GAO

United States Government Accountability Office

A

Testimony

Before the Subcommittee on Oversight of Government 

Management, the Federal Workforce, and the District of 

Columbia, Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

For Release on Delivery

Expected at 10:00 a.m. EDT

Tuesday, June 28, 2005

DOD PERSONNEL 

CLEARANCES 

Some Progress Has Been 

Made but Hurdles Remain 

to Overcome the 

Challenges That Led to 

GAO’s High-Risk 

Designation

Statement of Derek B. Stewart, Director

Defense Capabilities and Management

GAO-05-842T
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-842T.

To view the full product, click on the link 

above. For more information, contact Derek 

B. Stewart at (202) 512-5559 or 

stewartd@gao.gov. 

Highlights of GAO-05-842T, a testimony 

before the Subcommittee on Oversight of 

Government Management, the Federal 

Workforce, and the District of Columbia, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

June 28, 2005

DOD PERSONNEL CLEARANCES

Some Progress Has Been Made but 

Hurdles Remain to Overcome the 

Challenges that Led to GAO’s High-Risk 

Designation 

While DOD has taken steps to address the problems that led to designating 

its clearance program as high risk, continuing challenges are found in each 

of the three stages of DOD’s personnel security clearance process. Figure 1 

describes the process. 

Figure 1: DOD’s Process for Determining Clearance Eligibility

Preinvestigation: To address previously identified problems in projecting 

clearance workload, DOD is identifying the military and civilian positions 

that require clearances. Identifying clearance requirements for contractor 

personnel is still in the planning phase. Another problem is the efficient 

submission of investigation requests. In the 2 years since DOD and OPM 

announced the transfer of DOD’s investigative functions and personnel to 

OPM, the two agencies did not ensure the seamless submission of DOD 

requests to OPM. DOD is developing software to remedy this problem. 

Investigation: Delays in completing investigations are continuing. For 

February 2005, OPM—which now supplies an estimated 90 percent of the 

government’s clearance investigations—reported that over 185,000 of its 

clearance investigations had exceeded timeliness goals. OPM’s effort to add 

investigative staff is a positive step, but adding thousands of staff could 

result in continued timeliness problems and quality concerns as the staff 

gain experience. OPM’s workload should decrease because of two recent 

initiatives: (1) eliminating a few of the investigative requirements for some 

reinvestigations of personnel updating their clearances and (2) requiring the 

acceptance of clearances and access granted to personnel moving from one 

agency to another. 

Adjudication: In the past, DOD had difficulty monitoring who had been 

adjudicated for clearances and when the clearances needed to be renewed. 

While the Joint Personnel Adjudication System has combined databases 

from DOD’s 10 adjudicative facilities to enhance monitoring, wider 

consolidation of government databases may be required. The Director of 

OPM will need to integrate all federal agencies into a single governmentwide 

database in order to meet a requirement established in a recent law. As of 

September 30, 2003, DOD had a backlog of roughly 90,000 adjudications. 

Threats to national security—such 

as the September 11, 2001, terrorist 

attacks and high-profile espionage 

cases—underscore the need for 

timely, high-quality determinations 

of who is eligible for a personnel 

security clearance which allows an 

individual to access classified 

information. 

The Department of Defense (DOD) 

needs an effective and efficient 

clearance program because it is 

responsible for about 2 million 

active clearances and provides 

clearances to more than 20 other 

executive agencies as well as the 

legislative branch. Despite these 

imperatives, DOD has for more 

than a decade experienced delays 

in completing hundreds of 

thousands of clearance requests 

and impediments to accurately 

estimating and eliminating its 

clearance backlog. In January 2005, 

GAO designated DOD’s personnel 

security clearance program as a 

high-risk area. In February 2005, 

DOD transferred its personnel 

security investigative functions and 

about 1,800 positions to the Office 

of Personnel Management (OPM), 

after 2 years of negotiation 

between the agencies. 

This testimony provides an update 

on the challenges that led to GAO’s 

high-risk designation. It identifies 

both the positive steps that have 

been taken to address previously 

identified challenges and some of 

the remaining hurdles. GAO will 

continue to monitor this area. 
Page 1 GAO-05-842T 

Chairman Voinovich and Members of the Subcommittee:

I am pleased to be here today to discuss the Department of Defense’s 

(DOD) personnel security clearance program. As you know, Mr. Chairman, 

it is one of the 25 areas GAO has designated as high risk in our recent 

report, High-Risk Series: An Update.

1

 GAO’s high-risk list focuses on those 

major programs and operations that need urgent attention and 

transformation in order to ensure that our national government functions 

in the most economical, efficient, and effective manner possible. Also, 

some federal programs and operations are designated high risk because of 

their greater vulnerabilities to fraud, waste, abuse, and mismanagement.

