PERSONNEL SECURITY 

CLEARANCES

Additional Actions Needed 

to Implement Key Reforms 

and Improve Timely 

Processing of 

Investigations

Statement of Brenda S. Farrell, Director, Defense 

Capabilities and Management

Testimony 

Before the Select Committee on 

Intelligence, U.S. Senate

For Release on Delivery 

Expected at 9:30 am ET

Wednesday, March 7, 2018

GAO-18-431T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-431T, a testimony 

before the Select Committee on Intelligence, 

U.S. Senate

March 2018

PERSONNEL SECURITY CLEARANCES

Additional Actions Needed to Implement Key Reforms 

and Improve Timely Processing of Investigations

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 federal adjudicative guidelines and updated strategic documents 

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

implementing aspects of the 2012 Federal Investigative Standards—criteria for 

conducting background investigations—and in implementing a continuous 

evaluation program. 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 interagency Security, 

Suitability, and Credentialing Performance Accountability Council (PAC) have set 

a milestone for completing their establishment.

GAO’s analysis of timeliness data for specific executive branch agencies showed 

that the number of agencies meeting investigation and adjudication timeliness 

objectives for initial secret and top secret security clearances and periodic 

reinvestigations decreased from fiscal years 2012 through 2016. For example, 

while 73 percent of agencies did not meet timeliness objectives for initial 

clearances for three of four quarters in fiscal year 2012, 98 percent of agencies 

did not meet these objectives in fiscal year 2016. The DNI has not developed a 

government-wide plan, including goals and milestones, to help agencies improve

timeliness. Agencies’ challenges in meeting timeliness objectives have

contributed to a significant backlog of background investigations at the agency 

that is responsible for conducting the majority of investigations, the National

Background Investigations Bureau (NBIB). NBIB documentation shows that the

backlog of pending investigations increased from about 190,000 in August 2014 

to more than 710,000 as of February 2018, as shown below. NBIB leadership

has not developed a plan to reduce the backlog to a manageable level.

National Background Investigations Bureau’s Backlog of Background Investigations, August 

2014 to February 2018

View GAO-18-431T. For more information, 

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

farrellb@gao.gov.

Why GAO Did This Study

The government-wide personnel 

security clearance process was

designated as a high-risk area in 

January 2018 because it represents 

one of the highest management risks 

in government. 

This testimony focuses on, among 

other things, the extent to which 

executive branch agencies (1) made 

progress reforming the security 

clearance process, and (2) are meeting 

timeliness objectives and reducing

NBIB’s investigative backlog.

GAO’s statement is based on 

information from public versions of its 

reports issued in November 2017 on 

continuous evaluation of clearance 

holders and in December 2017 on 

clearance reform efforts. Information 

that ODNI and OPM deemed sensitive 

was omitted. For those reports, GAO 

reviewed Executive Orders and PAC 

strategic documents; obtained data 

from the Office of the Director of 

National Intelligence (ODNI) on the 

timeliness of initial clearances and 

periodic reinvestigations; and

interviewed officials from ODNI, NBIB, 

and other agencies.

What GAO Recommends

In November 2017 and December 

2017, GAO made 12 recommendations 

to the DNI and the Director of NBIB, 

including setting a milestone for

establishing measures for investigation 

quality, developing a plan to meet 

background investigation timeliness 

objectives, and developing a plan for

reducing the backlog. NBIB concurred 

with the recommendations. The DNI

concurred with some, but not all, of 

GAO’s recommendations. GAO 

continues to believe they are valid.
Letter

Page 1 GAO-18-431T 

Chairman Burr, Vice Chairman Warner, and Members of the Committee:

Thank you for the opportunity to be here today to discuss personnel 

security clearance reforms. The government-wide personnel security 

clearance process was designated as a high-risk area in January 2018 

because it represents one of the highest management risks in 

government. A high-quality personnel security 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 such as the September 2013 shooting at the 

