic reinvestigations. Efforts to implement a continuous evaluation 

program were included in the implementation documents from the prior 

reform effort following approval of the 2008 Federal Investigative 

Standards, including an operational milestone for implementing a 

continuous evaluation program by the fourth quarter of fiscal year 2010. 

ODNI has adjusted the milestones for implementing the program and 

issuing a Security Executive Agent Directive for continuous evaluation 

several times. For example, in April 2015, we reported that ODNI planned 

to issue a continuous evaluation policy by September 2016 and to 

implement a continuous evaluation capability for certain clearance 

holders by December 2016.53 However, in November 2017 we found that 

while ODNI has taken an initial step to implement continuous evaluation 

in a phased approach across the executive branch, it has not yet issued a 

 53GAO-15-179SU. 
Page 22 GAO-18-29 Personnel Security Clearance Reform

Security Executive Agent Directive for continuous evaluation or 

determined when the future phases of implementation will occur.54

According to ODNI officials, as of August 2017, this directive was

undergoing interagency coordination and would be issued upon 

completion of that process. As of August 2017, continuous evaluation had

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

when it would occur. In November 2017, we recommended, among other 

things, that the Director of National Intelligence issue a continuous 

evaluation directive and develop an implementation plan. ODNI generally 

concurred with those recommendations.55 Figure 2 provides an overview 

of the adjusted executive branch milestones for issuing a continuous 

evaluation policy and implementing a continuous evaluation program, 

including developing a technical capability.

Figure 2: Milestones for the Issuance of Continuous Evaluation Policy and Implementation of the Program

 54GAO-18-117. 

55GAO-18-117. 
Page 23 GAO-18-29 Personnel Security Clearance Reform

Reciprocity policy. In 2004, IRTPA required that all security clearance 

background investigations and determinations completed by an 

authorized investigative agency or authorized adjudicative agency be 

accepted by all agencies, subject to certain exceptions.56 As reported in a 

cross-agency priority goal quarterly update in fiscal year 2016, the 

milestone for ODNI to issue and promulgate an updated national security 

reciprocity policy was September 2016. Security clearance reciprocity is 

statutorily required by IRTPA, subject to certain exceptions,57 and it is 

currently implemented by executive orders and guidance across 

executive-branch agencies. To consolidate existing reciprocity guidance, 

ODNI planned to issue a comprehensive, national-level security 

clearance reciprocity policy intended to resolve challenges associated 

with consistent, timely reciprocity processing across the executive branch. 

However, the issuance date has been postponed multiple times—the 

original milestone was September 2013—and as of July 2017, ODNI had 

not yet issued a reciprocity policy or identified a new milestone for its 

issuance. In July 2017, ODNI officials stated that a draft reciprocity policy 

was pending entry into the formal interagency coordination process and 

would be issued upon completion of that process.58 However, ODNI 

officials were unable to provide an estimated issuance date because, 

according to the officials, the length of the interagency coordination 

process can vary. PAC Program Management Office officials noted that 

issuance delays are due, in part, to the development of related personnel 

security policies, including continuous evaluation, with which the 

reciprocity policy must be aligned. Figure 3 shows milestones for the 

issuance of the reciprocity policy.

 56Pub. L. No. 108-458, § 3001(d)(1), (5) (2004) (codified at 50 U.S.C. § 3341(d)(1), (5)). 

IRTPA also precluded authorized investigative or adjudicative agencies from conducting 

an investigation for the purposes of determining whether to grant a security clearance 

when a current investigation or clearance of equal level already exists or has been 

granted by another authorized adjudicative agency. § 3001(d)(4) (codified at 50 U.S.C. § 

3341(d)(4)). 

57Pub. L. No. 108-458, § 3001(d) (codified at 50 U.S.C. § 3341(d)). The Intelligence 

Authorization Act for Fiscal Year 2013 required the President to develop a strategy and 

schedule for carrying out the requirements of section 3001(d) of IRTPA. Pub. L. No. 112-

277, § 306 (2013). We reported in April 2015 that ODNI developed the Strategy and 

Schedule for Security Clearance Reciprocity in response to this requirement. 

GAO-15-179SU. 

58According to ODNI officials, the reciprocity policy will be issued as Security Executive 

Agent Directive 7.
Page 24 GAO-18-29 Personnel Security Clearance Reform

Figure 3: Milestones Related to the Issuance of a Personnel Security Clearance Reciprocity Policy

In November 2010, we found that although executive-branch agency 

officials stated that reciprocity is regularly granted, agencies did not have 

complete records on the extent to which previously granted security 

clearance investigations and adjudications are honored governmentwide.59 Further, we found that agencies lacked a standard metric for 

tracking reciprocity. We recommended that the Deputy Director for 

Management, OMB, in the capacity as chair of the PAC, develop 

comprehensive metrics to track when reciprocity is granted and report the 

findings from the expanded tracking to Congress. OMB concurred with 

our recommendation. However, in April 2015, we found that executive 

branch agencies still did not consistently track when reciprocity is or is not 

granted, nor did they have metrics in place to measure how often 

reciprocity occurs.60 ODNI officials stated that they planned to develop 

them by 2016. Although the Director of National Intelligence had 

requested Intelligence Community elements take steps to begin capturing 

reciprocity data in December 2014, such baseline data needed to support 

measures for reciprocity were not being collected government-wide. We 

recommended, in 2015, that the Director of National Intelligence require 

the development of baseline data to support measures for reciprocity.61

 59GAO, Personnel Security Clearances: Progress Has Been Made to Improve Timeliness 

but Continued Oversight Is Needed to Sustain Momentum. GAO-11-65. (Washington,

D.C.: Nov. 19, 2010). 

60GAO-15-179SU. 

61GAO-15-179SU.
Page 25 GAO-18-29 Personnel Security Clearance Reform

These data would help to identify and monitor changes in reciprocity 

government-wide. ODNI did not state whether it concurred with the 

recommendation, and as of November 2017, it had not been 

implemented.

PAC officials stated that the greatest challenge of the reform effort is the 

breadth and complexity of the issues it is trying to resolve, noting that the 

reform effort involves nearly every executive branch agency. In addition, 

these officials stated that sometimes agencies focus on short-term highvisibility issues instead of longer-term efforts, which are needed for 

systemic change. ODNI officials also noted the complexities of reforming 

the personnel security clearance process and working toward a whole-ofgovernment solution. These officials noted that the reform efforts involve 

coordination among a number of agencies across the executive branch, 

which is both time and resource intensive. Both PAC Program 

Management Office and ODNI officials also identified limited agency 

resources and competing priorities—across executive branch agencies—

as additional challenges.

The PAC has taken recent steps to help address some of these 

challenges to continued progress, which could facilitate the completion of 

the key initiatives discussed above. For example, in its Implementation 

Plan the PAC has identified approximately 50 initiatives on which it will 

focus its work over the next 5 fiscal years and has aligned those activities 

with its four strategic categories of initiatives—trusted workforce, modern 

vetting, secure and modern mission-capable IT, and continuous 

performance improvement. However, according to ODNI officials, during 

their review of a draft of the Implementation Plan, they raised concerns 

about the number of initiatives and highlighted the need to provide greater 

prioritization of the initiatives to help better focus efforts. For example, 

some agencies are assigned as a primary owner of multiple initiatives. 

Specific details of the number of initiatives to which agencies are 

assigned were omitted because the information is sensitive.

PAC Program Management Officials stated that, to alleviate these 

concerns, they subsequently identified two to four priority initiatives within 

each of the four categories to help focus agency efforts. These officials 

further stated that the PAC intends to update and reissue a condensed 

version of its Implementation Plan annually so that it can make revisions 

as issues that affect these priorities, such as reduced budgets, occur. 

These 11 priority initiatives are identified in the PAC’s Implementation 

Plan which, according to PAC Program Management Office officials, the 

PAC finalized and circulated to executive branch agencies in February 
Page 26 GAO-18-29 Personnel Security Clearance Reform

2017. For example, establishing a continuous evaluation capability and 

strengthening and aligning guidelines for the reciprocal recognition of 

existing vetting decisions are listed among the PAC’s priority initiatives. 

Given the limited agency resources cited by ODNI and PAC Program 

Management Office officials and other key competing efforts, such as 

improving investigation timeliness, the PAC’s prioritization of initiatives 

could help to refocus efforts on the most critical areas of the reform effort, 

and could provide agencies with a manageable number of initiatives on 

which to prioritize their efforts.

Our prior work on personnel security clearances has identified concerns 

about the quality of background investigations and has highlighted the 

need to build quality throughout the process for almost 20 years.62

Additionally, we found that executive branch reports on the personnel 

security clearance process contained limited information on quality in the 

process. In May 2009, we recommended, among other things, that the 

Deputy Director for Management of OMB, in the capacity as Chair of the 

PAC, include in an IRTPA-required report to Congress quality metrics to 

provide more transparency on personnel security clearances.63 OMB 

concurred with that recommendation. However, the 2010 report to 

Congress did not include quality metrics, and the IRTPA reporting 

requirement expired in 2011. Appendix III provides an overview of our 

work in this area and of executive branch efforts to establish governmentwide performance measures for the quality of background investigations.

According to Executive Order 13467, the PAC is to establish annual goals 

and progress metrics related to security and suitability processes and

continuous performance improvement.64 This focus on performance 

measures is consistent with our body of work on using results-oriented 

management tools to help achieve desired program outcomes—derived 

from our work on how to effectively implement the Government 

Performance and Results Act (GPRA) and the GPRA Modernization Act 

 62See figure 6 for a comprehensive timeline of our prior work related to personnel security 

clearance process quality.

63GAO-09-400. 

64See Exec. Order No. 13,467, § 2.4(d)(iv), as amended through Exec. Order No. 13,764, 

82 Fed. Reg. 8115, 8122 (Jan. 17, 2017). Under Executive Order 13467, as amended, the 

PAC is also to develop and continuously reevaluate and revise outcome-based metrics 

that measure the quality, efficiency, and effectiveness of the vetting enterprise. Exec. 

Order No. 13,467, § 2.4(d)(xii), as amended.

Executive Branch Has 

Taken Steps to Establish 

Government-wide 

Performance Measures for 

the Quality of Background 

Investigations, but It Is 

Unclear When This Effort 

Will Be Completed
Page 27 GAO-18-29 Personnel Security Clearance Reform

of 2010. This body of work provides agencies with a framework for 

effectively managing program performance to achieve desired outcomes, 

including establishing performance measures.65 In addition, Standards for 

Internal Control in the Federal Government states that management 

should establish and review performance measures and monitor internal 

control systems.66 Further, we found in previous work that interim 

milestones can be used to show progress toward implementing efforts or 

to make adjustments when necessary. Developing and using specific 

milestones and timelines to guide and gauge progress toward achieving 

an agency’s desired results informs management of the rate of progress 

toward achieving goals, and whether adjustments need to be made in 

order to maintain progress within given timeframes.67

As of July 2017, the executive branch had taken two of three steps to 

establish government-wide measures for the quality of investigations. 

First, as previously discussed, ODNI and OPM issued Quality 

Assessment Standards for background investigations in January 2015 to 

establish standard criteria for agencies to consistently evaluate complete 

investigations. The standards were developed through an interagency 

effort chaired by ODNI, OPM, and DOD. These standards define 

complete investigations as those in which all required components were 

obtained in full and any known issues—such as criminal activity—were 

resolved per the standards. DOD officials highlighted issue resolution—

having enough useful information about the circumstances surrounding a 

given issue to make an adjudicative determination—as a persistent 

challenge with background investigations for personnel security 

clearances, and as key to determining investigation quality.

Second, ODNI developed the QART, through which agencies will be able 

to report on the completeness of investigations, to include whether 

adjudicators considered issues identified during an investigation to have 

been sufficiently resolved.68 According to ODNI officials, they began to 

 65See, for example, GAO/GGD-97-180, GAO-03-95, and GAO-05-70.

66GAO-14-704G. 

67GAO, 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).

68The QART may be used by agencies to document investigation completeness, but it 

also serves as a repository for agencies that use their own tool to assess quality under the 

standards. 
Page 28 GAO-18-29 Personnel Security Clearance Reform

implement the QART in October 2016, and full implementation is 

expected by the end of calendar year 2017.

ODNI officials stated that they are collecting sufficient data from the 

QART in order to develop measures for the quality of investigations. In 

ODNI’s review of a draft of this report, officials stated that it is premature 

to set a milestone for completing government-wide performance 

measures for the quality of investigations and that ODNI will set such a 

milestone when the QART data have been fully analyzed. Specific details 

on this topic were omitted because the information is sensitive. Figure 4 

provides an overview of the timeline for the executive branch’s three-step 

process to develop measures for the quality of investigations.

Figure 4: Milestones Related to the Development of Government-Wide Personnel Security Clearance Investigation Quality 

Standards, Tool, and Measures
Page 29 GAO-18-29 Personnel Security Clearance Reform

Although ODNI has developed the QART, and ODNI and OPM have 

issued the Quality Assessment Standards, there are still challenges to 

resolve as measures for the quality of investigations are established. For 

example, DOD officials stated that they do not intend for all of their 

adjudicators to use the QART, and that they have not developed an 

interface between their Rapid Assessment of Incomplete Security 

Evaluations system and the QART.69 DOD officials also stated that they 

will continue to use their tool until the QART is automated for use in a 

new Defense Information System for Security. If DOD investigations—

which represent the majority of the background investigations conducted 

by NBIB—are not captured by the QART, it is unclear how ODNI will have 

sufficient data to develop government-wide measures for the quality of

investigations. Further, NBIB officials noted that if their largest customer 

is not utilizing the QART, they are not positioned to receive 

comprehensive feedback.

In April 2015 we recommended, among other things, that the Director of 

National Intelligence, in his capacity as Security Executive Agent, 

develop, implement, and report to Congress on government-wide, resultsoriented performance measures for security clearance background 

investigation quality.70 ODNI did not state whether it concurred with that 

recommendation, and the recommendation has not been implemented. 

We continue to believe that measures for the quality of background 

investigations are needed to provide decision-makers, including OMB and 

Congress, with information on the quality of personnel security clearance 

background investigations, and to help ensure the quality of 

investigations. Without establishing a milestone for the completion of 

government-wide performance measures for the quality of investigations, 

their completion may be further delayed, and executive branch agencies 

will not have a schedule against which they can track progress or to 

which they are accountable.

 69The Rapid Assessment of Incomplete Security Evaluations is a quality tool used by the 

Department of Defense for assessing the completeness of background investigations. 

70GAO-15-179SU.
Page 30 GAO-18-29 Personnel Security Clearance Reform

Executive branch agencies have experienced challenges in meeting 

timeliness objectives for investigation and adjudication of initial personnel 

security clearances, and their reporting on timeliness has been limited. 

The number of executive branch agencies meeting established timeliness 

objectives for both initial secret and initial top secret clearances 

decreased from fiscal year 2012 through fiscal year 2016. While ODNI 

has taken steps to address timeliness challenges, it has not developed a 

government-wide approach to help agencies improve the timeliness of 

initial personnel security clearances. In addition, the executive branch’s 

reporting on timeliness has been limited, which inhibits both transparency 

and oversight of the personnel security clearance process.

Our analysis of timeliness data for specific executive branch agencies 

showed that the percent of agencies meeting established investigation 

and adjudication timeliness objectives for initial secret and top secret 

personnel security clearances decreased from fiscal year 2012 through 

2016. Specifically, in fiscal year 2012, 27 percent of the agencies for 

which we obtained data met investigation and adjudication objectives for 

at least three of four quarters for initial secret clearances, and 59 percent 

met those objectives for initial top secret clearances. By fiscal year 2016, 

that decreased to 2 percent and 10 percent, respectively. IRTPA 

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 by an authorized investigative agency—not 

longer than 40 days to complete the investigative phase, and 20 days to 

complete the adjudicative phase.71 In assessing timeliness under these 

objectives, executive branch agencies exclude the slowest 10 percent 

and report on the average of the remaining 90 percent (referred to as the 

fastest 90 percent). In 2012, ODNI, in coordination with interagency 

participation, modified the timeliness goals for certain background 

investigations and established new timeliness goals.

 71Specifically, IRTPA required the development of a plan to reduce the length of the 

personnel security clearance process that included, to the extent practical, the above 

timeframes. See Pub. L. No. 108-458, § 3001(g) (2004) (codified as amended at 50 

U.S.C. § 3341(g)).