Threats to our national security—such as the September 11, 2001, terrorist 

attacks and high-profile espionage cases—underscore the need for timely, 

high-quality determinations of who is eligible for a personnel security 

clearance that will allow the individual access to classified information. An 

increase in the operations and deployments of military personnel since 

September 11, 2001, and the sensitive technology that military personnel, 

government civilians, and contractors use are other factors suggesting the 

need for an effective and efficient clearance program. Because of its size 

and the many parts of the government affected by DOD’s personnel 

security clearance program, an efficient and effective process is needed. 

The Office of the Under Secretary of Defense for Intelligence (OUSD(I)) is 

responsible for the clearances issued to approximately 2 million personnel 

and for coordinating and implementing DOD-wide policies related to 

access to classified information. While most of those personnel are 

servicemembers and DOD’s federal employees and contractor personnel, 

OUSD(I) is also responsible for the clearances of contractors for more than 

20 other federal agencies as well as for staff in the legislative branch of the 

federal government.2

Notwithstanding the critical mission of DOD and the size of its program, 

our prior reviews for more than a decade have documented persistent 

problems with DOD’s personnel security clearance program. (See the 

1

 GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: January 2005).

2

 A list of agencies and a discussion of the executive order authorizing DOD to enter into 

agreements with these agencies can be found in footnote 9 in GAO, DOD Personnel 

Clearances: Additional Steps Can Be Taken to Reduce Backlogs and Delays in 

Determining Security Clearance Eligibility for Industry Personnel, GAO-04-632

(Washington, D.C.: May 26, 2004).
Page 2 GAO-05-842T 

reports listed at the end of this statement.) Since fiscal year 2000, DOD has 

declared its personnel security clearance investigations program to be a 

systemic weakness—a management control problem that affects more than 

one DOD component and may jeopardize the department’s operations—

under the Federal Managers’ Financial Integrity Act of 1982. In addition, an 

October 2002 House Committee on Government Reform report 

recommended to the Secretary of Defense to include DOD’s clearance 

adjudication process (use of background investigative information to 

determine eligibility for a clearance) as a material weakness.3

 After noting 

in our May 2004 report4

 that DOD had dealt with the impediments to timely 

clearances in a piecemeal fashion, we recommended that DOD develop and 

implement an integrated, comprehensive management plan to eliminate the 

backlog, reduce the delays in conducting investigations and determining 

eligibility for security clearances, and overcome the impediments that 

could allow such problems to recur. Although DOD partially concurred 

with our recommendation, the department had not implemented such a 

plan as of May 2005.

The longstanding delays in completing hundreds of thousands of clearance 

requests and the impediments that hinder DOD’s ability to accurately 

estimate and eliminate its clearance backlog led us to declare the program 

a high-risk area in January 2005.5

 Specifically, we found delays and 

impediments in all three stages of DOD’s personnel security clearance 

process shown in Figure 1. Shortly after we placed DOD’s clearance 

program on our high-risk list, a major change in the program occurred. In 

February 2005, DOD transferred its personnel security investigative 

functions and about 1,800 investigative positions to the Office of Personnel 

Management (OPM). Now, DOD obtains nearly all of its clearance 

investigations from OPM.6

 The Deputy Associate Director of OPM’s Center 

for Investigations Services estimated that OPM is responsible for about 90 

3

 Committee on Government Reform, U.S. House of Representatives, Defense Security 

Service: The Personnel Security Investigations [PSI] Backlog Poses a Threat to National 

Security, H.R. Rep. No. 107-767, at 2 (2002).

4 GAO-04-632.

5 GAO-05-207.

6

 Currently the National Security Agency, Defense Intelligence Agency, and National 

Reconnaissance Office each have a 1-year waiver that allows them to contract for their own 

personnel security clearance investigations. OUSD(I) officials said they do not anticipate 

that the waivers will be granted after the current waivers expire.
Page 3 GAO-05-842T 

percent of the more than 650,000 investigations for security clearances 

conducted in fiscal year 2004, in addition to nearly 842,000 public trust, 

regulatory, and non-sensitive background investigations.7

Figure 1: DOD’s Process for Determining Clearance Eligibility

Today, I would like to provide the Subcommittee with an update on the 

challenges that led to our designation of DOD’s personnel security 

clearance program as a high-risk area. I will discuss both the positive steps 

that have been taken to address previously identified concerns and some of 

the remaining hurdles. My comments will be organized around the three 

stages (preinvestigation, investigation, and adjudication) in DOD’s 

personnel security clearance process.

My comments are based primarily on our completed work and our 

institutional knowledge from our prior reviews of the clearance process at 

DOD and other agencies. In addition, we used information from the 

Intelligence Reform and Terrorism Prevention Act of 20048

 and 

perspectives and statistical data that DOD and OPM officials supplied 

7

 The Deputy Associate Director of OPM’s Center for Investigations Services noted that the 

following departments/agencies have statutory or delegated authority to conduct 

background investigations: Central Intelligence Agency; Department of State; Department 

of the Treasury; Internal Revenue Service; Bureau of Engraving and Printing; Federal 

Bureau of Investigation; National Security Agency; U.S. Agency for International 

Development; Department of Homeland Security; Bureau of Customs and Border 

Protection; U.S. Secret Service; Small Business Administration; Broadcasting Board of 

Governors; Department of Justice—Bureau of Alcohol, Tobacco, Firearms, and Explosives; 

U.S. Postal Service; Tennessee Valley Authority; National Reconnaissance Office; and Peace 

Corps. Even though these agencies have authority to conduct their own investigations, some 

of them request OPM to conduct all or part of their investigations.