Washington Navy Yard by an individual who had both access to the 

facility and a security clearance. In November and December 2017, we 

reported, among other things, that the executive branch faces challenges 

completing key reform efforts, processing security clearances, and 

reducing a significant backlog in background investigations.1

In January 2018, in light of the serious challenges facing the interagency 

Security, Suitability, and Credentialing Performance Accountability 

Council (PAC), the entity responsible for driving the implementation of 

and overseeing the reform efforts, we placed the government-wide 

personnel security clearance process on GAO’s High-Risk List. We made 

this designation out-of-cycle because it was important to call attention to 

these challenges now.2 My testimony today focuses on three of the key 

challenges that led to the high-risk designation, including: (1) the extent to 

which executive branch agencies made progress reforming the security 

clearance process; (2) the extent to which executive branch agencies are 

meeting timeliness objectives and reducing the National Background 

Investigations Bureau’s (NBIB) investigative backlog; and (3) the potential 

effects of continuous evaluation—a process to review the background of 

clearance holders and individuals in sensitive positions at any time during 

the eligibility period—on executive branch agencies.

 1

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) and Personnel Security Clearances: Additional Actions Needed to Ensure Quality, 

Address Timeliness, and Reduce Investigation Backlog, GAO-18-29 (Washington, D.C.: 

Dec. 12, 2017).

2

GAO updates the High-Risk List every 2 years near the start of each new Congress to 

help set oversight agendas. Our next update will be in 2019.

Letter
Page 2 GAO-18-431T 

My testimony is primarily based on our November and December reports 

on these topics.3 For those reports, we reviewed relevant statutes, 

Executive Orders, and PAC strategic documents; obtained data from the 

Office of the Director of National Intelligence (ODNI) on the timeliness of 

initial personnel security clearances and periodic reinvestigations for 

fiscal years 2012 through 2016 for specific executive branch agencies; 

and interviewed PAC, Office of Personnel Management (OPM), NBIB, 

ODNI, and Department of Defense (DOD) officials.4 Our November and 

December 2017 reports include a detailed explanation of our scope and

methodology. In these reports, we made 12 recommendations to the 

Director of National Intelligence and the Director of NBIB, some of which I 

will discuss today. NBIB concurred with the recommendations. The 

Director of National Intelligence concurred with some, but not all, of our

recommendations. We continue to believe these recommendations are 

valid. Information that ODNI and OPM deemed sensitive was omitted. We 

conducted the work on which this statement is based in accordance with 

generally accepted government auditing standards.

 3

GAO-18-117 and GAO-18-29.

4

For this statement, we followed up with OMB and NBIB officials to obtain updated 

backlog data and other key performance indicators.
Page 3 GAO-18-431T 

The PAC has made progress in reforming the personnel security 

clearance process and implementing various security clearance reform 

initiatives. For example, the PAC has taken action on 73 percent of the 

recommendations of a February 2014 review conducted in the wake of 

the Washington Navy Yard shooting.5 Actions in response to these 

recommendations included ODNI and OPM jointly issuing Quality 

Assessment Standards in January 2015, which establish federal 

guidelines for assessing the quality of investigations. Additionally, ODNI 

developed the Quality Assessment Reporting Tool, through which 

agencies will report on the completeness of investigations.

Similarly, the PAC reported quarterly on the status and progress of key 

initiatives, as part of the Insider Threat and Security Clearance Reform 

cross-agency priority goal.6 This reporting included the milestone due 

date and status for each initiative.7 According to PAC Program 

Management Office officials, although the data are no longer publicly 

 5

Office of Management and Budget, February 2014 Suitability and security Processes 

Review—Report to the President (February 2014).

6

The PAC reports began in the second quarter of fiscal year 2014 and continued through 

the end of fiscal year 2016.

7

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

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

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

presidential transition. As of August 2017, it was undergoing revision as agencies 

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

budget submission to Congress. As of February 2018, the PAC is not reporting on the 

status of the reform effort via performance.gov.

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 4 GAO-18-431T 

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

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

complete as of the third quarter of fiscal year 2017.