Agencies Meeting 

Timeliness Objectives 

for Initial Clearances 

Decreased Since 

Fiscal Year 2012; a 

Government-wide 

Approach Has Not 

Been Developed to 

Improve Timeliness; 

and Reporting Has 

Been Limited

The Number of Executive 

Branch Agencies Meeting 

Established Timeliness 

Objectives for 

Investigations and 

Adjudications for Initial 

Secret and Top Secret 

Clearances Decreased 

from Fiscal Years 2012 

through 2016
Page 31 GAO-18-29 Personnel Security Clearance Reform

As part of the Insider Threat and Security Clearance Reform crossagency priority goal, from the second quarter of fiscal year 2014 until the 

fourth quarter of fiscal year 2016, the PAC reported quarterly on the 

average number of days to initiate, investigate, adjudicate, and complete 

the end-to-end process for initial secret and initial top secret cases for the 

executive branch as a whole. It reported this information as compared 

with the IRTPA-established timeliness objectives for initial secret 

clearances and ODNI’s revised timeliness objectives for initial top secret 

clearances. For fiscal year 2016, the PAC reported that the governmentwide average for executive branch agencies:

• Did not meet the 40-day investigation objective for the fastest 90 

percent of initial secret clearances for any quarter. The averages 

ranged from 92 days to 135 days.

• Did not meet ODNI’s revised investigation objective for the fastest 90 

percent of initial top secret clearances for any quarter. The averages 

ranged from 168 days to 208 days.

With regard to the timeliness of investigations, our analysis of timeliness 

data reported by specific executive branch agencies showed that the 

percent of agencies that met timeliness objectives decreased from fiscal 

year 2012 through 2016. Specifically, our analysis showed:

• While 27 percent of the agencies met the 40-day IRTPA-established 

investigation objective for at least three of four quarters for the fastest 

90 percent of initial secret cases in fiscal year 2012, only 2 percent 

met the objective for at least three of four quarters in fiscal year 

2016.72

• While 78 percent of the agencies met ODNI’s revised investigation 

objective for at least three of four quarters for the fastest 90 percent of 

initial top secret cases in fiscal year 2012, only 12 percent met the 

objective for at least three of four quarters in fiscal year 2016.

• Across the agencies we reviewed, the average number of days to 

complete the investigation phase of the fastest 90 percent of initial top 

secret cases for the fourth quarter of fiscal year 2016 ranged from 26 

days to 459 days.

 72Agencies 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, investigative phase timeliness data for 

agencies without delegated authority is generally a reflection of OPM’s timeliness.
Page 32 GAO-18-29 Personnel Security Clearance Reform

Furthermore, our analysis showed that, for the executive branch agencies 

included in our review, the time required to investigate initial personnel 

security clearances increased from fiscal year 2012 through fiscal year 

2016, often exceeding the investigation phase objective established by 

IRTPA.73 In addition, we found that both agencies with delegated 

authority to conduct their own investigations and those that used FIS 

(now NBIB) as their investigative service provider experienced challenges 

in meeting established investigation timeliness objectives. However, the 

only agencies that met investigation timeliness objectives for at least 

three of four quarters of fiscal year 2016—for the fastest 90 percent of 

initial secret and initial top secret clearances—have delegated authority to 

conduct their own investigations.74

The executive branch’s challenges in meeting investigation timeliness 

objectives for initial personnel security clearances have contributed to a 

significant backlog of background investigations at the primary entity 

responsible for background investigations, NBIB.75 NBIB documentation 

shows that its backlog of pending investigations increased from about 

190,000 in August 2014 to more than 709,000 investigations, as of 

September 2017. NBIB officials stated that more than 70 percent of the 

bureau’s pending background investigations had been pending for longer 

than the established timeliness objectives, as of June 2017. Additional 

details about NBIB’s investigation backlog and actions the bureau is 

taking to address it are discussed later in this report.

With regard to the timeliness of adjudications, our analysis showed:

• While 51 percent of the agencies met the 20-day adjudication 

objective for at least three of four quarters for the fastest 90 percent of 

 73We found that average security clearance processing times generally increased from 

2012 through 2016 for the fastest 90 percent of cases in the scope of our data request. 

Average times for initial secret and initial top secret investigations increased by statistically 

significant amounts (i.e., distinguishable from no change at the 0.01 level of significance). 

Due to the small sample size of reporting quarters and other factors, however, our 

analyses did not find statistically significant increases for average times for initial secret 

adjudications or initial top secret adjudications. 

74The data provided by ODNI identified the agencies with delegated authority to conduct 

their own investigations. 

75According to ODNI officials, NBIB is one of several investigative service providers 

government-wide.
Page 33 GAO-18-29 Personnel Security Clearance Reform

initial secret cases in fiscal year 2012, only 35 percent met the 

objective for at least three of four quarters in fiscal year 2016.

• While 65 percent of the agencies met the 20-day adjudication 

objective for at least three of four quarters for the fastest 90 percent of 

initial top secret cases in fiscal year 2012, only 43 percent met the 

objective for at least three of four quarters in fiscal year 2016.

• Across the executive branch agencies included in our review, the 

average number of days to adjudicate the fastest 90 percent of initial 

top secret cases for the fourth quarter of fiscal year 2016 ranged from 

3 days to 175 days.

Table 1 shows the percent of agencies meeting the investigation and 

adjudication objectives for the fastest 90 percent of initial secret and initial 

top secret cases for at least three of four quarters from fiscal years 2012 

through 2016.

Table 1: Percent of Executive Branch Agencies Meeting Timeliness Objectives for 

the Fastest 90 Percent of Initial Cases for at Least Three of Four Quarters from 

Fiscal Years 2012-2016

Fiscal year Initial secret 

investigations

Initial secret 

adjudications

Initial top secret 

investigations

Initial top 

secret 

adjudications

2012 27 51 78 65

2013 27 49 65 63

2014 20 45 55 57

2015 0 51 12 57

2016 2 35 12 43

Source: GAO analysis of ODNI timeliness information for specific executive branch agencies. I GAO-18-29

In November 2017, we reported that the percent of executive branch 

agencies meeting established timeliness goals for completing periodic 

reinvestigations also decreased from fiscal years 2012 through 2016.76

Appendix IV provides information on executive branch agency periodic 

reinvestigations from fiscal years 2012 through 2016.

 76GAO-18-117. 
Page 34 GAO-18-29 Personnel Security Clearance Reform

ODNI has taken steps to address challenges in meeting established 

timeliness objectives, such as revising the timeliness objective for top 

secret investigations in 2012; however, it has not developed a 

government-wide approach to help agencies improve the timeliness of 

initial personnel security clearances. ODNI officials stated that several 

significant events contributed to agency challenges in meeting timeliness 

objectives over the past 5 fiscal years, including a government shutdown, 

the 2015 OPM data breach, a loss of OPM contractor support, and OPM’s 

review of the security of its IT systems, which resulted in the temporary 

suspension of the web-based platform used to complete and submit 

background investigation forms. In addition, executive branch agencies 

noted the increased investigative requirements stemming from the 2012 

Federal Investigative Standards as a further challenge to meeting 

established timeliness objectives in the future.

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.77 In addition, 

the standards state that management should use quality information to 

achieve the entity’s objectives, including relevant data from internal and 

external sources.

As previously discussed, ODNI, in coordination with interagency 

participation, modified the timeliness goals for certain background 

investigations and established new timeliness goals. Since then, meeting 

timeliness objectives has become even more challenging due, for 

example, to updated investigation standards.

However, since 2012, ODNI has not revisited the investigation or 

adjudication timeliness objectives for secret and top secret clearances. 

Specifically, ODNI has not conducted an evidence-based review, using 

relevant data, to ensure that these objectives are appropriate, given 

changes to the investigative requirements and other stated challenges. In 

addition, while ODNI and interagency partners modified certain timeliness 

goals in 2012, the number of executive branch agencies able to 

consistently meet the revised objectives also decreased over the past 5 

fiscal years. Without conducting an evidence-based review of the 

investigation and adjudication timeliness objectives for both secret and 

top secret clearances to ensure that they are appropriate, agencies may 

 77GAO-14-704G. 

ODNI Has Taken Steps to 

Address Timeliness 

Challenges but Has Not

Developed a Governmentwide Approach to Help 

Improve Timeliness
Page 35 GAO-18-29 Personnel Security Clearance Reform

experience further timeliness challenges and delays in determining 

eligibility.

According to ODNI officials, they are aware of each agency that does not 

meet timeliness objectives and, in the capacity as Security Executive 

Agent, the Director of National Intelligence has taken steps to help these 

agencies improve their timeliness. Specifically, ODNI officials stated that 

the Director of National Intelligence issues annual agency performance 

letters to heads of agencies when security clearance timeliness objectives 

are not met. In the letters, the Director of National Intelligence requests 

that the agency submit an action plan, within 60 days of the date of the 

letter, identifying the factors that prevented the agency from meeting 

established timeliness objectives and the actions the agency will take to 

remedy those impediments. Officials stated that since the letter comes 

directly from the Director, this helps to attract the maximum amount of 

attention possible.

In addition to establishing the current timeliness objectives for initial 

security clearances, IRTPA also established a 5-year timeframe and an 

interim milestone for the executive branch to implement those objectives. 

Specifically, the act required the development of a plan to reduce the 

length of the personnel security clearance process, including the IRTPAestablished timeliness objectives described above. The plan was to be 

developed in consultation with appropriate committees of Congress and 

each authorized adjudicative agency, and to take effect 5 years after the 

date of enactment.78 Beginning no later than 2 years after the enactment 

of IRTPA and ending on the date the plan took effect, authorized 

adjudicative agencies were to make a determination on at least 80 

percent of all applications within an average of 120 days after receipt by 

an authorized investigative agency—not longer than 90 days to 

investigate and 30 days to adjudicate.79 In November 2005, the executive 

branch submitted a plan to improve the timeliness of personnel security 

 78Pub. L. No. 108-458, § 3001(g)(1), (2), (3)(A) (2004) (codified at 50 U.S.C. § 3341(g)). 

IRTPA required the President to select a single entity to be responsible for specified 

matters related to security clearances within 90 days of enactment, and required that 

entity to develop the plan within 90 days of selection. § 3001(b), (g)(1). 

79See § 3001(g)(3)(B) (codified at 50 U.S.C. § 3341(g)(3)(B)).
Page 36 GAO-18-29 Personnel Security Clearance Reform

clearance processes government-wide.80 The Joint Reform Team 

submitted its first reform plan to the President on April 30, 2008, which 

proposed a new process for determining clearance eligibility.

Standards for Internal Control in the Federal Government establishes that 

management should define objectives clearly to enable the identification 

of risks and define risk tolerances.81 In our prior work on interagency 

collaboration, we found that overarching plans can help agencies 

overcome differences in missions, cultures, and ways of doing business, 

and help agencies better align their activities, processes, and resources 

to collaborate effectively to accomplish a commonly defined outcome.82

Additionally, to help sustain and enhance collaboration among federal 

agencies, we found that agencies that create a means to monitor, 

evaluate, and report the results of collaborative efforts can better identify 

areas for improvement.83 Further, we have found in previous work, 

including our prior work on personnel security clearances, that interim 

milestones can be used to show progress toward implementing efforts or 

to make adjustments when necessary.84 Developing and using specific 

milestones to guide and gauge progress toward achieving an agency’s 

desired results informs management of the rate of progress toward 

achieving goals, and whether adjustments need to be made in order to 

maintain progress within given time frames.85

While ODNI requests individual corrective action plans from agencies not 

meeting security clearance timeliness objectives, the executive branch 

has not developed a government-wide plan, with goals and interim 

milestones, to meet established timeliness objectives for initial security 

 80The November 2005 plan included quarterly timeliness goals for initial investigations of 

clearances from November 2005 through December 2006 and an action plan for 

improving the security clearance process to meet the requirements of IRTPA, such as 

timeliness, reciprocity, and the establishment of an integrated database to track 

investigative and adjudicative information. 

81GAO-14-704G.

82GAO, Interagency Collaboration: Key Issues for Congressional Oversight of National 

Security Strategies, Organizations, Workforce, and Information Sharing, GAO-09-904SP 

(Washington, D.C.: Sept. 25, 2009).

83GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

84GAO/GGD/AIMD-99-69, GAO/GGD-96-118, and GAO-09-400.

85GAO-14-49.
Page 37 GAO-18-29 Personnel Security Clearance Reform

clearances that takes into consideration increased investigative 

requirements and other stated challenges. A coordinated approach, in 

addition to the ODNI-requested agency-specific plans, could help to 

improve timeliness, given that: (1) both agencies that use NBIB as their 

investigative service provider and those that have delegated authority to 

conduct their own investigations have experienced challenges in meeting 

established investigation and adjudication timeliness objectives over the 

past 5 fiscal years; and (2) timeliness challenges include governmentwide challenges, such as the increased requirements stemming from the 

2012 Federal Investigative Standards and past challenges in relation to 

OPM contractor support, as discussed above, and not just agencyspecific challenges, such as staffing shortfalls. While the individual 

agency action plans represent a positive step toward helping to improve 

timeliness, agencies across the executive branch continue to experience 

timeliness challenges. A government-wide plan would better position 

ODNI to identify and address any systemic issues. Without a governmentwide plan, including goals and interim milestones, for achieving timeliness 

objectives for initial secret and top secret investigations and 

adjudications—similar to the plan previously required by IRTPA—there 

could be continued delays in determining individuals’ eligibility for access 

to classified information. Ultimately, such delays may leave agencies 

unable to fill critical positions that require a security clearance.

Since 2011, the executive branch’s reporting on the timeliness of 

personnel security clearances has provided limited transparency and 

oversight of the overall reform effort. Specifically, IRTPA required the 

executive branch to submit an annual report, through 2011, to the 

appropriate congressional committees on the progress made toward 

meeting the act’s requirements, including timeliness data and a 

discussion of any impediments to the smooth and timely functioning of its 

requirements. With respect to timeliness data, the act required that those 

reports include the periods of time required by the authorized 

investigative agencies and authorized adjudicative agencies for 

conducting investigations, adjudicating cases, and granting clearances, 

from date of submission to ultimate disposition and notification to the 

subject and the subject’s employer.86

 86Pub. L. No. 108-458, § 3001(h) (2004) (presently codified at 50 U.S.C. § 3341(h)). 

Current Timeliness 

Reporting Provides 

Limited Transparency and 

Oversight of the Reform 

Effort
Page 38 GAO-18-29 Personnel Security Clearance Reform

In response to this requirement, the executive branch provided a series of 

reports from 2006 through 2011 on the timeliness of executive branch 

agencies’ initial investigations and periodic reinvestigations. For example, 

ODNI’s IRTPA Title III Annual Report for 2010 specified the average 

number of days by quarter it took for selected individual agencies to 

initiate, investigate, adjudicate, and complete the end-to-end process for 

the fastest 90 percent of security clearances.87 The report also included 

average timeliness data for the executive branch as a whole.

However, since the IRTPA requirement ended in 2011, executive branch 

reporting has been limited. For example, as previously discussed, the 

PAC did not begin its quarterly reporting on the timeliness of executive 

branch agencies’ personnel security clearances until the second quarter 

of fiscal year 2014 through the Insider Threat and Security Clearance 

Reform cross-agency priority goal. In addition, while these reports include 

the timeliness of both initial investigations and periodic reinvestigations, 

they provide the average timeliness of the executive branch as a whole 

and not the timeliness of individual executive branch agencies—as was 

provided under the prior IRTPA reporting—which makes it difficult to 

identify specific agencies that may be experiencing challenges.

Additionally, the Intelligence Authorization Act for Fiscal Year 2010 

requires the President to submit an annual report on security clearance 

determinations to Congress. Among other things, the report is to include, 

for the preceding fiscal year, the number of federal and contractor 

employees who held a security clearance at each level and the number of 

employees who were approved for a security clearance at each level, as 

well as in-depth security clearance determination timeliness information 

for each element of the intelligence community.88 However, the annual 

reports that ODNI provides to the congressional intelligence committees 

in response to this requirement include only limited data as compared 

with reports that were completed in response to IRTPA. Specifically, the 

Intelligence Authorization Act for Fiscal Year 2010 requires information on 

the total amount of time for the longest and shortest determinations, and 

the age of pending investigations, not average timeliness. The reports are 

also limited in that they capture data for only a portion of the intelligence 

 87ODNI, IRTPA Title III Annual Report for 2010, Feb. 15, 2011.