8

 Pub. L. No. 108-458 (Dec. 17, 2004).

After determining that a 

position requires the 

employee to have access 

to classified information, 

the requesting organization 

submits an individual’s 

personnel security 

questionnaire to OPM.

OPM or one of its 

contractors conducts a 

background investigation 

and forwards a report to 

one of DOD’s 

adjudication facilities.

Based on information in 

the investigative report, an 

adjudicator determines 

eligibility for access to 

classified information, and 

forwards this determination 

to the requesting 

organization.

Source: DOD.

Preinvestigation stage Investigation stage Adjudication stage
Page 4 GAO-05-842T 

during interviews and in written documents gathered as part of our routine 

monitoring of steps that had been taken to improve DOD’s personnel 

security clearance program. We conducted our work in accordance with 

generally accepted government auditing standards between February and 

June 2005.

Summary DOD has taken steps to address challenges found in each of the three 

stages of its personnel security clearance process, but this progress cannot 

be fully evaluated at this time because many of the steps have not been 

completed. In the preinvestigation stage, previous uncertainty in projecting 

the number and types of clearances made it difficult for DOD to determine 

budgets and staffing needs. The military services have begun identifying 

which military and civilian positions require clearances and the level of the 

clearance needed; however, the clearance requirements process for 

contractor personnel is still in the planning phase. Also, DOD has not been 

able to make full use of OPM’s electronic system for submitting requests for 

clearance investigations. Despite having 2 years between the time when 

OPM and DOD announced an agreement to transfer DOD’s investigative 

functions and personnel to OPM and when this transfer actually occurred, 

DOD and OPM did not ensure that software was available for the seamless 

submission of requests from DOD’s system to OPM’s. Converting a DOD 

request for investigation into a format that is acceptable to OPM’s system 

and obtaining missing or corrected data to open the investigation delays 

completion of the clearance process. Until these two issues are fully 

addressed, DOD will continue to encounter problems determining budgets 

and staff and minimizing the delays in completing the clearance process.

For the investigation stage, OPM reported that more than 185,000 of its 

clearance investigations had exceeded timeliness goals during February 

2005. In December 2003, DOD and OPM did not have sufficient numbers of 

investigative personnel. Combined, they had about 4,200 full-timeequivalent investigative staff, but an OPM official at that time estimated 

that DOD and OPM would need about 8,000 full-time-equivalent 

investigative staff to eliminate backlogs and deliver investigations on time. 

Since then, OPM has added investigative staff, but adding thousands of 

staff could result in continued timeliness problems and quality concerns as 

the staff gain experience. However, the governmentwide investigative 

workload should decrease because of two recent developments: (1) the 

elimination of formerly required interviews and other data gathering during 

some reinvestigations for renewal of top secret clearances and (2) the 
Page 5 GAO-05-842T 

requirement for government agencies to accept clearances and access 

granted to personnel by other agencies. 

For the third step in the clearance process, the adjudication stage, our 

reviews documented problems in monitoring overdue reinvestigations and 

generating accurate estimates of the backlog that were both partially due to 

DOD maintaining separate databases for each of its 10 adjudication 

facilities. DOD has largely implemented its Joint Personnel Adjudication 

System to consolidate the databases and thereby has addressed some of 

our adjudication-related concerns. While this is a positive step, the Director 

of OPM must now establish and maintain a single governmentwide 

database as required by the Intelligence Reform and Terrorism Prevention 

Act of 2004. As of September 30, 2003, DOD had a backlog of roughly 90,000 

completed investigations that had not been adjudicated within prescribed 

time limits. In addition, even though we made four recommendations for 

improving DOD’s adjudicative process in April 2001 and DOD concurred 

with those recommendations, none has been fully implemented at this 

time.

Background Since 1997, all federal agencies have been subject to a common set of 

personnel security investigative standards and adjudicative guidelines for 

determining whether servicemembers, government employees, industry 

personnel, and others are eligible to receive a security clearance.9

Clearances allow personnel to access classified information categorized 

into three levels: top secret, secret, and confidential.10 The expected 

damage to national defense and foreign relations that unauthorized 

disclosure could reasonably be expected to cause is “exceptionally grave 

damage” for top secret information, “serious damage” for secret 

information, and “damage” for confidential information. Individuals who 

need access to classified information for extended periods of time are 

required to periodically renew their clearance (a reinvestigation). The time

9

 The White House, “Implementation of Executive Order 12968,” Memorandum (Washington, 

D.C.: Mar. 24, 1997). This memorandum approves the adjudication guidelines, temporary 

eligibility standards, and investigative standards required by Executive Order 12968, Access 

to Classified Information (Aug. 2, 1995).