Additionally, the PAC has issued three documents that serve as its 

updated strategic framework for the next 5 years. 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. According to PAC program management officials, the third 

document—PAC Strategic Intent and Enterprise IT Strategy 

Implementation Plan—was distributed to executive branch agencies in 

February 2017.8 Further, we reported in December 2017 that PAC 

members noted additional progress in reforming the personnel security 

clearance process, such as the development of Security Executive Agent 

Directives, the identification of executive branch—wide IT shared service 

capabilities, and the standardization of adjudicative criteria.

Although the PAC has reformed many parts of the personnel security 

clearance process, the implementation of certain key initiatives, including 

the full implementation of the 2012 Federal Investigative Standards and 

the development of government-wide performance measures for the 

quality of investigations, remain incomplete. The Federal Investigative 

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.9

However, the standards also changed the frequency of periodic 

reinvestigations for certain clearance holders and include continuous 

evaluation as a new requirement for certain clearance holders. 

 8

Security, 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).

9

In 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.

Long-Standing Key 

Reform Initiatives Remain 

Incomplete
Page 5 GAO-18-431T 

Continuous evaluation is a key executive branch initiative to more 

frequently identify and assess security-relevant information, such as 

criminal activity, between periodic reinvestigations. 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. Continuous 

evaluation involves automated record checks conducted on a more 

frequent basis, whereas periodic reinvestigations are conducted less 

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

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

are the same as those checked for other personnel security purposes. 

Security-relevant information discovered in the course of continuous 

evaluation is to be investigated and adjudicated under the existing 

standards.

Efforts to implement an executive branch continuous evaluation program 

go back to at least 2008, with a milestone for full implementation by the 

fourth quarter of fiscal year 2010. In November 2017, we reported that 

while ODNI has taken an initial step to implement continuous evaluation 

in a phased approach across the executive branch, it had not determined 

when the future phases of implementation will occur. We recommended, 

among other things, that the Director of National Intelligence develop an 

implementation plan. ODNI generally concurred with that 

recommendation.10

Regarding government-wide measures for the quality of background 

investigations, as noted earlier, ODNI and OPM issued the Quality 

Assessment Standards and ODNI issued the Quality Assessment 

Reporting Tool. The Quality Assessment Standards established federal 

guidelines for assessing the quality of investigations. The Quality 

Assessment Reporting Tool is a tool through which agencies will report 

on the completeness of investigations. However, measures for quality 

have not been developed, and it is unclear when this key effort will be 

completed. The original milestone for completing government-wide 

measures was fiscal year 2010, and no new milestone has been 

established. In our December 2017 report, we recommended that the 

Director of National Intelligence, in his capacity as the Security Executive 

Agent, and in coordination with the other PAC Principals, establish a 

milestone for the completion of government-wide performance measures 

 10GAO-18-117.
Page 6 GAO-18-431T 

for the quality of investigations. ODNI disagreed with the 

recommendation, stating that it is premature to establish such a milestone 

and that it will do so once the Quality Assessment Reporting Tool metrics 

have been fully analyzed. We continue to believe that setting a milestone, 

which takes into consideration the amount of time needed to analyze 

Quality Assessment Reporting Tool data, will help to ensure that the 

analysis of the data is completed, initial performance measures are 

developed, and agencies have a greater understanding of what they are 

being measured against.

Our analysis of government-wide and agency-specific data shows a 

decline in the number of executive branch agencies meeting the 

timeliness objectives for processing clearances. 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. Additionally, the backlog of 

background investigations conducted by NBIB—the primary entity 

responsible for conducting background investigations—has steadily 

increased since 2014 and as of February 2018 exceeds 710,000 cases. 

NBIB personnel are attempting to decrease the backlog by making the 

background investigation process more effective and efficient and 

increasing investigator capacity. However, NBIB faces challenges in 

developing a plan to reduce the size of the investigation backlog to a 

manageable level.