88Pub. L. No. 111-259, § 367 (2010) (presently codified at 50 U.S.C. § 3104). The 

provision permits the use of two security clearance levels for reporting purposes: one 

consisting of confidential and secret, and one consisting of top secret or higher. § 

3104(a)(2).
Page 39 GAO-18-29 Personnel Security Clearance Reform

community.89 Specifically, ODNI’s 2015 Annual Report on Security 

Clearance Determinations states that the report includes information for 7 

of 15 elements of the intelligence community and that the other 8 

elements reported that collecting the information would be a manual, 

resource-intensive process that was not viable due primarily to 

technology restrictions.90

Standards for Internal Control in the Federal Government states that 

management should externally communicate the necessary quality 

information to achieve the entity’s objectives through reporting lines so 

that external parties can help the entity achieve its objectives and address 

related risks.91 In addition, our high-risk criteria for monitoring and 

demonstrated progress call for agencies to report on program progress 

and related risks as well as show that issues are being effectively 

managed.92

However, since the IRTPA annual reporting requirement ended in 2011, 

the executive branch has provided limited reporting on the timeliness of 

individual agencies’ initial investigations or periodic reinvestigations for 

personnel security clearances. In addition, while the PAC had regularly 

reported publicly on timeliness for the executive branch as a whole on a 

quarterly basis, it has not provided a public quarterly status update since 

the fourth quarter of fiscal year 2016. According to performance.gov, the 

 89The House bill for the Intelligence Authorization Act for Fiscal Year 2018 includes a 

proposed provision related to intelligence community reports on security clearances, 

which would amend the reporting requirement. Specifically, it would require the Director of 

National Intelligence to submit an annual report to the congressional intelligence 

committees on matters related to the security clearances processed by each element of 

the intelligence community, such as the number of background investigations that 

remained pending for specified periods of time, as well as the causes of delays for 

determinations that have taken longer than 1 year to complete. H.R. 3180, 115th Cong. § 

603(3) (as passed by House, July 28, 2017). In addition to the proposed amendment, the 

House Permanent Select Committee on Intelligence directed ODNI, within 90 days of the 

enactment of the act, to brief the congressional intelligence and defense committees on 

the amount of time required for processing initial security clearances, periodic 

reinvestigations, and reciprocal actions for intelligence community agencies started during 

fiscal years 2016 and 2017. The briefing is to include the average time required for certain 

steps in the process, including investigation and adjudication. H.R. Rep. No. 115-251, at 

19-20 (2017). 

90Office of the Director of National Intelligence, 2015 Annual Report on Security Clearance 

Determinations.

91GAO-14-704G. 

92GAO-17-317. 
Page 40 GAO-18-29 Personnel Security Clearance Reform

website through which the PAC distributes its quarterly updates, the 

content—including the PAC’s quarterly updates—is undergoing an 

overhaul as agencies develop updated goals and objectives for release in 

February 2018 with the President’s next budget submission to 

Congress.93 It is unclear whether the new administration will continue to 

designate personnel security clearance reform as a cross-agency priority 

goal. PAC Program Management Office officials stated that they continue 

to track and report this information internally within the executive branch. 

These officials stated that they were uncertain as to whether 

performance.gov would remain a vehicle by which they would report on 

the status of the reform effort, including executive branch-wide timeliness. 

However, the officials also stated that it is important for the information to 

be reported in order to maintain transparency and the momentum of the 

reform effort.

Without transparent reporting by the executive branch on investigation 

and adjudication timeliness for both initial investigations and periodic 

reinvestigations, Congress will not be able to effectively execute its 

oversight role and monitor individual executive branch agency progress in 

meeting timeliness objectives. In addition, the absence of comprehensive 

reporting on personnel security clearance timeliness limits the ability of 

congressional decision makers to thoroughly evaluate and precisely 

identify where and why delays exist within the process, as well as to 

identify corrections as necessary. In addition, should the PAC’s quarterly 

progress updates be suspended indefinitely, Congress and the public will 

have limited transparency into the status of key reform effort initiatives, 

which may delay the timely identification of problems, and ultimately 

disrupt the momentum of the reform effort as a whole.94

 93We last verified the status of performance.gov on August 11, 2017.

94As this report was in its final stages of issuance, the House of Representatives and 

Senate passed a bill for the National Defense Authorization Act for Fiscal Year 2018 that 

included matters related to the security clearance process. Section 925(k) of the bill would 

require an annual report to the appropriate congressional committees on the timeliness of 

personnel security clearance initiations, investigations, and adjudications, by clearance 

level, for both initial investigations and periodic reinvestigations, including the average 

periods of time taken by each authorized investigative agency and authorized adjudicative 

agency to initiate cases, conduct investigations, and adjudicate cases as compared with 

established timeliness objectives. See H.R. Rep. No. 115-404, at 249-50 (2017) (Conf. 

Rep., relaying section 925(k) of the bill, as passed by the Senate on November 16 and the 

House of Representatives on November 14).
Page 41 GAO-18-29 Personnel Security Clearance Reform

The transition from FIS to NBIB has involved organizational changes 

intended to improve the background investigation process, but the bureau 

faces operational challenges in addressing the investigation backlog and 

associated workforce planning. NBIB’s organizational changes include 

the creation of some new departments, and DOD is now responsible for 

designing, developing, and maintaining a new IT system for the bureau, 

but must contend with risks posed by vulnerabilities in OPM’s legacy IT 

systems, which NBIB still utilizes. As NBIB transitions, it has taken steps 

to improve its oversight of background investigations contracts and 

measure the completeness of background investigations; however, it 

faces operational challenges in developing a plan to reduce the size of 

the investigation backlog to a manageable level and in ensuring that its 

overall workforce is sized and structured to meet its mission.

The transition from FIS to NBIB involved some organizational changes, 

such as the creation of new departments designed to enhance 

information sharing and contract oversight, among other things. NBIB 

also made changes to existing departments, such as enhancing its 

counterintelligence division to foster greater collaboration with the 

intelligence community. In addition, NBIB is subject to oversight from 

multiple entities, such as OPM, ODNI, and the PAC. Further, DOD is now 

responsible for designing, developing, and maintaining a new IT system 

for NBIB that can provide increased security. However, vulnerabilities in 

OPM’s legacy systems pose risks to the security of the new system and 

could delay its implementation.

NBIB was established to replace FIS, and the transition has involved 

changes to the organizational structure. In response to the results of 90-

day review that were announced in January 2016, in September 2016, 

Executive Order 13741 amended Executive Order 13467 to establish the 

roles and responsibilities of NBIB within OPM and made the Director of 

NBIB a member of the PAC.95 According to Executive Order 13467, as 

amended, NBIB is to serve as the primary executive branch service 

 95Exec. Order No. 13,741, 81 Fed. Reg. 68,289 (Sept. 29, 2016). The Executive Order 

designated the Director of NBIB as a member of the PAC, but not one of the four PAC 

principals.

NBIB Has Taken 

Steps to Improve the 

Background 

Investigation Process 

but Faces 

Operational 

Challenges in 

Addressing the 

Investigation Backlog 

and Workforce 

Planning

Establishment of NBIB 

Involved Organizational 

Changes, the Designation 

of Oversight Roles, and 

Transfer of IT 

Responsibilities to DOD

Transition from FIS to NBIB 

Involved Changes to 

Organizational Structure
Page 42 GAO-18-29 Personnel Security Clearance Reform

provider for background investigations for, among other things, eligibility 

for access to classified information; eligibility to hold a sensitive position; 

suitability or fitness for government employment; and authorization to be 

issued a federal credential for logical and physical access to federally 

controlled facilities or information systems.96 Among other things, the 

bureau is to also provide effective, efficient, and secure personnel 

background investigations for the federal government.97

When announcing the establishment of NBIB, in January 2016, the 

administration reported the intention to create a dedicated transition team 

headquartered in Washington, D.C., to develop and implement a 

transition plan to: (1) stand up the bureau; (2) ensure that the transition 

timeline fully aligns with business needs; (3) transition the management of 

FIS IT systems to DOD; (4) migrate the existing mission, functions, 

personnel, and support structure of FIS to NBIB; and (5) provide 

continuity of service to customer agencies during the transition. According 

to its charter, the transition team was composed of current OPM 

employees, and federal employees detailed or assigned to OPM or DOD 

from other executive branch agencies and departments. NBIB officials 

noted that employees from across the executive branch with relevant 

experience and qualifications were recruited to ensure that stakeholder 

agencies’ equities were represented, and that the transition team leader 

was recruited from outside of OPM and reported directly to the OPM 

Director throughout the transition process.

OPM reported that NBIB became operational on October 1, 2016, but that 

the complete transition will take some time.98 For example, the transition 

plan specifies activities throughout fiscal year 2017 and into fiscal year 

2018 to implement the transition from FIS to NBIB. NBIB officials said 

they expect that the bureau will have migrated to the new organizational 

structure substantially by mid-2018. The transition also involved some 

organizational changes intended to streamline certain business 

processes or more effectively manage background investigations as the 

organization has continued to evolve. NBIB officials stated that the 

transition team established the organizational structure by assessing 

 96Executive Order 13467 defines logical and physical access as access other than 

occasional or intermittent access to federally controlled facilities or information systems. 

Exec. Order No. 13,467, § 1.3(m) (as amended).

97Exec. Order No. 13,467, § 2.6(a), as amended through Exec. Order No. 13,764. 

98OPM, Agency Financial Report Fiscal Year 2016 (November 2016).
Page 43 GAO-18-29 Personnel Security Clearance Reform

essential FIS functions in coordination with key community 

stakeholders—including new and external customers—through the PAC 

as well as FIS personnel. The officials said that the transition team then 

linked similar functions and interdependencies to establish each of the 

offices. Additionally, NBIB officials stated that the 2015 90-day review 

helped to determine the organizational structure because it identified a 

need for a business process reengineering analysis.

Through its establishment, NBIB absorbed FIS and assumed its mission. 

NBIB’s organizational structure has several changes from the structure of 

FIS, to include the establishment of the following four new departments:

1. Federal Investigative Records Enterprise. The functions of this 

department include a new law enforcement and records outreach 

group to improve outreach and more effectively collect information 

with state and local law enforcement offices.

2. Policy, Strategy and Business Transformation. The functions of 

this department include expanding existing performance reporting to 

incorporate metrics regarding effectiveness; and researching and 

identifying systemic issues in workload, processes, and products to 

determine where process improvement could be achieved.

3. Contracting and Business Solutions. The functions of this 

department include enhancing and consolidating administration of 

NBIB contracts to provide consistent oversight.

4. Information Technology Management Office. The functions of this 

department include supporting the delivery and enhancement of 

quality IT systems to NBIB in a timely and effective manner, gathering 

and communicating needs and requirements for new applications, and 

coordinating implementation of changes to current systems.

In addition to the creation of these new departments, NBIB also made 

changes to several other departments from FIS. For example, according 

to NBIB documents, the Field Operations department added a “Field 

Contracts” division that is designed to oversee and monitor the contractor 

workforce performing background investigations, to ensure quality and 

timely products. This department also enhanced its counterintelligence 

division to focus on counterintelligence and insider threat support and to 

foster greater collaboration with the intelligence community. Further, NBIB 

created a new financial office to oversee budgeting, pricing and funding 

models, financial reporting, data accuracy, and internal controls 
Page 44 GAO-18-29 Personnel Security Clearance Reform

monitoring. Moreover, NBIB created a new Integrity Assurance, 

Compliance, and Inspection division by merging the FIS Integrity 

Assurance and Inspection divisions to streamline similar functions and 

improve processes and efficiencies.

Executive Order 13741 provided some guidelines governing the structure 

and location of NBIB. Specifically, it required that NBIB be headquartered 

in or near Washington, D.C., and that NBIB have dedicated resources, 

including but not limited to a senior privacy official.99 NBIB’s headquarters 

is located in Washington, D.C., but according to NBIB officials, as of July 

2017, only 48—including both occupied and vacant positions—of NBIB’s 

3,260 positions, or about 1.5 percent, were located in Washington, D.C. 

In addition, although the position of the senior privacy official has been 

established in the NBIB organization chart, according to NBIB officials, 

this position had not been filled as of July 2017. NBIB officials explained 

that they work closely with OPM’s senior privacy officer, and so they 

decided to prioritize filling other leadership positions within NBIB.

NBIB is subject to oversight from multiple entities, such as OPM, ODNI, 

and the PAC. Executive Order 13741 provided that the bureau would be 

established within OPM.100 NBIB officials stated that the bureau is part of 

OPM and is governed in a manner consistent with its other operational 

components. They also said that although the structure of NBIB is 

different from that of FIS, its general relationship with OPM and its 

leadership reporting chain are similar. Specifically, comparing the 

organizational charts of FIS and NBIB, FIS was led by an Associate 

Director who reported to the Director of OPM, while NBIB is led by a 

Director who reports to the Director of OPM.

According to NBIB, the OPM Director has delegated certain authorities to 

NBIB; additionally, the OPM Senior Procurement Executive delegated to 

NBIB certain administrative and acquisition authorities. NBIB officials said 

 99Exec. Order No. 13,741, § 1(f), 81 Fed. Reg. at 68,290 (amending Exec. Order No. 

13,467). Executive Order 13764 subsequently amended the relevant provision to require a 

senior privacy and civil liberties official. 82 Fed. Reg. 8115, 8126 (Jan. 17, 2017).

100See Exec. Order No. 13,741, § 1(d), 81 Fed. Reg. at 68,289 (adding section 1.3(k) to 

Exec. Order No. 13,467). Executive Order 13764 subsequently amended the description 

of NBIB, providing that the bureau was established within OPM under section 1103(a)(3) 

of Title 5, U.S. Code. Exec. Order No. 13,764, § 3(k), 82 Fed. Reg. at 8120. Section 

1103(a)(3) vests in the Director of OPM, or designated employees, the functions of 

directing and supervising OPM employees, distributing business among employees and 

organizational units, and directing the internal management of OPM.

NBIB Subject to Oversight from 

OPM, ODNI, and the PAC
Page 45 GAO-18-29 Personnel Security Clearance Reform

that this makes its structure more flexible. NBIB officials said that where 

support is provided from other OPM offices—such as communications, 

legislative affairs, legal, procurement, security, facilities, and the office of 

the Chief Information Officer—there is continual dialogue between that 

office’s leadership and the staff directly supporting the bureau. The 

officials also noted a variety of regular meetings, such as a weekly 

meeting between the Acting Director of OPM and the NBIB Director and 

Chief of Staff, attendance at daily OPM senior staff meetings, and 

briefings every other month with the OPM Inspector General, among 

others.

In addition, as previously discussed, as the Security Executive Agent, the 

Director of National Intelligence is responsible for various matters related

to security clearance investigation oversight, programs, policies, and 

processes.101 Executive Order 13467, as amended by Executive Orders 

13741 and 13764, provides that NBIB, through the Director of OPM, is 

subject to the oversight of the Security Executive Agent with respect to 

the conduct of investigations for eligibility for access to classified 

information or to hold a sensitive position.102 Similarly, Executive Order 

13467, as amended, provides that NBIB is responsible for conducting 

background investigations in accordance with policies, procedures, 

standards, and requirements established by the Security Executive Agent 

and Suitability Executive Agent.103 In February 2017, the Acting Director 

of OPM testified that the bureau has been working closely with ODNI to 

identify policy and process changes to address the investigation 

backlog.104 NBIB officials stated that the bureau and ODNI are active 

partners, and that the bureau participates in many of ODNI’s working 

groups in the development of policies or processes related to personnel 

security clearances. In addition, the officials said that the bureau reports 

timeliness, quality, and performance metrics to ODNI on no less than a 

 101See Exec. Order No. 13,467, § 2.5(e), as amended through Exec. Order No. 13,764, 

82 Fed. Reg. at 8125.

102Exec. Order No. 13,467, § 2.6(c), as amended through Exec. Order No. 13,764, 82 

Fed. Reg. at 8126. Executive Order 13467 similarly subjects NBIB, through the Director of 

OPM, to the oversight of the Suitability and Credentialing Executive Agent in the conduct 

of investigations of suitability or fitness and logical and physical access. Id.

103Exec. Order No. 13,467, § 2.6(a)(8), as amended.

104Kathleen McGettigan, Acting Director, U.S. Office of Personnel Management, 

Improving Security and Efficiency at OPM and the National Background Investigations 

Bureau, testimony before the House Committee on Oversight and Government Reform, 

115th Cong., 1st sess. (Feb. 2, 2017).
Page 46 GAO-18-29 Personnel Security Clearance Reform

quarterly basis, and that its personnel collaborate with ODNI on reviews 

of processes, such as those related to social media, continuous 

evaluation, insider threat, and counterintelligence. ODNI officials told us 

that in its oversight role of NBIB, ODNI collects quarterly timeliness data 

and requests that agencies using NBIB as their investigative service 

provider enter the investigations into the QART to assess the quality of 

the investigations.