10 Classified Designations, 5 C.F.R. § 1312.4 (2005).
Page 6 GAO-05-842T 

frames for reinvestigations are 5 years for top secret clearances, 10 years 

for secret clearances, and 15 years for confidential clearances.11

In addition to requiring different time frames for renewal, the different 

levels of clearances require that different types of background information 

be gathered and used in making the adjudicative decision about whether an 

individual is or is not eligible for a clearance (see table 1). Much of the 

information for a secret or confidential clearance is gathered through 

electronic files. The investigation for a top secret clearance requires the 

information needed for the secret or confidential clearance as well as 

additional data which are gathered through time-consuming tasks, such as 

interviews with the subject of the investigation request, references in the 

workplace, and neighbors. OPM officials estimated that the time required 

to gather information to complete initial investigations for top secret 

clearances is twice that needed for reinvestigations for top secret 

clearances and 10 times as much as that needed for initial investigations or 

reinvestigations for secret or confidential clearances. DOD estimated that 

adjudicators’ reviews of the longer investigative reports for top secret 

clearances also take three times as long as the reviews of investigative 

reports for determining eligibility for secret or confidential clearances. 

Moreover, if the clearance required for a position is upgraded from secret 

to top secret, the investigation and adjudication would need to be 

performed twice as often (every 5 years instead of every 10 years).

11 Adjudicative Guidelines for Determining Eligibility for Access to Classified 

Information, 32 C.F.R. Part 147, Subpart B, Attach. A and Attach. C (2004).
Page 7 GAO-05-842T 

Table 1: Information Gathered to Determine Eligibility for a Security Clearance

Source: DOD.

Type of security clearance and investigation

Confidential or secret Top secret

Type of information gathered

Initial investigation or 

reinvestigation Initial investigation Reinvestigation

1. Personnel security questionnaire: The subject’s 

self-reported answers on a paper SF-86 form or an 

electronic form

X XX

2. National agency check: Data from the Federal 

Bureau of Investigation, military records centers, 

Department of the Treasury, etc.

X XX

3. Credit check: Data from credit bureaus where the 

subject lived/worked/attended school for at least 

6 months

X XX

4. Local agency checks: Data from law enforcement 

agencies where the subject lived/worked/attended 

school during past 5 years

X XX

5. Date and place of birth: Corroboration of 

information supplied on the personnel security 

questionnaire

X X

6. Citizenship: For individuals born outside of the 

United States, verification of U.S. citizenship directly 

from the appropriate registration authority

X

7. Education: Corroboration of most recent or 

significant claimed attendance, degree, or diploma

X X

8. Employment: Review of employment records 

and interviews with workplace references, such as 

supervisors and coworkers

X X

9. References: Data from interviews with 

subject-identified and investigator-developed leads

X X

10. National agency check for spouse or 

cohabitant: National agency check without fingerprint

X X

11. Former spouse: Data from interview(s) 

conducted with spouse(s) divorced within the last 

10 years

X X

12. Neighborhoods: Interviews with neighbors and 

verification of residence through records check

X X

13. Public records: Verification of issues, such as 

bankruptcy, divorce, and criminal and civil court cases

X X

14. Subject interview: Collection of relevant data, 

resolution of significant inconsistencies, or both

X X
Page 8 GAO-05-842T 

Progress and 

Continuing Challenges 

Found at Each Stage of 

DOD’s Personnel 

Security Clearance 

Process

We found that DOD has taken steps to address challenges found at all three 

stages of its personnel security clearance process, but many of the steps 

have not yet resulted in implementations that fully address the challenges. 

In the preinvestigation stage, DOD has begun decreasing the uncertainty in 

its projections of how many and what levels of clearances are required by 

identifying the clearances needed for military and civilian positions and 

developing software that will result in electronic submissions of clearance 

investigation requests to OPM. Regarding the second stage of the clearance 

process, OPM has been hiring investigative staff to address past personnel 

shortages and the resulting delays from having too few staff for the 

investigative workload. Adding thousands of staff could, however, result in 

continued timeliness problems as well as quality concerns until the staff 

gain experience. Regarding the adjudication stage, DOD’s Joint Personnel 

Adjudication System consolidated the databases for 10 DOD adjudication 

facilities to enhance monitoring of adjudicative decisions and time frames 

for renewing clearances, but a new law requires a governmentwide 

clearance database.

Preinvestigation Steps 

Being Taken to Help DOD 

Identify Requirements for 

Clearances and Address 

Submission of Requests for 

Clearance Investigations

At this time, DOD is uncertain about the number and level of clearances 

that it requires and has experienced problems submitting investigation 

requests, but the department has begun addressing these problems. DOD’s 

inability to accurately project such clearance requirements makes it 

difficult to determine budgets and staffing needs. DOD is addressing this 

problem by identifying the clearance needs for military and civilian 

positions, but no military service had completed this task as of May 2005. 