Further, Executive Order 13467, as amended by Executive Order 13741, 

describes an oversight relationship between the PAC and NBIB. It 

requires the PAC to hold NBIB accountable for the fulfillment of the 

bureau’s responsibilities set out in the Executive Order. It further provides 

that NBIB is to provide the PAC with information, to the extent permitted 

by law, on matters of performance, timeliness, capacity, IT modernization, 

continuous performance improvement, and other relevant aspects of 

NBIB operations.105 PAC Program Management Office officials told us 

that they worked with NBIB during the transition from FIS and answered a 

lot of questions, and have helped to fill in staffing and organization holes 

that were identified by the transition team.

Executive Order 13467, as amended, assigns the Secretary of Defense 

the role of developing and securely operating IT systems that support all 

background investigation processes conducted by NBIB.106 According to 

officials from the Office of the DOD Chief Information Officer (CIO), NBIS 

will be built to NBIB specifications, and OPM will remain the owner of the 

data and processes. In testimony before the House Oversight and 

Government Reform Committee in February 2017, the DOD CIO 

estimated that NBIS would have several “prototype” capabilities by the 

end of fiscal year 2017, and an initial capability covering the full 

investigative process sometime in the fourth quarter of 2018.107 According 

to DOD officials, full capability for NBIS is scheduled for some time in 

2019. However, a NBIB official noted the existence of challenges 

 105Exec. Order No. 13,467, § 2.6(c), (a)(3), as amended through Exec. Order No. 13,764, 

82 Fed. Reg. at 8126-27.

106See Exec. Order No. 13,467, § 2.6(b), as amended through Exec. Order No. 13,764, 

82 Fed. Reg. at 8126. Executive Order 13741 added this responsibility in September 

2016; it was subsequently amended by Executive Order 13764.

107Terry Halvorsen, Department of Defense Chief Information Officer, The National 

Background Investigations Bureau Transition, Related Information Technology Security, 

and the Security Clearance Investigation Process, testimony before the House Oversight 

and Government Reform Committee, 115th Cong., 1st sess. (Feb. 2, 2017). 

DOD Is Building and Managing 

a New Security Clearance IT 

System for NBIB, but Security 

Concerns May Delay Planned 

Milestones for the New System
Page 47 GAO-18-29 Personnel Security Clearance Reform

regarding the IT infrastructure and stated that it is more realistic for NBIS 

to be fully operational in 2020.

According to DOD CIO officials, unexpected complications have arisen 

since beginning development of NBIS. Specifically, these officials stated 

that they have discovered that NBIS may require many more interconnections to OPM legacy systems than originally planned. According to 

these officials, NBIB will continue to rely on OPM legacy systems for

investigations of any complexity until NBIS becomes fully operational.

Further, according to DOD CIO officials, when the executive branch 

begins to use NBIS, complex background investigations would begin in 

NBIS’s electronic application, but would then need to pass through or 

draw data from multiple OPM legacy systems before returning to NBIS for 

adjudication. According to DOD CIO officials, since OPM has 43 backoffice functions fed by various systems that are often inter-related, a 

simple one-to-one system swap of NBIS for an OPM legacy system is not 

feasible. DOD CIO officials stated that the project management team 

building NBIS is currently working to fully understand how OPM’s various 

back-office functions are tied together, and also evaluating the cybersecurity risks inherent in connecting to OPM’s legacy systems. DOD CIO 

officials explained that this connection, as well as logistical challenges 

associated with data migration from the legacy systems to NBIS, raises 

concerns about risks to NBIS. Until these risks are properly evaluated, 

any connection to the legacy systems could present vulnerabilities, 

according to DOD CIO officials. OPM officials disagreed, stating that 

OPM and DOD already have IT connection points with the OPM legacy 

systems, and that the security of OPM’s systems and data continues to 

be an OPM priority.

Securing the legacy systems will be a joint effort by DOD and OPM, 

according to an October 2016 Memorandum of Agreement between the 

two agencies regarding the roles, responsibilities, and expectations of 

each party throughout the entire lifecycle of OPM’s use of DOD’s IT 

systems in support of the background investigation process. Under the 

agreement, OPM will retain ownership and responsibility for the operation 

and performance of all system authorization activities for OPM legacy 

systems throughout their lifecycle. The agreement provides that OPM will 

maintain security documentation and information and interconnection 

exchange agreements, own control selection and security role 

assignment processes, and perform risk executive functions. The 

memorandum further states that the security of the legacy OPM IT 

environment will be a joint effort between OPM and DOD, with DOD 
Page 48 GAO-18-29 Personnel Security Clearance Reform

assisting in a comprehensive security assessment of all OPM legacy IT 

systems and related infrastructure on a reimbursable basis. According to 

DOD CIO and NBIB officials, there is close coordination on a technical 

level between the two agencies on securing the OPM legacy systems 

used by NBIB. The officials said that weekly coordination meetings are 

held between the two agencies, and that DOD has embedded staff at 

OPM who are under the direct supervision of the OPM CIO.

Both GAO and the OPM Inspector General have raised concerns on 

multiple occasions about various aspects of IT security at OPM, including 

OPM legacy systems used by NBIB.108 For example, in August 2017, we 

reported on OPM’s progress in implementing 19 recommendations made 

by the United States Computer Emergency Readiness Team to bolster its 

information security practices and controls in the wake of the 2015 

breaches.109 We found that, as of May 2017, OPM had fully implemented 

11 of the recommendations. For the remaining 8 recommendations, 

actions for 4 were still in progress, and for the other 4, OPM indicated it 

had completed actions to address them, but we noted further 

improvements were needed.

We further reported that since the 2015 data breaches, which included a 

compromise of OPM’s systems and files related to background 

investigations for 21.5 million individuals, OPM has made progress in 

improving its security to prevent, mitigate, and respond to data breaches 

involving sensitive personal records and background investigations 

information.110 However, we also found that OPM did not effectively 

monitor actions taken to remediate identified weaknesses. OMB requires 

 108Additionally, a provision in the Consolidated Appropriations Act, 2017 limited the 

obligation of certain amounts available to OPM for IT systems until the Director submits to 

congressional committees a plan for expenditure, prepared in consultation with the 

Director of OMB, the Administrator of the United States Digital Service, and the Secretary 

of Homeland Security that, among other things, complies with OMB, Department of 

Homeland Security, and National Institute of Standards and Technology requirements 

related to securing the agency’s information system. See Pub. L. No. 115-31, div. E, tit. V 

(2017).

109GAO, Information Security: OPM Has Improved Controls, but Further Efforts Are 

Needed, GAO-17-614 (Washington, D.C.: Aug. 3, 2017). Due to the sensitive nature of the 

United States Computer Emergency Readiness Team recommendations, we are not 

providing the specific recommendations or specific examples associated with them. 

Generally, the recommendations pertained to strengthening activities and controls related 

to passwords, access permissions, patches, audit, and monitoring, among other things. 

110GAO-17-614.
Page 49 GAO-18-29 Personnel Security Clearance Reform

agencies to create a Plan of Action and Milestones to track efforts to 

remediate identified weaknesses, such as those leading to the 19 

recommendations made by the United States Computer Emergency 

Readiness Team.111 In addition, OPM’s policy requires that scheduled 

completion dates be included in the plan. The policy also requires a 

system’s Information System Security Officer to develop a weakness 

closure package containing evidence of how an open Plan of Action and 

Milestones has been remediated before the issue, or recommendation in 

this case, can be closed. Although OPM has a Plan of Action and 

Milestones to address the 19 recommendations, we found that it had not 

validated actions taken in a timely manner or updated completion dates in 

the plan. Because the United States Computer Emergency Readiness 

Team recommendations are intended to improve the agency’s security 

posture, we recommended that more timely validation of the effectiveness 

of the actions taken is warranted. Until closure packages are created and 

the evidence of such actions is validated, OPM has limited assurance that 

the actions taken have effectively mitigated vulnerabilities that can 

expose its systems to cybersecurity incidents.

Additionally, in May 2016 we reported on the implementation of OPM’s 

information security program and the security of selected high-impact 

systems.112 We found that OPM, one of four agencies reviewed, had 

implemented numerous controls to protect selected systems, but that 

access controls had not always been implemented effectively. We 

reported that weaknesses also existed in patching known software 

vulnerabilities and planning for contingencies, and that an underlying 

reason for these weaknesses was that OPM had not fully implemented 

key elements of its information security program. We recommended that 

OPM fully implement key elements of its program, including addressing 

shortcomings related to its security plans, training, and system testing. 

According to OPM officials, the agency is taking actions to address these 

recommendations. In August 2016, we issued a restricted version of our 

May 2016 report that identified vulnerabilities specific to each of the two 

systems we reviewed and made recommendations to resolve access 

control weaknesses in those systems.113 In December 2016, OPM 

 111OMB, FY 2004 Reporting Instructions for the Federal Information Security Management 

Act, M-04-25 (August 23, 2004). 

112GAO, Information Security: Agencies Need to Improve Controls over Selected HighImpact Systems, GAO-16-501 (Washington, D.C.: May 18, 2016).

113GAO, Information Security: OPM Needs to Improve Controls over Selected HighImpact Systems, GAO-16-687SU (Washington, D.C.: Aug. 15, 2016).
Page 50 GAO-18-29 Personnel Security Clearance Reform

indicated its concurrence with the recommendations and provided 

timeframes for implementing them. OPM officials expressed concern that 

the information from our 2016 reports was now dated, stating that it no 

longer reflects the current security posture at OPM, and said that they 

had taken actions to address these recommendations. However, all of the 

recommendations directed to OPM from the two reports remained open 

as of November 2017. We had not received any documentation regarding 

these actions as of November 2017 and thus could not validate the extent 

that any of these recommendations have been addressed.

OPM’s Office of the Inspector General has also raised related concerns, 

most recently in its October 2017 report on OPM’s security program and 

practices.114 Overall, the OPM Inspector General found that OPM’s 

cybersecurity maturity level was measured at a level 2, “Defined”, 

meaning that its policies, procedures and strategy were formalized and 

documented but were not consistently implemented.115 According to the 

report, OPM has made improvements in its security assessment and 

authorization program, and its previous material weakness related to 

authorizations is now considered a significant deficiency for fiscal year 

2017.116 The report noted that there are still widespread issues related to 

system authorizations, primarily related to documentation inconsistencies 

and incomplete or inadequate testing of the systems’ security controls. In 

addition, the report identified a significant deficiency in OPM’s information 

security management structure, and found that OPM was not making 

 114OPM, Office of the Inspector General, Federal Information Security Modernization Act 

Audit Fiscal Year 2017, 4A-CI-00-17-020 (Washington, D.C.: Oct. 27, 2017).

115According to the Inspector General report, the fiscal year 2017 reporting metrics fully 

adopted a maturity model evaluation system derived from the National Institute of 

Standards and Technology’s Cybersecurity Framework. The Cybersecurity Framework is 

comprised of seven “domain” areas, and the modes (i.e., the number that appears most 

often) of the domain scores are used to derive the agency’s overall cybersecurity score. In 

this model, level 1 is the lowest maturity level, and level 5 is the highest maturity level.

116According to an earlier OPM Inspector General report, an information system 

authorization is a comprehensive assessment that evaluates whether a system’s security 

controls are meeting the security requirements of that system. The purpose of this 

assessment is to document the system’s controls, risks, and remediation plans. If the 

security risk associated with the system is deemed to be acceptable, then the system is 

formally authorized to operate in the agency’s production IT environment. OPM, Office of 

the Inspector General, Audit of the U.S. Office of Personnel Management’s Security 

Assessment and Authorization Methodology, 4A-CI-00-17-014 (Washington, D.C.: June 

20, 2017). According to the Office of the Inspector General at OPM, an IT material 

weakness is a severe control deficiency that prohibits the organization from adequately 

protecting its data; a significant deficiency is less serious than a material weakness. 
Page 51 GAO-18-29 Personnel Security Clearance Reform

substantial progress in implementing prior Inspector General 

recommendations. The report noted that OPM had only closed 34 percent 

of its findings issued in the past 2 years.117

In addition to these IT security concerns, funding uncertainties have also 

complicated the development of NBIS. The President’s fiscal year 2017 

budget included $95 million for the development of the system; however, 

according to DOD CIO officials, of the $95 million that was appropriated, 

DOD had provided only $31 million for NBIS as of June 2017.118

According to DOD CIO officials, the fiscal year 2017 continuing resolution 

had complicated decisions about the funding and disbursement schedule 

with consequences for planning and the apportioning of resources. A draft 

funding profile covering fiscal years 2017-2023 estimates funding needs 

of $175.7 million for research, development, test and evaluation, and 

$709.4 million for operation and maintenance, over this 7-year period, for 

a total of $885.2 million.

As NBIB transitions, it has taken steps to improve its operations but 

continues to face workforce challenges that may hinder its ability to 

address the backlog of investigation cases and strengthen the 

background investigation process. The bureau has taken positive steps to 

improve its oversight of background investigation contracts, including 

changing contract oversight processes and measuring the completeness 

of background investigations. However, it faces operational challenges in 

developing a plan to reduce the size of the investigation backlog and in 

ensuring that its overall workforce is sized and structured to address it.

Contractors are responsible for about 60 percent of NBIB’s background 

investigation fieldwork, according to NBIB officials. Since 2014, OPM has 

taken steps to improve its oversight of contracts. NBIB officials stated that 

changes were made in response to OPM Inspector General 

 117For information on the specific recommendations made in the OPM Inspector General’s 

report, and OPM’s response to those recommendations, please see the report, which is 

available at https://www.opm.gov/our-inspector-general/reports/.

118The Consolidated Appropriations Act, 2017, enacted on May 5, 2017, appropriated up 

to $95 million to DOD from the Defense-Wide Operation and Maintenance and DefenseWide Research, Development, Test and Evaluation accounts to develop, replace, and 

sustain OPM security and suitability background investigation IT systems. Pub. L. No. 

115-31, § 8125 (2017). A similar provision appeared in the Continuing Appropriations Act, 

2017, enacted in September 2016. Pub. L. No. 114-223, div. C, § 121 (2016).

NBIB Has Taken Steps to 

Improve Operations but 

Faces Workforce 

Challenges

OPM Has Taken Steps to 

Improve Oversight of 

Background Investigation 

Contracts
Page 52 GAO-18-29 Personnel Security Clearance Reform

recommendations, and that some others were made in response to 

lessons learned after issues that led to the loss of OPM’s largest fieldwork 

contractor in 2014. These changes included (1) having federal employees 

review all background investigation reports, (2) increasing the number of 

individuals responsible for monitoring contractors’ compliance with 

contractually established requirements, and (3) establishing a contracting 

activity within NBIB.

Since February 2014, federal employees have reviewed 100 percent of 

background investigation reports produced by contractors. In contrast, 

prior to February 2014, federal employees at FIS or a support contractor 

would review a subset of all of the investigations before releasing them to 

the respective customer agencies for adjudication. As currently 

structured, NBIB officials stated that there are now about 350 federal 

employees within NBIB’s Quality Oversight department who conduct 

these reviews for both contractor- and federal investigator-conducted 

cases to determine whether an investigation meets investigative 

standards for completeness before being released to the customer 

agency for adjudication.

Using an internal database, OPM reviewers identify what, if any, elements 

of the investigative reports are incomplete and do not meet standards, 

and they return cases to the investigators for rework as necessary. When 

OPM reviewers determine that a case meets investigative standards, they 

close the case and submit it to an adjudicator. Contractors are evaluated 

for quality performance based on the number of times a case is returned 

by OPM reviewers for rework as a percentage of the total number of 

cases completed. According to NBIB data from its internal quality 

database, the percentage of cases conducted by contractors requiring 

rework decreased between the last quarters of fiscal years 2014 and 

2016 from about 6 percent to 3.2 percent.

According to NBIB officials, in 2014, OPM established an independent 

inspections branch to help the agency’s contracting officer’s 

representatives (CORs) oversee the background investigation fieldwork 

contracts. CORs, who are designated in writing by contracting officers, 

assist in the technical monitoring or administration of a contract. Under 

NBIB’s current background investigation fieldwork contracts, the COR 

provides technical direction and control during contractor performance, 

monitors contract progress, and determines for payment approval 

purposes whether performance is acceptable with respect to content, 
Page 53 GAO-18-29 Personnel Security Clearance Reform

quality of services and materials, cost, and timeliness.119 NBIB officials 

stated that prior to the establishment of the inspections branch, the CORs 

were responsible for monitoring all aspects of contract compliance as well 

as a range of administrative duties, such as tracking performance data, IT 

support, and billing. Under the current NBIB structure, 16 inspectors in 

the Integrity Assurance, Compliance and Inspections division focus on 

contract oversight, according to NBIB officials. In addition to the 

inspectors, the officials said that there are 17 CORs—one in the Integrity 

Assurance, Compliance and Inspections division and 16 in the Field 

Operations department.

Additionally, according to NBIB officials, FIS, NBIB’s predecessor, did not 

have its own contracting division, and instead relied on OPM’s centralized 

Office of Procurement Operations for contracting support. NBIB’s new 

organizational structure includes a Contracting and Business Solutions 

department. According to NBIB officials, they filled the new Head of 

Contracting Activity position in January 2017. NBIB officials stated that 

OPM established this new position and department in an effort to 

strengthen the bureau’s contracting function by creating dedicated 

positions more narrowly focused on overseeing the contracting function 

for background investigations and support services.

NBIB has developed quality assurance processes and tools to measure 

the completeness of its investigations. Specifically, NBIB has developed 

an internal quality database through which federal case reviewers can 

determine the completeness of investigations, in accordance with 

investigative standards, that are being produced by both its federal and 

contract investigators, and can rate cases as either “meets standards” or 

“below standards.” Cases that are marked as “below standards” are 

returned to the contractor for rework prior to being finalized and sent to 

the customer for adjudication. NBIB then monitors, through its Key 

Performance Indicators, the percentage of investigations that are returned 

by customer agencies and that NBIB agrees require additional work. Our 

prior work found that relying on agencies to provide information on 

investigation quality, by itself, may not provide an accurate reflection of 

the quality of background investigations. We have reported in the past 

that officials from several agencies have stated that to avoid further costs 

 119CORs do not have authority to make commitments or changes that affect price, quality, 

quantity, delivery, or other terms and conditions of the contract, or to direct the contractor 

or subcontractors to operate in conflict with contract terms and conditions. 48 C.F.R. § 

1.602-2(d)(5) (2017).

NBIB Has Taken Steps to 

Measure Completeness of 

Background Investigations
Page 54 GAO-18-29 Personnel Security Clearance Reform

or delays, agencies often choose to perform additional steps internally to 

obtain missing information, clarify or explain issues identified in 

investigative reports, or gather evidence for issue resolution or 

mitigation.120 As recently as July 2017, DOD officials stated that issue 

resolution was still a concern for them. However, NBIB officials stated that 

they conduct background investigations in accordance with the Federal 

Investigative Standards, and that while adjudicators may want more or 

different details, these are considered outside the scope of background 

investigations, but can be provided on a case-by-case basis.

NBIB leadership has not developed a plan to reduce the size of the 

investigation backlog to a manageable level. NBIB’s Key Performance 

Indicators report states that a “healthy” inventory of work, representing 

approximately 6 weeks of work and allowing NBIB to meet timeliness 

objectives, is around 180,000 pending investigations. According to NBIB, 

the backlog of pending investigations increased from about 190,000 in 

August 2014, before OPM decided not to exercise subsequent option 

periods for its largest investigative fieldwork contract at the time, to more 

than 709,000 investigations as of September 2017, as shown in figure 

5.121 NBIB estimated the backlog grew at an average rate of about 3,600 

investigations each week from October 2016 through July 2017.

As we reported when placing DOD’s personnel security clearance 

program on the high-risk list, problems related to backlogs and the 

resulting delays in determining clearance eligibility and issuing initial 

clearances can result in millions of dollars of additional costs to the 

federal government, longer periods of time needed to complete national 

security-related contracts, lost opportunity costs if prospective employees 

decide to work elsewhere rather than wait to get a clearance, and 

diminishing quality of the work because industrial contractors may be 

performing government contracts with personnel who have the necessary 

security clearances but are not the most experienced and best-qualified 

personnel for the positions involved.122 Delays in renewing previouslyissued clearances can lead to heightened risk of national security 

 120See GAO-15-179SU and GAO-11-65.

121About 46 percent of the backlogged investigations as of July 2017 (approximately 

327,000) were for initial clearances, and about 28 percent (approximately 204,000) were 

for reinvestigations. The remaining 26 percent were for suitability and other cases.

122GAO-05-207.

NBIB Leadership Has Not 

Developed a Plan to Reduce 

the Investigation Backlog
Page 55 GAO-18-29 Personnel Security Clearance Reform

breaches because the longer individuals hold a clearance, the more likely 

they are to be working with critical information and systems.

Figure 5: National Background Investigation Bureau’s Backlog of Background 

Investigations, August 2014 to September 2017

As the backlog has grown, NBIB has taken steps to increase its capacity 

to conduct background investigations by increasing its own investigator 

staff as well as awarding new contracts, effective in December 2016, to 

four contractors for investigation fieldwork services. NBIB officials said 

that NBIB has a goal to increase its total number of investigators—federal 

employees and contractors—to about 7,200 by the end of fiscal year 

2017. Specifically, to help address the backlog, NBIB officials reported 

that NBIB increased its authorized federal investigator workforce by 

adding 400 federal investigator positions in fiscal year 2016 and 200 

positions in fiscal year 2017—an increase from 1,375 to 1,975 authorized 

positions.123 As of July 2017, NBIB had filled 1,620 of the 1,975 positions, 

and 1,513 of its federal investigators were fully trained. NBIB officials 

 123According to NBIB officials, the authorized federal investigator workforce refers to the 

workforce capacity approved by OPM.
Page 56 GAO-18-29 Personnel Security Clearance Reform

explained that they do not plan to increase the federal investigator 

capacity beyond the currently approved 1,975 because they do not have 

the ability to absorb more staff. According to the officials, new 

investigators must be trained by experienced investigators which reduces 

the amount of time the experienced investigators have to conduct 

investigative work. When estimating federal investigator capacity, NBIB 

assumes it will have 277 full-time equivalent vacancies at any given time 

due to high attrition rates. Further, NBIB officials could not project the 

federal investigator workforce past April 2018 due to high attrition rates.

Given challenges with increasing its federal investigative staff, NBIB 

continues to rely on contractors to conduct the majority of investigations. 

NBIB officials noted that contractors perform about 60 percent of NBIB’s 

total investigative cases. OPM awarded four new investigative fieldwork 

services contracts that became effective in December 2016—two to 

incumbent contractors and two to new vendors. In July 2017, OPM 

officials told us that the contractor and federal staff capacity they currently 

possess enables them to complete a sufficient number of investigations to 

prevent the number of pending investigations from increasing further. 

However, they acknowledged that the four contracts and federal 

investigator staff do not currently provide OPM enough capacity to reduce 

the pending number of investigations to the “healthy” inventory level of 

180,000 cases.

NBIB officials have conducted analyses to determine how changes in the 

total number of investigators could affect the backlog over time, 

accounting for current and projected investigator capacity, prior time 

studies, historical data, geographic location, and other factors. 

Specifically, NBIB officials assessed four scenarios, from the status quo—

assuming no additional contractor or federal investigator hires—to an 

aggressive contractor staffing plan beyond January 2018, but in July 2017 

they determined that the aggressive plan was not feasible. The two 

scenarios that NBIB identified as most feasible would not result in a 

“healthy” inventory level until fiscal year 2022 at the earliest. For example, 

under one scenario, each contractor would increase investigator capacity 

under current staffing projections through early 2018. Assuming that the 

contractors adhere to these projections, NBIB would have the capacity to 

address incoming cases and begin to reduce the backlog, but the backlog 

would not reach a “healthy” inventory level until sometime after fiscal year 

2022. However, NBIB leadership has not determined whether the costs 

and benefits of any one scenario are preferable to the costs and benefits 

of the others.
Page 57 GAO-18-29 Personnel Security Clearance Reform

Standards for Internal Control in the Federal Government establishes that 

management should clearly define objectives to enable the identification 

of risks and define risk tolerances.124 In addition, our high-risk criteria for 

capacity call for agencies to ensure they have the capacity, in terms of 

people and resources, to address and resolve risks.125 We have also 

found in previous work that milestones can be used to show progress 

toward implementing efforts, or to make adjustments when necessary.126

Developing and using specific milestones to guide and gauge progress 

toward achieving an agency’s desired results informs management of the 

rate of progress toward achieving goals or whether adjustments need to 

be made in order to maintain progress within given timeframes. However, 

NBIB leadership has not established goals or milestones for reducing the 

size of the investigation backlog, or goals for increasing total investigator 

capacity—for both federal employees and contractor personnel. As a 

result, the value of NBIB’s backlog analysis is limited, because it is not 

part of a broader plan to address the backlog and achieve timeliness 

objectives. Further, the extent to which NBIB should adjust its investigator 

capacity in the future remains unclear, as the currently projected capacity 

levels are not tied to any established goals or milestones to address the 

backlog or achieve the timeliness objectives.

In addition to increasing investigative capacity, NBIB personnel are 

attempting to decrease the backlog by making the background 

investigation process more effective and efficient. To do so, NBIB 

conducted a business process reengineering effort that was intended to 

identify challenges in the process and their root causes. This effort 

identified 57 challenges, which were divided into five main categories that 

affected multiple phases of the background investigation process. NBIB 

then developed five portfolios, with 21 initiatives, to address the identified 

challenges. For example, one of the categories of challenges was poor 

data quality at the start of the investigation, which was described as 

related to issues such as no auto-validation of information, no prepopulation of forms, and variable quality of submissions. NBIB developed 

four initiatives related to automation and digitization to improve the quality 

of this information. NBIB officials said that this business process 

reengineering effort is working to reduce the investigative level of effort 

 124GAO-14-704G. 

125GAO-17-317. 

126GAO/GGD/AIMD-99-69 and GAO/GGD-96-118.
Page 58 GAO-18-29 Personnel Security Clearance Reform

across the community. Specifically, NBIB officials cited efforts that have 

been implemented to reduce the number of personnel hours necessary to 

complete an investigation, such as centralizing interviews and using 

video-teleconferencing for overseas investigations (to decrease travel 

time), automated record checks, and focused writing (to make reports 

more succinct and less time-consuming to prepare). However, NBIB has 

not identified how the implementation of the business process 

reengineering effort will affect the backlog or the need for additional 

investigators in the future.

Without a plan, including goals and milestones, for reducing the backlog, 

which includes a determination of the effect of the business process 

reengineering efforts on the backlog, NBIB will lack the information and a 

course of action needed to effectively manage the inventory of pending 

investigations it conducts on behalf of other executive branch agencies. 

Further, without establishing goals for increasing total investigator 

capacity—for both federal employees and contractor personnel—in 

accordance with the plan for reducing the backlog, NBIB may not be 

positioned to achieve the goals and milestones outlined in that plan. 

Ultimately, if NBIB is unable to reduce the backlog, executive branch 

agencies will continue to lack the cleared personnel needed to help 

execute their respective missions, which could decrease the agencies’

overall effectiveness and efficiency, and pose risks to national security.

Our review of NBIB planning and workforce documents indicates that it 

has taken workforce planning steps. For example, the bureau developed 

a transition plan to help guide the transition from FIS to NBIB. This plan 

includes a request for a personnel study for its new Contracting and 

Business Solutions department to determine any needs or realignment of 

resources, skills, or qualification gaps; however, the transition plan does 

not mention a personnel study to address the needs of any other 

departments within NBIB. NBIB officials stated that the bureau conducted 

this study in early fiscal year 2017, and those results are being used to 

build the Contracting and Business Solutions department. NBIB officials 

said that NBIB plans to conduct a personnel study for its other 

departments once there is greater clarity and direction regarding the 

conduct of background investigations as a result of the plan developed by 

DOD to conduct its own investigations and any subsequent direction from 

Congress and the Administration. The officials stated that the personnel 

study was needed for the contracting department because this work had 

not been done in NBIB before and so they needed to establish a baseline 

for staffing it.

NBIB Has Identified Some 

Workforce Needs but Does Not 

Have a Strategic Workforce 

Plan
Page 59 GAO-18-29 Personnel Security Clearance Reform

As previously discussed, section 951 of the National Defense 

Authorization Act for Fiscal Year 2017 required, among other things, the 

Secretary of Defense to develop an implementation plan for the Defense 

Security Service to conduct background investigations for certain DOD 

personnel—presently conducted by OPM—after October 1, 2017.127 

Additionally, in November 2017, as this report was in its final stages, 

Congress passed a bill for the National Defense Authorization Act for 

Fiscal Year 2018, which includes a provision that, among other things, 

would authorize DOD to conduct its own background investigations. It 

would also require DOD to begin carrying out the implementation plan 

developed in response to section 951 by October 1, 2020.128 The 

legislation would further require the Secretary of Defense, in consultation 

with the Director of OPM, to provide for a phased transition of the conduct 

of investigations from NBIB to the Defense Security Service.129 Moreover, 

this legislation would require the Secretary of Defense to conduct a 

comprehensive assessment of workforce requirements for both DOD and 

NBIB as part of planning for the transfer of certain functions from OPM to 

DOD.130

In addition, the NBIB transition team developed a talent acquisition 

strategy for the establishment of the bureau; however, this strategy was 

focused solely on filling nine key leadership positions (according to NBIB 

officials, four positions are senior executive service positions, and five are 

general schedule grade 14 and 15 positions). As of July 2017, NBIB 

officials said that six of these positions had been filled, and that another 

position was in the process of being staffed. The only mention of other 

positions in this strategy was a statement that once these key leadership 

positions have been filled, executives should build their respective 

departments consistent with mission needs and aligned with the NBIB 

strategic plan, and that NBIB use current FIS leadership for field 

operations, engagements and customer service, and integrity assurance. 

According to NBIB officials, NBIB has 3,260 positions authorized by OPM 

but had 495 vacancies as of July 1, 2017—approximately a 15 percent 

 127See Pub. L. No. 114-328, § 951(a)(1) (2016). DOD delivered the report in August 2017.

128See H.R. Rep. No. 115-404, at 245-46 (2017) (Conf. Rep., relaying section 925 of the 

bill, as passed by the Senate on November 16 and the House of Representatives on 

November 14).

129See id.

130See id. at 246-47 (Conf. Rep., relaying section 925(d) of the bill). 
Page 60 GAO-18-29 Personnel Security Clearance Reform

vacancy rate. NBIB officials said that most positions were not affected by 

the recent executive-branch hiring freeze, including investigators and 

investigative assistants, because they qualified for national security 

waivers; however, some positions, such as administrative support, were 

not covered by the waivers.

The greatest total number of vacancies within NBIB is in its field 

operations department, which as of July 2017 had almost 400 vacancies, 

or a vacancy rate of about 17 percent. The Field Operations department 

provides contractor oversight, including program and project managers 

for fieldwork and CORs; it also includes federal investigator staff. NBIB 

officials stated that their greatest challenge in filling vacancies has been 

with their investigative workforce, and that as they fill their investigator 

positions, they will be able to better perform their mission of delivering 

completed background investigations in a timely manner due to having 

greater capacity. NBIB officials told us that they plan to hire another 200 

federal investigators in fiscal year 2017 to help address the backlog of 

investigations; however, hiring 200 new federal investigator positions was 

not listed as a step on the transition plan for the Field Operations 

department, and these new investigator positions also are not included in 

the planned new hires listing of personnel hiring priorities. NBIB officials 

said that these new investigator positions were not included in the 

transition plan because the decision to hire for these positions had 

already been made and the hiring was being executed when the transition 

plan was developed.

Furthermore, NBIB has developed detailed plans to hire new personnel. 

NBIB’s listing of personnel hiring priorities showed that NBIB initially 

planned to hire 155 new personnel. NBIB officials explained that in 

developing this initial hiring plan, organizational leaders assessed OPM 

legacy resources that would align with NBIB’s mission, roles and 

responsibilities, and identified gaps. These officials stated that at a 

leadership offsite held in December 2016, small groups identified existing 

and notional resources, prioritized resource gaps for identified programs, 

and briefed out their assessment of priorities. These officials said that the 

offsite participants then selected the top priorities for fiscal years 2017 

and 2018, and that NBIB leadership subsequently developed 

individualized proposals outlining revisions and changes to personnel 

requirements and organization of each of the program areas. NBIB 

officials said that they subsequently refined these plans and reduced the 

number of planned new hires. The officials stated that in 2017, NBIB 

established a transitional hiring committee to further prioritize and select 

the final NBIB personnel structure, and that through a series of meetings 
Page 61 GAO-18-29 Personnel Security Clearance Reform

in March, May, and June 2017, they refined their plans to reduce the 

number of planned new positions. As of July 2017, they said that NBIB 

planned to create and fill 49 new positions. According to NBIB officials, 13 

of the new positions would involve an increase to the budget.131 Of those 

49 new positions, they said that 21 had been filled as of July 2017.