Similarly, in response to our May 2004 recommendation to improve the 

projection of clearance requirements for industry personnel, DOD 

indicated that it is developing a plan and computer software to have the 

government’s contracting officers authorize the number of industry 

personnel investigations required to perform the classified work on a given 

contract and link the clearance investigations to the contract number. 

Despite having 2 years between the time when OPM and DOD announced 

an agreement for the transfer of DOD’s investigative functions and 

personnel to OPM and when the transfer actually occurred, DOD cannot 

make full use of OPM’s Electronic Questionnaires for Investigations 

Processing (eQIP), the system used to submit materials required to start a 

background investigation. To overcome this challenge to the prompt and 

efficient submission of investigation requests, DOD is developing software 

that will convert the department’s submissions into the eQIP format. Also, 
Page 9 GAO-05-842T 

OPM told us that about 11 percent of the February 2005 clearance 

investigation requests submitted outside of eQIP were returned to the 

requesting offices when missing or discrepant information could not be 

obtained telephonically. Converting a DOD request for investigation into a 

format that is compatible with OPM’s eQIP and obtaining missing or 

corrected data to open an investigation delays the completion of the 

clearance process. OPM does not monitor how many days elapse between 

initial submissions and resubmissions of corrected material and, therefore, 

does not include that time in its calculations of the average time required to 

complete an investigation. Until DOD implements the software currently 

being developed and fully determines its clearance requirements, the 

department will continue to encounter problems determining budgets and 

staff and minimizing the delays in completing the clearance process.

Delays Exist in Completing 

Investigations, but Recent 

Steps May Decrease the 

Delays

DOD and the rest of the government serviced by OPM are not receiving 

completed investigations promptly, but recent initiatives may decrease 

these delays. For February 2005, OPM told us that it had more than 185,000 

investigations governmentwide that had taken longer than its goals for 

closing cases: 120 days for initial investigations and 180 days for 

reinvestigations. The current goals for completing a case allow more time 

than did the DOD goals reported in our earlier work and, therefore, 

comparison of the investigation backlog size that OPM reported in 

February 2005 to the backlog size cited in our prior reviews would not 

provide any meaningful information.12 The Intelligence Reform and 

Terrorism Prevention Act of 2004 requires that not later than December 17, 

2006, and ending December 17, 2009, each authorized adjudicative agency 

shall make a determination on at least 80 percent of all applicants for 

personnel security clearances within an average of 120 days—90 days to 

complete the investigation and 30 days to complete the adjudication—of

12 For example, DOD’s performance goals were to have 75 percent of its in-house 

investigations completed in the following time frames: 120 days for a periodic 

reinvestigation for a top secret clearance, 90 days for an initial top secret clearance, and 75 

days for either a secret or confidential clearance being issued initially. Therefore, if these 

DOD goals were applied to the current OPM inventory of investigations, the size of the 

backlog would be higher.
Page 10 GAO-05-842T 

receiving the security clearance application.13 Also, not later than February 

15, 2006, and annually thereafter through 2011, a report on the progress 

made during the preceding year toward meeting these goals is to be 

supplied to appropriate congressional committees.14 Table 2 shows that, 

across the government, standard service for both initial investigations and 

reinvestigations for top secret clearances resulted in more than 1 year 

elapsing, on average, between submitting the investigation requests and 

closing the investigations. OPM does, however, permit agencies to request 

priority (expedited) processing on a limited number of investigations, and 

those investigations took less time to close. Table 2 also shows a difference 

in the time required to close initial investigations and reinvestigations for 

top secret clearances.

Table 2: February 2005 Governmentwide Findings on the Types of Investigations for Different Clearances, Average Number of 

Days Used to Close an Investigation, and the Number of Investigations Exceeding Goals for Closing

Source: OPM.

In February and May 2004, we reported that different risks are associated 

with delays in completing initial investigations and reinvestigations.15

Delays in completing initial personnel security clearances can have 

negative impacts on the costs of performing classified work within or for 

13 Pub. L. No. 108-458, § 3001(g) (Dec. 17, 2004). The act also notes that the time frame for 

completing clearances will reduce further once 5 years have elapsed from the enactment. At 

that time, the act notes that to the extent practical, each authorized adjudicative agency 

shall make a determination on at least 90 percent of all applications for a personnel security 

clearance within an average of 60 days—40 days to complete the investigation and 20 days 

to complete the adjudication.

14 Pub. L. No. 108-458, § 3001(h) (Dec. 17, 2004).

Type of investigation

Type of 

processing

Average number

of days to close

Number exceeding the

goals for closing

Initial investigations and reinvestigations for 

secret/confidential clearances

Priority 87 555

Standard 160 99,543

Initial investigations for top secret clearances Priority 115 1,938

Standard 370 47,444

Reinvestigations for top secret clearances Standard 498 36,320

Total 185,800

15GAO-04-344 and GAO-04-632.
Page 11 GAO-05-842T 

the U.S. government. For example, delays in clearing industry personnel 

can affect the cost, timeliness, and quality of contractor performance on 

defense contracts. Conversely, delays in completing reinvestigations may 

lead to a heightened risk of national security breaches because the longer 

individuals hold clearances, the more likely they are to be working with 

critical information systems.