In addition, NBIB uses contractor support to fill some positions in its Field 

Operations, Federal Investigative Records Enterprise, and customer 

service departments, but NBIB officials did not provide documentation 

explaining the determinations for which tasks should be performed by 

contractors versus federal employees. NBIB officials stated that they 

followed a deliberative process requiring a thoughtful assessment of the 

personnel resource skills and competencies required to address the new 

NBIB objectives, but they could not provide any supporting 

documentation to that effect.

A key principle of strategic workforce planning is determining the critical 

skills and competencies needed to achieve current and future 

programmatic results, such as identifying how the agency will obtain the 

workforce skills and competencies that are critical to achieving its 

strategic goals.132 In addition, OPM’s workforce planning best practices 

include forecasting the optimal headcount and competencies needed to 

meet the needs of the organization in the future, and a gap analysis to 

identify headcount surpluses and deficiencies for current and future 

demand levels.133 Further, OMB policy requires agencies to take actions 

to ensure they have sufficient internal capability to maintain control over 

functions that are core to the agency’s mission and operations.134

However, NBIB officials were unable to provide us with documentation 

that identified any of the gaps or explained the rationale for its 

determinations about the specific number and positions of additional staff 

 131According to documentation provided by NBIB, the 49 new positions are estimated to 

require budget increases of around $2.44 million in fiscal year 2017, and $7.22 million in 

fiscal year 2018, for a total increase of around $9.66 million over the FIS-NBIB transition 

period.

132GAO-04-39.

133OPM, Migration Planning Guidance Information Documents: Workforce Planning Best 

Practices (Washington, D.C.: Oct. 7, 2011).

134OMB, Office of Federal Procurement Policy Letter 11-01, Performance of Inherently 

Governmental and Critical Functions, 76 Fed. Reg. 56,227, 56,228 (Sept. 12, 2011).
Page 62 GAO-18-29 Personnel Security Clearance Reform

needed. The documents they did provide appeared to be summaries of 

the revisions and changes decided upon, and included detailed 

information about the identified staffing requirements, such as information 

about the number of positions, position titles and types, grade levels, and 

hiring priority. While this information reflects detailed planning and 

thought, it does not illuminate whether the quantities and types of 

positions identified are the appropriate positions with the right critical skills 

and competencies needed to address any gaps in the bureau’s 

workforce. NBIB officials said that the hiring plans were originally 

determined at the leadership offsite, where the rationale for the specific 

number and positions of additional staff was discussed orally, and then 

further refined at a series of meetings beginning in March 2017. The 

officials told us that extensive review went into determining the rationale

for the requests for new staff, and that these requests were the subject of 

robust and sometimes contentious debate, after which the requests were 

voted on by senior leadership.

Although NBIB has taken some steps to develop and implement certain 

strategic workforce planning elements, it has not created a 

comprehensive, formal workforce plan that is focused on workforce needs 

to reduce the backlog. Such a plan should include the workforce skills 

and competencies that are critical to achieving NBIB’s strategic goals. As 

we previously reported, the most important consideration in identifying 

needed skills and competencies is that they are clearly linked to the 

agency’s mission and long-term goals developed jointly with key 

congressional and other stakeholders during the strategic planning 

process. If an agency identifies staff needs without linking the needs to 

strategic goals, or if the agency has not obtained agreement from key 

stakeholders on the goals, the needs assessment may be incomplete and 

premature. In addition, a strategic workforce plan could enable NBIB to 

(1) develop hiring, training, staff development, succession planning, 

performance management, use of flexibilities, and other human capital 

strategies and tools that could be implemented with the resources that 

can be reasonably expected to be available; and (2) eliminate gaps and 

improve the contribution of critical skills and competencies that they have 

identified between the future and current skills and competencies needed 

for mission success.135 NBIB officials explained that a strategic workforce 

plan is something they should create, but that as a new organization the 

bureau was focused on other priorities, such as hiring a director, selecting 

 135GAO-04-39. 
Page 63 GAO-18-29 Personnel Security Clearance Reform

the headquarters location, addressing the backlog, and filling vacant 

positions. However, after being operational for almost a year, NBIB still 

lacks a comprehensive workforce plan.

While it has taken several other steps intended to strengthen the 

background investigation process, without a formal strategic workforce 

plan, NBIB does not know whether the identified needs in its new hires, 

transition plan, and overall workforce vacancies will provide the 

appropriate mix of personnel. Specifically, it does not know whether it has 

the appropriate mix of federal employees and contractors, with the right 

critical skills and competencies, to address any staffing gaps and better 

enable the bureau to fulfill its mission. A comprehensive strategic 

workforce plan that focuses on the workforce and organizational elements 

needed and addresses capacity issues related to its vacancies would 

better position NBIB to address its investigation backlog. Additionally, a 

comprehensive strategic workforce plan would better position the bureau 

to execute its roles and responsibilities related to overseeing the 

background investigations for DOD and other executive branch agencies 

that rely on NBIB as their investigative service provider.

The PAC has made progress in reforming the personnel security 

clearance process. However, 13 years after the passage of IRTPA, it is 

now at a crossroads. The backlog of background investigations totaled 

over 700,000 cases as of September 2017 and while the executive 

branch is taking actions to help address it, there are no indications that 

the government can readily do so.

We have noted in prior work concerns about the quality of background 

investigations and have emphasized the need to build quality throughout 

the personnel security clearance process for nearly two decades. Even 

though it has made significant attempts, the executive branch has still not 

established government-wide performance measures for the quality of 

background investigations to help ensure that critical security-relevant 

information is identified and mitigated when granting a security clearance. 

Over the past 2 years, the executive branch has taken steps toward 

establishing such measures. However, ODNI, as the Security Executive 

Agent, and the PAC have not prioritized setting a milestone for their 

completion. Without a milestone for establishing government-wide 

performance measures for the quality of investigations, their completion 

may be further delayed, and executive branch agencies will not have a 

schedule against which they can track progress or to which they are 

accountable.

Conclusions
Page 64 GAO-18-29 Personnel Security Clearance Reform

Executive branch timeliness in completing initial secret and initial top 

secret clearances has declined over the past 5 years. While ODNI has 

taken some steps to correct this downward trend on an agency-byagency basis, neither ODNI nor the PAC have led a government-wide 

approach to improve the timeliness of initial personnel security 

clearances. While ODNI requests that agencies submit corrective action 

plans when they are not meeting timeliness objectives, it has not 

developed a comprehensive, government-wide plan with goals and 

milestones. A government-wide plan would help position ODNI, as the 

Security Executive Agent, as well as the PAC, to better identify and 

address systemic issues across the executive branch that affect the 

ability of agencies to meet timeliness objectives.

IRTPA also created greater transparency and oversight of the overall 

reform effort by mandating annual reports to the appropriate 

congressional committees on the progress made toward meeting the act’s 

requirements, including reporting timeliness data. However, since the 

IRTPA reporting requirement ended in 2011, executive branch reporting 

has been limited, which makes it difficult to thoroughly evaluate and 

precisely identify where and why delays exist within the process, as well 

as to direct corrections as necessary. Without transparent reporting on 

investigation and adjudication timeliness, for both initial investigations and 

periodic reinvestigations, Congress will not be able to effectively execute 

its oversight role and monitor individual executive branch agency 

progress in meeting timeliness objectives.

The establishment of NBIB in 2016, to strengthen the background 

investigation process, involved a number of organizational changes and 

efforts to improve the process. While NBIB has taken steps to increase its 

investigative capacity, it faces challenges in developing a comprehensive 

plan, with goals and milestones, to address the investigation backlog. 

Without such a plan, NBIB lacks a necessary course of action to reduce

the backlog to a manageable level. Relatedly, NBIB has not established 

goals for increasing total investigator capacity. Establishing such goals, in 

accordance with the plan for reducing the backlog, may better position 

NBIB to achieve the goals and milestones outlined in that plan. Ultimately, 

if NBIB is unable to reduce the investigation backlog, executive branch 

agencies will continue to lack the cleared personnel needed to help 

execute their respective missions, which poses potential risks to national 

security. Demonstrated leadership from ODNI, in the capacity as the 

Security Executive Agent, and the PAC, by assisting NBIB as it works to 

reduce the investigation backlog could better position NBIB to reach a 

manageable level of investigations.
Page 65 GAO-18-29 Personnel Security Clearance Reform

Additionally, NBIB faces operational challenges related to workforce 

planning. While the bureau has taken a number of workforce planning 

steps, such as identifying specific hiring needs, it has not developed a 

strategic workforce plan. As a result, it may not know whether it has 

planned for the appropriate mix of personnel, with the right critical skills 

and competencies, and it has experienced delays in addressing its hiring 

needs. A comprehensive strategic workforce plan that focuses on the 

workforce and organizational elements needed and addresses capacity 

issues related to its vacancies would better position NBIB to address its 

investigation backlog and strengthen the investigation process.

Congress should consider reinstating the Intelligence Reform and 

Terrorism Prevention Act of 2004’s requirement for the executive branch 

to report annually to appropriate committees of Congress on the amount 

of time required by authorized investigative and adjudicative agencies to

conduct investigations, adjudicate cases, and grant initial personnel 

security clearances. Congress should also consider adding to this 

reporting requirement the amount of time required to investigate and 

adjudicate periodic reinvestigations and any other information deemed 

relevant, such as the status of the investigation backlog and implementing 

government-wide measures for the quality of investigations or other 

reform efforts. (Matter for Consideration 1)

We are making a total of six recommendations, including three to ODNI, 

in coordination with the PAC, and three to NBIB. Specifically,

• The Director of National Intelligence, in his capacity as Security 

Executive Agent, and in coordination with the other Security, 

Suitability, and Credentialing Performance Accountability Council 

Principals—the Deputy Director for Management of OMB in his 

capacity as Chair of the PAC, the Director of OPM, and the Under 

Secretary of Defense for Intelligence—should take the following three 

actions:

• establish a milestone for the completion of government-wide 

performance measures for the quality of investigations; 

(Recommendation 1)

• conduct an evidence-based review of the investigation and 

adjudication timeliness objectives for completing the fastest 90 

percent of initial secret and initial top secret security clearances, 

Matter for 

Congressional 

Consideration

Recommendations for 

Executive Action
Page 66 GAO-18-29 Personnel Security Clearance Reform

and take action to adjust the objectives if appropriate;

(Recommendation 2) and

• develop a government-wide plan, including goals and interim 

milestones, to meet those timeliness objectives for initial 

personnel security clearance investigations and adjudications.

(Recommendation 3)

• The Director of NBIB, in coordination with the Deputy Director for 

Management of OMB, in the capacity as Chair of the PAC, and the 

Director of National Intelligence, in the capacity as Security Executive 

Agent, should take the following two actions:

• develop a plan, including goals and milestones, that includes a 

determination of the effect of the business process reengineering 

efforts for reducing the backlog to a “healthy” inventory of work, 

representing approximately 6 weeks of work; (Recommendation 4) 

and

• establish goals for increasing total investigator capacity—federal 

employees and contractor personnel—in accordance with the plan 

for reducing the backlog of investigations. (Recommendation 5)

• The Director of NBIB should build upon NBIB’s current workforce 

planning efforts by developing and implementing a comprehensive 

strategic workforce plan that focuses on what workforce and 

organizational needs and changes will enable the bureau to meet the 

current and future demand for its services. (Recommendation 6)

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

Department of Justice, and the Department of Homeland Security for 

review and comment. OMB provided its comments via email, and the 

comments are summarized below. Written comments from ODNI and 

OPM are reprinted in their entirety in appendixes V and VI, respectively. 

OMB, ODNI, OPM, and the Department of Homeland Security provided 

additional technical comments, which we incorporated in the report as 

appropriate. DOD and the Department of Justice did not provide 

comments. OMB and OPM concurred with the recommendations directed 

to them. ODNI stated that it did not concur with the report’s conclusions 

and recommendations, but did not specifically state with which 

recommendations it did not concur.

In comments e-mailed to us on November 9, 2017, the Acting Deputy 

Director for Management of OMB concurred with the report’s findings, 

conclusions, and recommendations. The comments also stated that the 

Agency Comments 

and Our Evaluation
Page 67 GAO-18-29 Personnel Security Clearance Reform

administration is committed to renewing public reporting of security 

clearance timeliness, once the government-wide reform initiatives are 

announced in early 2018, either as one of the administration’s crosscutting priority goals or via another approach. While the PAC’s prior public 

reporting on the status of security clearance reform efforts was beneficial 

and helped to provide for transparency of the process, we believe that 

security clearance timeliness information should be reported—whether 

publicly or via reporting to Congress—broken out by individual executive 

branch agency and not only as an executive branch-wide average, as 

noted in our Matter for Congressional Consideration. As discussed in the 

report, such detailed reporting could help congressional decision-makers 

and OMB to thoroughly evaluate and precisely identify where and why 

delays exist within the process, as well as to direct corrections as 

necessary. In addition, OMB stated that the PAC is committed to ensuring 

that its Implementation Plan is continually updated to reflect the current 

status of reform efforts and that it incorporates any new initiatives arising 

from our review.

In its written comments, ODNI stated that the report appears to draw 

negative inferences from the facts and that the conclusions do not 

present an accurate assessment of the current status of the personnel 

security clearance process. ODNI also stated that the conclusions do not 

include the significant progress ODNI has achieved in coordination with 

executive branch agencies. We disagree with these statements. The 

report discusses in detail the progress that the PAC—of which ODNI is a 

Principal member—has made to reform the personnel security clearance 

process, including the implementation of recommendations and 

milestones from the 120-day and 90-day reviews, and cross-agency 

priority goal updates. The report also discusses areas of progress 

highlighted by ODNI officials, such as the development of seven Security 

Executive Agent Directives, the issuance of Quality Assessment 

Standards for background investigations, and the implementation of the

QART.

In its comments, ODNI further stated that while it generally concurred with 

the factual observations in the report, it did not concur with our 

recommendations. While ODNI did not specifically state with which 

recommendations it disagreed, it discussed each of the three 

recommendations addressed to it. In addition, ODNI stated that it did not 

concur with our conclusions, and provided specific observations in the 

following three areas, which lead to the three recommendations.
Page 68 GAO-18-29 Personnel Security Clearance Reform

First, ODNI disagreed with our conclusion that it has not prioritized setting 

a milestone for the completion of government-wide performance 

measures for the quality of background investigations. ODNI also stated 

that the report ignores significant progress that ODNI has made in this 

area; specifically, the approval of Quality Assessment Standards for 

background investigations and the implementation of the QART. We 

disagree with ODNI’s position, as the report discusses in detail both the 

Quality Assessment Standards and the QART, and identifies these as the 

two steps toward the development of performance measures for the 

quality of background investigations. Additionally, ODNI stated that it has 

the ability to determine trends in background investigative quality from the 

data collected by the QART. However, as we note in the report, DOD 

background investigations—which represent the majority of the 

investigations conducted by NBIB—are not captured by the QART. We 

further noted that according to NBIB officials, they are not positioned to

receive comprehensive feedback if their largest customer, DOD, is not 

utilizing the QART. Therefore, as we concluded in the report, it is unclear 

how ODNI will have sufficient data to develop government-wide measures 

for the quality of investigations since it will lack data for a significant 

portion of the executive branch’s background investigations.

Regarding our recommendation that the Director of National Intelligence, 

in coordination with the other PAC Principals, establish a milestone for 

the completion of government-wide performance measures for the quality 

of investigations, ODNI stated that it is premature to do so and that it will 

set a milestone once the QART metrics discussed above have been fully 

analyzed. However, in its written comments, ODNI did not state when it 

anticipates the QART metrics will be fully analyzed. We recognize that 

fully analyzing the QART data may take time and that initial performance 

measures may be refined as ODNI collects and assesses data regarding 

the quality of background investigations. However, setting a milestone—

that takes into consideration the amount of time needed to analyze QART 

data—will help to ensure that the analysis is completed, that initial 

performance measures are developed, and that agencies will have a 

greater understanding of what they are being measured against. We 

identify in the report that the executive branch previously set a milestone 

for the completion of government-wide performance measure for quality, 

which was adjusted over time and most recently set as October 2015. We 

further identify that the PAC has set milestones for the completion of 

nearly 50 other initiatives in its Implementation Plan, and that in the 

aftermath of the 2013 Washington Navy Yard shooting, the PAC (which 

includes ODNI) issued a 120-day review report that, among other things, 

recommended reporting on measures for quality. We continue to believe 
Page 69 GAO-18-29 Personnel Security Clearance Reform

that setting a milestone could help to prevent further delays to their 

completion and provide the executive branch with a schedule against 

which it would be accountable.

Second, ODNI did not agree with our conclusion that neither ODNI nor 

the PAC have led a government-wide approach to improve timeliness of 

initial personnel security clearances. In its written comments, ODNI 

discusses actions it has taken to improve timeliness since the passage of 

IRTPA, including resetting timeliness goals for certain clearances in 2012, 

in coordination with interagency stakeholders, issuing annual 

memorandums to agencies on their performance, and requesting that 

agencies develop agency-specific corrective action plans. We discuss all 

of these actions in the report and while we agree that they are positive 

actions, the executive branch would further benefit from a more 

coordinated approach. For example, even with the cited actions, the 

executive branch is experiencing significant challenges related to the 

timely processing of initial personnel security clearances. Specifically, as 

discussed in the report, in fiscal year 2016, only 2 percent of the agencies 

for which ODNI provided timeliness data met the 40-day IRTPAestablished investigation objective for at least three of four quarters for 

the fastest 90 percent of initial secret cases; and only 12 percent met 

ODNI’s revised investigation objective for at least three of four quarters 

for the fastest 90 percent of initial top secret cases. In addition, as 

discussed in the report, timeliness challenges are not only an issue for 

agencies that use NBIB as their investigative service provider. Agencies 

with delegated authority to conduct their own investigations have also 

experienced timeliness challenges over the past 5 fiscal years. Further, 

the timeliness challenges cited by agencies to GAO include governmentwide challenges, such as the increased investigative requirements—not 

just agency-specific challenges, such as staffing shortfalls. A governmentwide plan would better position ODNI to identify and address any 

systemic government-wide issues.

Regarding our recommendation that the Director of National Intelligence, 

in coordination with the other PAC Principals, conduct an evidence-based 

review of the timeliness objectives for completing initial secret and initial 

top secret security clearances, and take action to adjust the objectives if 

appropriate, ODNI stated that it is premature to revise the existing 

timeliness goals until NBIB’s backlog is resolved. In its written comments, 

ODNI states that while timeliness has exceeded the established 

standards, this is not necessarily an indication of a flaw in timeliness 

goals, but an indicator of the impact of the backlog and that as such, the 

current challenge in meeting timeliness should not serve as the sole basis 
Page 70 GAO-18-29 Personnel Security Clearance Reform

for modifying existing goals. Our recommendation is to conduct an 

evidence-based review of the timeliness objectives, through which ODNI 

could determine whether there are any issues with the timeliness goals 

or, as ODNI suggests, whether the timeliness challenges are just a 

reflection of the backlog. At the conclusion of that review, ODNI can 

determine if it is appropriate to adjust the timeliness objectives, and take 

action if necessary. We do not suggest that ODNI should immediately 

revise the timeliness objectives without first determining if there is an 

evidence-based need to do so. ODNI further notes that other agencies 

that are not supported by NBIB are still achieving or very close to 

achieving current standards. However, as discussed in the report, even 

agencies with delegated authority to conduct their own investigations are 

experiencing challenges meeting established timeliness objectives.

ODNI further stated in response to our recommendation that the Director 

of National Intelligence will continue to assess the impact of the 

implementation of the 2012 Federal Investigative Standards and modify 

the timeliness goals as appropriate. Given that ODNI has not 

comprehensively revisited the investigation or adjudication timeliness 

objectives for initial security clearances since 2012 despite the increased 

investigative requirements stemming from the implementation of the 2012 

Federal Investigative Standards, we continue to believe that our 

recommendation to conduct an evidence-based review, using relevant 

data, is valid.

Third, ODNI disagreed with our conclusion that demonstrated leadership 

from ODNI, in the capacity as the Security Executive Agent, and the PAC, 

by assisting NBIB as it works to reduce the investigation backlog could 

better position NBIB to reach a manageable level of investigations. ODNI 

stated that it has demonstrated leadership in this area and has worked 

closely as the Security Executive Agent with NBIB to reduce its 

investigation backlog and noted recent efforts by the Director of National 

Intelligence and the other PAC Principals to help reduce the backlog. We 

believe that these recent actions, which have taken place since the 

completion of our review, are positive steps that, along with our 

recommendations to NBIB, could help to reduce the backlog of 

background investigations. However, as discussed in the report, prior to 

these recent actions, ODNI had not demonstrated the leadership 

necessary to improve executive branch timeliness, as evidenced by the 

decrease in the number of agencies meeting timeliness objectives from 

fiscal years 2012 through 2016 and a backlog of over 700,000 

investigations as of September 2017. Additionally, while the recent 

actions could help to reduce the backlog, sustained demonstrated 
Page 71 GAO-18-29 Personnel Security Clearance Reform

leadership by the Director of National Intelligence and the other PAC 

Principals will be crucial to maintaining and increasing momentum, and 

ultimately critical to comprehensively addressing the current timeliness 

challenges and reducing the investigation backlog.

Regarding our recommendation that the Director of National Intelligence 

develop a government-wide plan, including goals and interim milestones, 

to meet timeliness objectives for initial personnel security clearances, 

ODNI stated that it has already established timeliness goals for the 

security clearance process and that prior to the investigation backlog, 

which was created, in part, due to a loss of OPM investigator capacity, 

the executive branch met those goals. ODNI further stated that until NBIB 

reduces its backlog, departments and agencies that use NBIB cannot 

accurately predict budgetary requirements for the phases of the security 

clearance process under their control, which complicates the 

development of a government-wide plan at this time. However, as 

discussed in the report, the most feasible date by which NBIB could 

reduce the backlog of background investigations to a “healthy” inventory 

level is fiscal year 2022 at the earliest. Given the significant timeliness 

challenges that the executive branch is currently experiencing, agencies 

would benefit from developing a government-wide plan now, rather than 

waiting at least 5 years for the reduction of the backlog to do so. In 

addition, through the development of a government-wide plan, ODNI 

could help to identify additional actions to more quickly reduce the 

investigation backlog. Without such a plan, continued delays in 

processing clearances may leave agencies unable to fill critical positions 

that require a security clearance. Ultimately, developing a governmentwide plan, including goals and interim milestones, will better ensure timely 

determinations of individuals’ eligibility for access to classified 

information. As such, we continue to believe that the recommendation is 

valid.

In its written comments, OPM concurred with the three recommendations 

directed to NBIB, and described some actions it plans to take to address 

them. Separate from the recommendations, OPM also provided 

comments related to the discussion in the draft report regarding DOD’s 

development of NBIS and the security of OPM’s IT systems and data. 

Specifically, OPM expressed concerns about some of the statements by 

DOD officials, stating that they were unverified opinions. We agree that 

including the countering views of OPM officials could provide some 

helpful context. As a result, we have added language to the report to 

include OPM’s perspectives on the statements made by the DOD CIO 

officials. 
Page 72 GAO-18-29 Personnel Security Clearance Reform

In addition, OPM stated that the prior GAO and OPM Inspector General 

audits referenced in the IT discussion were outdated audit assessments. 

We agree that some information in the draft report from the prior audits 

was based on reports from 2016 or earlier in 2017, and we understand 

that circumstances may have changed since those reports were issued. 

Specifically, the OPM Inspector General released a new audit report in 

October 2017, when this report was with the agency for comment, 

regarding the state of security of OPM IT systems. Accordingly, we 

replaced the discussion of the older OPM Inspector General reports in the 

draft report with a discussion of the OPM Inspector General’s October 

2017 report. This latest OPM Inspector General report found, among 

other things, that OPM had made improvements in its security 

assessment and authorization program, and its previous “material 

weakness” related to authorizations has been upgraded to a “significant 

deficiency” for fiscal year 2017. Overall, the OPM Inspector General 

found that OPM’s cybersecurity maturity level was measured at a level 2, 

“Defined”, meaning that its policies, procedures and strategy were 

formalized and documented, but were not consistently implemented. We 

also added language to emphasize the date of the 2016 GAO reports, 

and added information about the status of the recommendations from 

those two reports, because none of the recommendations directed to 

OPM from the two 2016 GAO reports had been closed as implemented 

as of November 2017. 

OPM further stated that it has implemented critical enhancements to 

strengthen the security of OPM’s networks and has improved its security 

and assessment authorization process. In the draft report, we stated that 

OPM has strengthened the security of its networks, and we noted that—

as stated in our 2017 report—OPM has made progress in improving its 

security to prevent, mitigate, and respond to data breaches involving 

sensitive personal records and background investigations information. 

However, as we noted our 2017 report, we also found that OPM did not 

effectively monitor actions taken to remediate identified weaknesses, and 

we continue to believe that discussion of the deficiencies we identified in 

our prior reports is appropriate in this report.

In November 2017, after the conclusion of our audit work, Congress 

passed a bill for the National Defense Authorization Act for Fiscal Year 

2018. Among other things, the bill includes a provision that would 

authorize DOD to conduct its own background investigations and require 

DOD to begin carrying out the implementation plan required by section 

951 of the National Defense Authorization Act for Fiscal Year 2017 by 

October 1, 2020. It would also require the Secretary of Defense, in 
Page 73 GAO-18-29 Personnel Security Clearance Reform

consultation with the Director of OPM, to provide for a phased 

transition.136 While this pending legislation may affect how some 

background investigations are conducted, we believe that our 

recommendations remain important points on which the executive branch 

should focus in order to help improve the security clearance process as 

these legislative changes are implemented.

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 Homeland Security, the 

Director of OPM, the Director of NBIB, the Attorney General of the United 

States, 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.

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. Contact 

points for our Offices of Congressional Relations and Public Affairs may

be found on the last page of this report. GAO staff who made significant 

contributions to this report are listed in appendix VII.

Brenda S. Farrell

Director, Defense Capabilities and Management

 136See H.R. Rep. No. 115-404, at 245-46 (2017) (Conf. Rep., relaying section 925 of the 

bill, as passed by the Senate on November 16 and the House of Representatives on 

November 14).
Page 74 GAO-18-29 Personnel Security Clearance Reform

List of Addressees

The Honorable John McCain

Chairman

The Honorable Jack Reed

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Mark R. Warner

Vice Chairman

Select Committee on Intelligence

United States Senate

The Honorable Shelley Moore Capito

Chairman

The Honorable Christopher Coons

Ranking Member

Subcommittee on Financial Services and General Government

Committee on Appropriations

United States Senate

The Honorable Mac Thornberry

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Devin Nunes

Chairman

The Honorable Adam Schiff

Ranking Member

Permanent Select Committee on Intelligence

House of Representatives
Page 75 GAO-18-29 Personnel Security Clearance Reform

The Honorable Tom Graves

Chairman

The Honorable Michael Quigley

Ranking Member

Subcommittee on Financial Services and General Government

Committee on Appropriations

House of Representatives

The Honorable Jon Tester

United States Senate
Appendix I: Status of Prior GAO Personnel 

Security Clearance Recommendations to 

Executive Branch Agencies as of November

2017

Page 76 GAO-18-29 Personnel Security Clearance Reform

Since May 2009, we have made 37 recommendations to appropriate 

executive branch agencies—the Office of Management and Budget 

(OMB), Office of Personnel Management (OPM), Office of the Director of 

National Intelligence (ODNI), Department of Defense (DOD), and 

Department of Homeland Security (DHS)—to improve the personnel 

security clearance process. As of November 2017, these agencies had 

implemented 12 of those recommendations; we closed 4 due to the 

inaction of the responsible agencies; and 21 remained open. Examples of 

implemented recommendations include DOD’s issuance of adjudication 

guidance related to incomplete investigative reports, ODNI and OPM’s 

jointly proposed chapter and part to the Code of Federal Regulations 

clarifying, among other things, the position sensitivity designation of 

national security positions, and DHS’s issuance of new standards for 

tracking information on security clearance revocations and appeals.

The 21 recommendations that remain open as of November 2017 

focused on different aspects of the personnel security clearance process. 

First, in February 2012, we reported on background investigation pricing 

and costs, and we found, among other things, that the Performance 

Accountability Council had not provided the executive branch with 

guidance on cost savings.1 Second, in September 2014, we reported on 

the security clearance revocation processes at DHS and DOD. We found 

that DHS and DOD data systems did not track complete revocation 

information; there was inconsistent implementation of the requirements in 

the governing executive orders by DHS, DOD, and some of their 

components; and there was limited oversight over the revocation process, 

among other things.2 Third, in April 2015, we reported on the status of 

government-wide security clearance reform efforts. We found, among 

other things, that limited progress had been achieved in implementing 

updated Federal Investigative Standards, and that the extent to which 

reciprocity is granted government-wide was unknown.3 Fourth, in 

 1

GAO, Background Investigations: Office of Personnel Management Needs to Improve 

Transparency of Its Pricing and Seek Cost Savings, GAO-12-197 (Washington, D.C.: Feb. 

28, 2012).

2

GAO-14-640. We noted in the report that although certain differences are permitted or 

required by the executive orders, some components’ implementation of the clearance 

revocation process could potentially be inconsistent with the executive orders or agency 

policy in two areas.

3

GAO, Personnel Security Clearances: Funding Estimates and Government-Wide Metrics 

Are Needed to Implement Long-Standing Reform Efforts, GAO-15-179SU (Washington, 

D.C.: Apr. 23, 2015) (FOUO/LE/INVESTIGATORY FILES PRIVILEGED).

Appendix I: Status of Prior GAO Personnel 

Security Clearance Recommendations to 

Executive Branch Agencies as of November 

2017
Appendix I: Status of Prior GAO Personnel 

Security Clearance Recommendations to 

Executive Branch Agencies as of November 

2017

Page 77 GAO-18-29 Personnel Security Clearance Reform

November 2017, we found that ODNI had taken an initial step to 

implement continuous evaluation across the executive branch, but it had 

not yet determined key aspects of the program; and it lacked plans for 

implementing, monitoring, and measuring program performance.4 See 

table 2 for the 21 open recommendations from these four reports as of 

November 2017.

Table 2: Open GAO Security Clearance Recommendations as of November 2017

GAO report 

number

Responsible agency Recommendation Agency’s 

response

1 GAO-12-197 Office of Management 

and Budget (OMB)

To improve transparency of costs and the efficiency of suitability and 

personnel security clearance background investigation processes that 

could lead to cost savings, expand and specify reform-related 

guidance to help ensure that reform stakeholders identify 

opportunities for cost savings, such as preventing duplication in the 

development of electronic case-management and adjudication 

technologies in the suitability determination and personnel security 

clearance processes. 

Concur

2 GAO-14-640 Department of 

Defense (DOD)

To help ensure that DOD data systems contain sufficiently complete 

and accurate information to facilitate effective oversight of the 

personnel security clearance revocation and appeal process, take 

steps to ensure that data are recorded and updated in the Joint 

Personnel Adjudication System (JPAS) and the department’s new 

systems, so that the relevant fields are filled. 

Concur 

3 GAO-14-640 DOD To help ensure independence and the efficient use of resources, first, 

resolve the disagreement about the legal authority to consolidate the 

Personnel Security Appeals Boards (PSAB) and, in collaboration with 

the PSABs and the Under Secretary of Defense for Intelligence, 

address any other obstacles to consolidating DOD’s PSABs. 

Partial concur 

4 GAO-14-640 DOD To help ensure independence and the efficient use of resources, and, 

if the General Counsel determines that there are no legal 

impediments and that other obstacles to consolidation can be 

addressed, take steps to implement the Secretary of Defense’s 

direction to consolidate DOD’s PSABs. 

Partial concur 

5 GAO-14-640 DOD To help ensure that all employees within DOD receive the same 

rights during the revocation process, revise Secretary of the Navy 

Manual M-5510. 30 to specify that any information collected by the 

Navy PSAB from the employee’s command will be shared with the 

employee, who will also be given the opportunity to respond to any 

such information provided. 