Our prior review noted that delays in completing personnel security 

clearance investigations for DOD and other agencies have resulted, in part, 

from a shortage of investigative staff. In February 2004, we noted that the 

Deputy Associate Director of OPM’s Center for Investigations Services 

estimated that OPM and DOD would need a total of roughly 8,000 full-timeequivalent investigative personnel16 to eliminate backlogs and deliver 

investigations in a timely fashion to their customers.17 To reach its goal of 

8,000, OPM must add and retain approximately 3,800 full-time equivalent 

investigative staff, and retain all of the estimated 4,200 full-time-equivalent 

staff that OPM and DOD had combined in December 2003. In our February 

2004 report, we noted that OPM’s primary contractor was adding about 100 

and losing about 70 investigators per month. If the high rate of turnover has 

continued, the ability to grow investigative capacity could be difficult. In 

addition, OPM could be left with a large number of investigative staff with 

limited experience.

OPM’s Deputy Associate Director noted that the inexperience among 

investigative staff results in investigations not being completed as quickly 

as they might have been if the investigators were more experienced. The 

OPM official also noted that the quality of the investigations is not where 

she would like to see it. As we noted in our September 2004 testimony 

before this subcommittee,18 OPM had continued to use its investigations 

contractor to conduct personnel security clearance investigations on its 

own employees even though we raised an internal control concern about 

16 In our February 2004 report, we noted that OPM’s estimate includes workers who may be 

(1) investigators or investigative technicians, (2) federal or contracted staff, and (3) full- or 

part-time employees. 

17 GAO, DOD Personnel Clearances: DOD Needs to Overcome Impediments to Eliminating 

Backlog and Determining Its Size, GAO-04-344 (Washington, D.C.: Feb. 9, 2004).

18 GAO, Intelligence Reform: Human Capital Considerations Critical to 9/11 

Commission’s Proposed Reforms, GAO-04-1084T (Washington, D.C.: Sept. 14, 2004).
Page 12 GAO-05-842T 

this practice during our 1996 review. 19 OPM officials indicated that they 

plan to use the government employees that were transferred from DOD to 

address this concern.

In addition to adding staff, two other initiatives should decrease delays in 

completing clearance investigations. A new DOD initiative—the phased 

periodic reinvestigation (phased PR)—that we discussed in our May 2004 

report can make more staff available and thereby decrease the workload 

associated with some reinvestigations for top secret clearances.20 The 

phased approach to periodic reinvestigations involves conducting a 

reinvestigation in two phases; a more extensive reinvestigation would be 

conducted only if potential security issues were identified in the initial 

phase. Specifically, investigative staff would verify residency records and 

conduct interviews of listed references, references developed during the 

investigation, and individuals residing in the neighborhood only if potential 

security issues were identified in other parts of the standard reinvestigation 

process. The Defense Personnel Security Research Center showed that at 

least 20 percent of the normal investigative effort could be saved with 

almost no loss in identifying critical issues needed for adjudication. In 

December 2004, the President approved the use of the phased PR for 

personnel needing to renew their top secret clearances.

Another source of investigative, as well as adjudicative, workload 

reduction may result from the recent reciprocity requirements contained in 

the Intelligence Reform and Terrorism Prevention Act of 2004.21 Our May 

2004 report noted that the lack of reciprocity (the acceptance of clearance 

and access granted by another department, agency, or military service) was 

cited as an obstacle that can cause contractor delays in filling positions and 

starting work on government contracts. Under the new law, all security 

clearance background investigations and determinations completed by an 

authorized investigative agency or authorized adjudicative agency shall be 

accepted by all agencies.

19 GAO, Privatization of OPM’s Investigations Service, GAO/GGD-96-97R (Washington, 

D.C.: Aug. 22, 1996).

20 GAO-04-632.

21 Pub. L. No. 108-458, § 3001(d) (Dec. 17, 2004).
Page 13 GAO-05-842T 

Joint Personnel 

Adjudication System 

Consolidates DOD 

Adjudicative Data, but a 

New Law Requires Wider 

Consolidation

DOD’s Joint Personnel Adjudication System (JPAS) consolidated 10 DOD 

adjudication databases to provide OUSD(I) with better monitoring of 

adjudication-related problems, but a new law requires wider consolidation. 

Past delays in implementing DOD’s JPAS greatly inhibited OUSD(I)’s ability 

to monitor overdue reinvestigations and generate accurate estimates for 

that portion of the backlog. In addition to correcting these problems, 

implementation of much of JPAS has eliminated the need for DOD’s 10 

adjudication facilities to maintain their own databases of adjudicative 

information. This consolidation may also assist with a requirement in the 

Intelligence Reform and Terrorism Prevention Act of 2004.22 Among other 

things, the law requires that not later than December 17, 2005, the Director 

of OPM shall, in cooperation with the heads of the certain other 

government entities, establish and commence operating and maintaining a 

single, integrated, secure database into which appropriate data relevant to 

the granting, denial, and revocation of a security clearance or access 

pertaining to military, civilian, or government contractor personnel shall be 

entered from all authorized investigative and adjudicative agencies. OPM 

officials stated that JPAS and OPM’s Clearance Verification System account 

for over 90 percent of the government’s active security clearances and that 

the remaining clearances are primarily housed in classified record systems 

(e.g., the Central Intelligence Agency’s Scattered Castles) devoted to the 

intelligence community.