Concur 

 4

GAO, Personnel Security Clearances: Plans Needed to Fully Implement and Oversee 

Continuous Evaluation of Clearance Holders, GAO-18-117 (Washington, D.C.: Nov. 21, 

2017). 
Appendix I: Status of Prior GAO Personnel 

Security Clearance Recommendations to 

Executive Branch Agencies as of November 

2017

Page 78 GAO-18-29 Personnel Security Clearance Reform

GAO report 

number

Responsible agency Recommendation Agency’s 

response

6 GAO-14-640 DOD To help ensure that all employees within DOD receive the same 

rights during the revocation process, revise Army Regulation 380-67 

to specify that any information collected by the Army PSAB from the 

employee’s command or by the Army PSAB itself will be shared with 

the employee, who will also be given the opportunity to respond to 

any such information provided. 

Concur 

7 GAO-14-640 Department of 

Homeland Security 

(DHS)

To help ensure that all employees are treated fairly and receive the 

protections established in the executive order, revise the Coast 

Guard instruction for military personnel to specify that military 

personnel may be represented by counsel or other representatives at 

their own expense. 

Concur

8 GAO-14-640 Office of the Director 

of National Intelligence 

(ODNI)

To facilitate department-wide review and assessment of the quality of 

the personnel security clearance revocation process, in consultation 

with the Secretaries of Defense and Homeland Security, develop 

performance measures to better enable them to identify and resolve 

problems, and direct the collection of related revocation and appeals 

information. 

Concur 

9 GAO-14-640 DOD To facilitate coordination between personnel security and human 

capital offices regarding how a security clearance revocation should 

affect an employee’s employment status, and to help ensure that 

individuals are treated in a fair and consistent manner, in consultation 

with the Under Secretary of Defense for Intelligence, review and 

revise policy regarding coordination between the personnel security 

and human capital offices to clarify what information can and should 

be communicated between human capital and personnel security 

officials at specified decision points in the revocation process, and 

when that information should be communicated. 

Concur

10 GAO-14-640 DOD To help ensure that the Director of National Intelligence (DNI) report 

to Congress contains accurate data about the number of current DOD 

military and federal civilian employees eligible to access classified 

information, review and analyze the discrepancies in the total number 

of employees and the number of employees eligible to access 

classified information, and take immediate steps to address the 

problems. 

Concur

11 GAO-14-640 ODNI To help ensure that similarly situated individuals are treated 

consistently, and to facilitate oversight and help ensure the quality of 

the security clearance revocation process, review whether the 

existing security clearance revocation process is the most efficient 

and effective approach. In this review, the DNI should consider 

whether there should be a single personnel security clearance 

revocation process used across all executive-branch agencies and 

workforces, with consideration of areas such as the timing of the 

personal appearance in the revocation process, and the ability to 

cross-examine witnesses. Further, to the extent that a single process 

or changes to the existing parallel processes are warranted, the DNI 

should consider whether there is a need to establish any policies and 

procedures to facilitate a more consistent process, and recommend 

as needed any revisions to existing executive orders or other 

executive-branch guidance. 

Concur
Appendix I: Status of Prior GAO Personnel 

Security Clearance Recommendations to 

Executive Branch Agencies as of November 

2017

Page 79 GAO-18-29 Personnel Security Clearance Reform

GAO report 

number

Responsible agency Recommendation Agency’s 

response

12 GAO-15-179 SU OMB To assist executive-branch agencies in budget planning to implement 

the 2012 Federal Investigative Standards and obtain needed 

personnel security clearances, develop long-term funding estimates 

for changes to the federal government’s investigation practices 

resulting from the implementation of the standards. These long-term 

funding estimates should include but not be limited to: (1) costs 

related to information technology adjustments to enable governmentwide data sharing; (2) costs related to implementing continuous 

evaluation of clearance holders; and (3) costs related to additional 

personnel resources for twice-as-frequent reinvestigations. 

Concur

13 GAO-15-179 SU ODNI To provide decision makers—including OMB and Congress—with 

information on the quality of personnel security clearance background 

investigations and help ensure the quality of the investigations, 

develop, implement, and report to Congress on government-wide, 

results-oriented performance metrics to measure security clearance 

background investigation quality. 

Did not state

14 GAO-15-179 SU ODNI To provide executive-branch agencies necessary information 

concerning incomplete prior investigations or adjudications, develop 

procedures to require information sharing between executive-branch 

agencies concerning incomplete investigations or adjudications that 

may affect the eligibility of an individual for a security clearance. 

Did not state

15 GAO-15-179 SU ODNI To provide Congress with information on the extent of personnel 

security clearance background investigation and adjudication 

reciprocity, require the development of government-wide baseline 

data on required reciprocity determinations to support governmentwide metrics to measure the extent of reciprocity. 

Did not state

16 GAO-18-117 ODNI 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.

Concur

17 GAO-18-117 ODNI In coordination with the Continuous Evaluation Working Group, 

develop an implementation plan for continuous evaluation across the 

executive branch that 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.

Concur

18 GAO-18-117 ODNI Develop a plan for monitoring continuous evaluation performance, to 

include assessing continuous evaluation at various phases of 

implementation.

Concur

19 GAO-18-117 ODNI Develop performance measures 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.

Concur
Appendix I: Status of Prior GAO Personnel 

Security Clearance Recommendations to 

Executive Branch Agencies as of November 

2017

Page 80 GAO-18-29 Personnel Security Clearance Reform

GAO report 

number

Responsible agency Recommendation Agency’s 

response

20 GAO-18-117 ODNI 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.

Concur

21 GAO-18-117 ODNI 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.

Concur

Source: GAO status of open recommendations. I GAO-18-29
Appendix II: Overview of Selected Personnel 

Security Clearance Provisions in the 

Intelligence Reform and Terrorism Prevention 

Act of 2004 (IRTPA)

Page 81 GAO-18-29 Personnel Security Clearance Reform

The 2004 enactment of IRTPA initiated a reform effort that includes goals 

and requirements for improving the personnel security clearance process 

government-wide.1 Specifically, among other things, IRTPA required that:

• The President select a single entity—currently designated as the 

Office of the Director of National Intelligence—to be responsible for, 

among other things, the development and implementation of uniform 

and consistent policies and procedures to ensure the effective, 

efficient, and timely completion of security clearances.

• The President, in consultation with the head of the entity above, select 

a single agency—currently designated as the National Background 

Investigations Bureau within the Office of Personnel Management 

(OPM)—tasked with conducting, to the maximum extent practicable, 

security clearance investigations of federal employees and contractor 

personnel, among other things.2 It also required this entity to ensure 

that investigations are conducted in accordance with uniform 

standards and requirements.

• All security clearance background investigations and determinations 

completed by an authorized investigative agency or authorized 

adjudicative agency be accepted by all agencies (known as 

reciprocity), subject to certain exceptions.3

 1

Pub. 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. 

2

The Office of the Director of National Intelligence (ODNI), as the Security Executive 

Agent, may designate other agencies to conduct such investigations to the extent that it is 

not practicable to use NBIB. See Exec. Order No. 13,467, § 2.5(e)(vi), as amended 

through Exec. Order No. 13,764, 82 Fed. Reg. 8115, 8125 (Jan. 17, 2017).

3

IRTPA also provided that authorized investigative or adjudicative agencies may not 

establish additional investigative or adjudicative requirements, other than requirements for 

polygraph examinations, that exceed requirements specified in Executive Orders 

establishing security requirements for access to classified information without the approval 

of the agency selected under section 3001(b) (currently ODNI). However, it authorizes the 

head of that agency to establish additional requirements considered necessary for 

national security purposes. § 3001(d)(3) (codified at 50 U.S.C. § 3341(d)(3)). IRTPA also 

precluded authorized investigative or adjudicative agencies from conducting an 

investigation for the purposes of determining whether to grant a security clearance when a 

current investigation or clearance of equal level already exists or has been granted by 

another authorized adjudicative agency. § 3001(d)(4) (codified at 50 U.S.C. § 3341(d)(4)). 

As an exception to reciprocity, IRTPA authorized the head of the entity selected under 

section 3001(b) to disallow the reciprocal recognition of an individual security clearance on 

a case-by-case basis, if determined necessary for national security purposes. § 3001(d)(5) 

(codified at 50 U.S.C. § 3341(d)(5)).

Appendix II: Overview of Selected Personnel 

Security Clearance Provisions in the 

Intelligence Reform and Terrorism 

Prevention Act of 2004 (IRTPA)
Appendix II: Overview of Selected Personnel 

Security Clearance Provisions in the 

Intelligence Reform and Terrorism Prevention 

Act of 2004 (IRTPA)

Page 82 GAO-18-29 Personnel Security Clearance Reform

• Not later than 12 months after the date of enactment of the act, the 

Director of OPM in cooperation with the heads of the entities selected 

above, establish and commence operating and maintaining an 

integrated, secure database of personnel security clearance 

information.

• The executive branch evaluate the use of available information 

technology and databases to expedite investigative and adjudicative 

processes and to verify standard information submitted as part of an 

application for a security clearance and, not later than 1 year after 

enactment, submit a report to the President and the appropriate 

committees of Congress on the results of that evaluation.4

• The executive branch submit an annual report, through 2011, to the 

appropriate congressional committees on the progress made toward 

meeting IRTPA requirements, including timeliness data and a 

discussion of any impediments to the smooth and timely functioning of 

IRTPA requirements.5

IRTPA also established specific objectives for the timeliness of security 

clearance processing. Specifically, the act required the entity selected 

under section 3001(b) to develop a plan to reduce the length of the 

personnel security clearance process, in consultation with appropriate 

committees of Congress and each authorized adjudicative agency. To the 

extent practical, the plan was to require that each authorized adjudicative 

agency 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 by an authorized investigative 

agency—not longer than 40 days to complete the investigative phase and 

20 days to complete the adjudicative phase. IRTPA required the plan to 

take effect December 17, 2009.6

 4

This evaluation was to be conducted by the head of the entity selected under section 

3001(b). 

5

This report was to be submitted by the head of the entity selected under section 3001(b). 

6

See § 3001(g) (codified at 50 U.S.C. § 3341(g)). IRTPA also established timeliness 

requirements prior to the plan taking effect. Specifically, the act required that, from not 

later than December 2006 until the plan took effect, each authorized adjudicative agency 

make a determination on at least 80 percent of all applications within an average of 120 

days after receipt by an authorized investigative agency—not longer than 90 days to 

complete the investigative phase and 30 days to complete the adjudicative phase. § 

3001(g)(3)(B) (codified at § 3341(g)(3)(B)).
Appendix III: GAO Work on Personnel Security 

Clearance Quality and Executive Branch 

Efforts to Establish Government-wide 

Measures for the Quality of Investigations

Page 83 GAO-18-29 Personnel Security Clearance Reform

Since 1999 we have reported on issues related to investigative quality at 

the Department of Defense and the Office of Personnel Management and 

have issued recommendations to help ensure the personnel security 

clearance reform effort results in the development of metrics to track 

quality. Figure 6 provides an overview of our work in this area and 

executive branch efforts to establish government-wide performance 

measures for investigation quality.

Appendix III: GAO Work on Personnel 

Security Clearance Quality and Executive 

Branch Efforts to Establish Government-wide

Measures for the Quality of Investigations
Appendix III: GAO Work on Personnel Security 

Clearance Quality and Executive Branch 

Efforts to Establish Government-wide 

Measures for the Quality of Investigations

Page 84 GAO-18-29 Personnel Security Clearance Reform

Figure 6: Timeline Regarding Selected GAO Work and Executive Branch Efforts to Establish Government-wide Measures for 

the Quality of Investigations
Appendix IV: Timeliness of Executive Branch 

Periodic Reinvestigations

Page 85 GAO-18-29 Personnel Security Clearance Reform

In November 2017, we reported on the timeliness of the executive 

branch’s periodic reinvestigations for fiscal years 2012 through 2016, 

among other things.1 Our analysis of timeliness data for select executive 

branch agencies showed that the percent of agencies meeting timeliness 

goals decreased from fiscal year 2012 through 2016. The timeliness 

goals for periodic reinvestigations are outlined in a 2008 Joint Security 

and Suitability Reform Team report to the President entitled Security and 

Suitability Process Reform.2 Specifically, the report includes Office of 

Management and Budget-issued interim government-wide processing 

goals for security clearances for calendar year 2008. The calendar year 

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

reinvestigations is the same as the goal currently in place: 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. Table 3 shows the percent of executive 

branch agencies meeting the timeliness goals for investigating, 

adjudicating, and completing the fastest 90 percent of periodic 

reinvestigations for at least three of four quarters from fiscal years 2012 

through 2016.

Table 3: Percent of Executive Branch Agencies Meeting Timeliness Goals for the 

Fastest 90 Percent of Periodic Reinvestigations for at Least Three of Four Quarters 

of Fiscal Years 2012-2016

Fiscal year Investigation Adjudication End-to-end 

processing

2012 84 61 84

2013 76 73 71

2014 84 73 78

2015 16 80 22

2016 18 67 22

Source: GAO analysis of Office of the Director of National Intelligence (ODNI) information. I GAO-18-29

Note: We analyzed timeliness data from the Office of the Director of National Intelligence for specific 

executive branch agencies from fiscal years 2012 to 2016. The timeliness goals for the fastest 90 

percent of periodic reinvestigations are 15 days to initiate a case, 150 days to investigate, and 30 

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

reinvestigations.

 1

GAO-18-117. 

2

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

December 2008.

Appendix IV: Timeliness of Executive Branch

Periodic Reinvestigations
Appendix IV: Timeliness of Executive Branch 

Periodic Reinvestigations

Page 86 GAO-18-29 Personnel Security Clearance Reform

Specific details of the timeliness of initial secret and initial top secret 

clearances for select individual executive branch agencies were omitted 

because the information is sensitive.
Appendix V: Comments from the Office of the 

Director of National Intelligence

Page 87 GAO-18-29 Personnel Security Clearance Reform

Appendix V: Comments from the Office of 

the Director of National Intelligence
Appendix V: Comments from the Office of the 

Director of National Intelligence

Page 88 GAO-18-29 Personnel Security Clearance Reform
Appendix V: Comments from the Office of the 

Director of National Intelligence

Page 89 GAO-18-29 Personnel Security Clearance Reform
Appendix VI: Comments from the Office of 

Personnel Management

Page 90 GAO-18-29 Personnel Security Clearance Reform

Appendix VI: Comments from the Office of 

Personnel Management
Appendix VI: Comments from the Office of 

Personnel Management

Page 91 GAO-18-29 Personnel Security Clearance Reform
Appendix VI: Comments from the Office of 

Personnel Management

Page 92 GAO-18-29 Personnel Security Clearance Reform
Appendix VI: Comments from the Office of 

Personnel Management

Page 93 GAO-18-29 Personnel Security Clearance Reform
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 94 GAO-18-29 Personnel Security Clearance Reform

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov

In addition to the contact named above, Kimberly Seay (Assistant 

Director), Nathan Tranquilli (Assistant Director), Renee S. Brown, Chris 

Businsky, Molly Callaghan, Jenny Chanley, Katheryn Hubbell, Saida 

Hussain, Jeffrey L. Knott, James Krustapentus, Caryn E. Kuebler, 

Michael Shaughnessy, Rachel Stoiko, Paul Sturm, John Van Schaik, 

Cheryl Weissman, and Jina Yu made significant contributions to this 

report.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 95 GAO-18-29 Personnel Security Clearance Reform

Personnel Security Clearances: Additional Actions Needed to Address 

Quality, Timeliness, and Investigation Backlog. GAO-18-26SU. 

Washington, D.C.: December 7, 2017 (FOUO). 

Personnel Security Clearances: Additional Planning Needed to Fully 

Implement and Oversee Continuous Evaluation of Clearance Holders.

GAO-18-159SU. Washington, D.C.: November 21, 2017 (FOUO). 

Personnel Security Clearances: Plans Needed to Fully Implement and 

Oversee Continuous Evaluation of Clearance Holders. GAO-18-117. 

Washington, D.C.: November 21, 2017.

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: Actions Needed to Help Ensure Correct 

Designations of National Security Positions. GAO-14-139T. Washington, 

D.C.: November 20, 2013.

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.

Related GAO Products
Related GAO Products

Page 96 GAO-18-29 Personnel Security Clearance Reform

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.

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.
Related GAO Products

Page 97 GAO-18-29 Personnel Security Clearance Reform

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.

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.
Related GAO Products

Page 98 GAO-18-29 Personnel Security Clearance Reform

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: New Concerns Slow Processing of 

Clearances for Industry Personnel. GAO-06-748T. Washington, D.C.: 

May 17, 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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