Additionally, DOD may move closer toward the 9/11 Commission’s 

recommendation of having a single government agency responsible for 

providing and maintaining clearances by co-locating its 10 adjudication 

facilities on a single military installation. The recent base realignment and 

closure list includes a recommendation to co-locate all of DOD’s 

adjudication facilities. While co-location—if it occurs—would not be the 

same as consolidation, it might provide opportunities for greater 

communication within DOD. However, the proposed co-location at Fort 

Meade, Maryland, could also result in the loss of trained staff who might 

choose not to relocate, such as some of the roughly 400 employees in the 

Defense Industrial Security Clearance Office and the Defense Office of 

Hearings and Appeals Personal Security Division in Columbus, Ohio.

22 Pub. L. No. 108-458, § 3001(e) (Dec. 17, 2004).
Page 14 GAO-05-842T 

In our February 2004 report,23 we noted that DOD had (1) as of September 

30, 2003, a backlog of roughly 90,000 completed investigations that had not 

been adjudicated within prescribed time limits, (2) no DOD-wide standard 

for determining how quickly adjudications should be completed, and 

(3) inadequate adjudicator staffing. Also at the time of our report, the DOD 

Office of Inspector General was examining whether the Navy adjudicative 

contracts led to contractors’ staff performing an inherently governmental 

function—adjudication. Because of that examination, it was unclear 

whether the Army and Air Force adjudication facilities would be able to use 

similar contracting to eliminate their backlogs.

Although DOD concurred with our April 200124 recommendations for 

improving its adjudicative process, it has not fully implemented any of the 

recommendations as of May 2005. OUSD(I) reported the following progress 

for those four recommendations. (Our recommendations appear in italics, 

followed by a summary of DOD’s response and/or actions.)

• Establish detailed documentation requirements to support 

adjudication decisions. Use of JPAS will require greater documentation 

on adverse information and possible factors to mitigate that 

information, but this feature of JPAS has not been fully implemented.

• Require that all DOD adjudicators use common explanatory guidance.

DOD has developed this guidance and is awaiting review by the 

Personnel Security Working Group of Policy Coordinating Committee 

for Records Access and Information Security Policy, an interagency 

group.

• Establish common adjudicator training requirements and develop 

appropriate continuing education opportunities for all DOD 

adjudicators. A work plan has been developed to establish an 

adjudicator certification process, to be implemented in late 2005 or early 

2006. The plan will include continuing education requirements.

• Establish a common quality assurance program to be implemented by 

officials in all DOD adjudication facilities and monitor compliance 

23 GAO-04-344.

24 GAO, DOD Personnel: More Consistency Needed in Determining Eligibility for Top 

Secret Security Clearances, GAO-01-465 (Washington, D.C.: Apr. 18, 2001).
Page 15 GAO-05-842T 

through annual reporting. OUSD(I) indicates DOD is developing 

criteria and a form to assess the quality of the investigations that DOD is 

receiving. Also, in the future, cases are to be randomly selected from 

JPAS and reviewed by a team of adjudicators from the various 

adjudication facilities.

Mr. Chairman and Members of the Subcommittee, this concludes my 

prepared statement. I would be happy to answer any questions you may 

have at this time. In summary, Mr. Chairman, we will continue to monitor 

this area as we do for all of the high-risk programs on our list. Much 

remains to be done to bring lasting solutions to this high-risk area. As we 

stated in our report, High-Risk Series: An Update, perseverance by the 

administration in implementing GAO’s recommended solutions and 

continued oversight and action by the Congress are both essential.
Page 16 GAO-05-842T 

Appendix I

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact Derek B. Stewart, (202) 512-5559

Acknowledgments Individuals making key contributions to this statement include Alissa H. 

Czyz, Jack E. Edwards, Julia C. Matta, and Mark A. Pross.
Page 17 GAO-05-842T 

Related GAO Products

Defense Management: Key Elements Needed to Successfully Transform 

DOD Business Operations. GAO-05-629T. Washington, D.C.: April 28, 2005.

Maritime Security: New Structures Have Improved Information Sharing, 

but Security Clearance Processing Requires Further Attention. 

GAO-05-394. Washington, D.C.: April 15, 2005.

DOD’s High-Risk Areas: Successful Business Transformation Requires 

Sound Strategic Planning and Sustained Leadership. GAO-05-520T. 

Washington, D.C.: April 13, 2005.

High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January 2005.

Intelligence Reform: Human Capital Considerations Critical to 9/11 

Commission’s Proposed Reforms. GAO-04-1084T. Washington, D.C.: 

September 14, 2004.

DOD Personnel Clearances: Additional Steps Can Be Taken to Reduce 

Backlogs and Delays in Determining Security Clearance Eligibility for 

Industry Personnel. GAO-04-632. Washington, D.C.: May 26, 2004.

DOD Personnel Clearances: Preliminary Observations Related to 

Backlogs and Delays in Determining Security Clearance Eligibility for 

Industry Personnel. GAO-04-202T. Washington, D.C.: May 6, 2004.

Security Clearances: FBI Has Enhanced Its Process for State and Local 

Law Enforcement Officials. GAO-04-596. Washington, D.C.: April 30, 2004.

Industrial Security: DOD Cannot Provide Adequate Assurances That Its 

Oversight Ensures the Protection of Classified Information. GAO-04-332. 

Washington, D.C.: March 3, 2004.

DOD Personnel Clearances: DOD Needs to Overcome Impediments 

to Eliminating Backlog and Determining Its Size. GAO-04-344. 

Washington, D.C.: February 9, 2004.

Aviation Security: Federal Air Marshal Service Is Addressing Challenges 

of Its Expanded Mission and Workforce but Additional Actions Needed. 

GAO-04-242. Washington, D.C.: November 19, 2003.
Related GAO Products

Page 18 GAO-05-842T 

DOD Personnel: More Consistency Needed in Determining Eligibility 

for Top Secret Security Clearances. GAO-01-465. Washington, D.C.: 

April 18, 2001.

DOD Personnel: More Accurate Estimate of Overdue Security Clearance 

Reinvestigation Is Needed. GAO/T-NSIAD-00-246. Washington, D.C.: 

September 20, 2000.

DOD Personnel: More Actions Needed to Address Backlog of Security 

Clearance Reinvestigations. GAO/NSIAD-00-215. Washington, D.C.: 

August 24, 2000.

DOD Personnel: Weaknesses in Security Investigation Program Are 

Being Addressed. GAO/T-NSIAD-00-148. Washington, D.C.: April 6, 2000.

DOD Personnel: Inadequate Personnel Security Investigations 

Pose National Security Risks. GAO/T-NSIAD-00-65. Washington, D.C.: 

February 16, 2000.

DOD Personnel: Inadequate Personnel Security Investigations 

Pose National Security Risks. GAO/NSIAD-00-12. Washington, D.C.: 

October 27, 1999.

Background Investigations: Program Deficiencies May Lead DEA to 

Relinquish Its Authority to OPM. GAO/GGD-99-173. Washington, D.C.: 

September 7, 1999.

Military Recruiting: New Initiatives Could Improve Criminal History 

Screening. GAO/NSIAD-99-53. Washington, D.C.: February 23, 1999.

Executive Office of the President: Procedures for Acquiring Access to and 

Safeguarding Intelligence Information. GAO/NSIAD-98-245. Washington, 

D.C.: September 30, 1998.

Privatization of OPM’s Investigations Service. GAO/GGD-96-97R. 

Washington, D.C.: August 22, 1996.

Cost Analysis: Privatizing OPM Investigations. GAO/GGD-96-121R. 

Washington, D.C.: July 5, 1996.
Related GAO Products

Page 19 GAO-05-842T 

Personnel Security: Pass and Security Clearance Data for the 

Executive Office of the President. GAO/NSIAD-96-20. Washington, D.C.: 

October 19, 1995.

Privatizing OPM Investigations: Perspectives on OPM’s Role in 

Background Investigations. GAO/T-GGD-95-185. Washington, D.C.: 

June 14, 1995.

Background Investigations: Impediments to Consolidating 

Investigations and Adjudicative Functions. GAO/NSIAD-95-101. 

Washington, D.C.: March 24, 1995.

Security Clearances: Consideration of Sexual Orientation in the 

Clearance Process. GAO/NSIAD-95-21. Washington, D.C.: March 24, 1995.

Personnel Security Investigations. GAO/NSIAD-94-135R. 

Washington, D.C.: March 4, 1994.

Nuclear Security: DOE’s Progress on Reducing Its Security Clearance 

Work Load. GAO/RCED-93-183. Washington, D.C.: August 12, 1993.

Personnel Security: Efforts by DOD and DOE to Eliminate Duplicative 

Background Investigations. GAO/RCED-93-23. Washington, D.C.: 

May 10, 1993.

Security Clearances: Due Process for Denials and Revocations by 

Defense, Energy, and State. GAO/NSIAD-92-99. Washington, D.C.: 

May 6, 1992.

DOD Special Access Programs: Administrative Due Process Not Provided 

When Access Is Denied or Revoked. GAO/NSIAD-93-162. Washington, D.C.: 

May 5, 1993.

Administrative Due Process: Denials and Revocations of Security 

Clearances and Access to Special Programs. GAO/T-NSIAD-93-14. 

Washington, D.C.: May 5, 1993.

Due Process: Procedures for Unfavorable Suitability and Security 

Clearance Actions. GAO/NSIAD-90-97FS. Washington, D.C.: April 23, 1990.

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