Our analysis showed that the percentage of executive branch agencies 

meeting timeliness objectives for investigations and adjudications 

decreased from fiscal years 2012 through 2016. The Intelligence Reform 

and Terrorism Prevention Act of 2004 (IRTPA)11 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. The objective includes

no longer than 40 days to complete the investigative phase and 20 days 

 11Pub. 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 statement pertain solely to section 3001, unless otherwise specified.

Agencies Meeting 

Timeliness Objectives 

for Clearances 

Decreased, and a 

Government-Wide 

Approach Has Not 

Been Developed to 

Improve Timeliness or 

Address the Backlog

Agencies Meeting 

Timeliness Objectives 

Decreased
Page 7 GAO-18-431T 

to complete the adjudicative phase.12 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).

13

As part of the Insider Threat and Security Clearance Reform crossagency priority goal, 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 and periodic 

reinvestigations for the executive branch as a whole from fiscal year 2014 

through 2016.

14 For fiscal year 2016, the PAC reported that the 

government-wide average for executive branch agencies15

• 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;

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

periodic reinvestigations within 150 days for the fastest 90 percent of 

cases for any quarter; the averages ranged from 175 days to 192 

days; and

 12Specifically, 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 time

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

3341(g)).

13In 2012, ODNI, in coordination with interagency participation, modified the timeliness 

goals for certain background investigations.

14However, the timeliness goals on which the PAC currently reports for periodic 

reinvestigations are the same as those identified in a 2008 report that included 

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: 195 days to complete the endto-end processing of the periodic reinvestigations. Joint Security and Suitability Reform 

Team, Security and Suitability Process Reform (December 2008).

15Of the agencies we reviewed, we found that agencies that use NBIB as their 

investigative service provider and agencies with delegated authority to conduct their own 

investigations both experienced challenges in meeting established timeliness goals. Data 

provided by ODNI identified the agencies with delegated authority to conduct their own 

investigations.
Page 8 GAO-18-431T 

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

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

the averages ranged from 209 days to 227 days.

Our analysis of timeliness data for specific executive branch agencies 

showed that the percentage of agencies meeting established 

investigation and adjudication timeliness objectives for initial secret and 

top secret personnel security clearances and periodic reinvestigations 

decreased from fiscal year 2012 through 2016. We found that agencies 

with delegated authority to conduct their own investigations and those 

that use NBIB as their investigative provider experienced challenges in 

meeting established investigative timeliness objectives. Specifically, in 

fiscal year 2012, we found that

• 73 percent of the agencies, for which we obtained data, did not meet 

investigation and adjudication objectives for at least three of four 

quarters for initial secret clearances,

• 41 percent did not meet those objectives for initial top secret 

clearances, and

• 16 percent did not meet the investigative goal for at least three of four 

quarters for the fastest 90 percent of periodic reinvestigations.

By fiscal year 2016, the percentage of agencies that did not meet these 

same objectives had increased to 98 percent, 90 percent, and 82 percent, 

respectively.

Furthermore, ODNI requests individual corrective action plans from 

agencies not meeting security clearance timeliness objectives. However, 

the executive branch has not developed a government-wide plan, with 

goals and interim milestones, to meet established timeliness objectives 

for initial security clearances that takes into consideration increased 

investigative requirements and other stated challenges. In our December 

2017 report, we recommended that the Director of National Intelligence, 

as Security Executive Agent, develop a government-wide plan, including 

goals and interim milestones, to meet timeliness objectives for initial 

personnel security clearance investigations and adjudications. Although 

the DNI did not specifically comment on this recommendation, we 

continue to believe a government-wide plan would better position ODNI to 

identify and address any systemic government-wide issues.

We also recommended that the Director of National Intelligence conduct 

an evidence-based review of the investigation and adjudication timeliness 

objectives and take action to adjust the objectives if appropriate. He did 
Page 9 GAO-18-431T 

not agree with this recommendation and stated that it is premature to 

revise the existing timeliness goals until NBIB’s backlog is resolved. We 

continue to believe that our recommendation to conduct an evidencebased review, using relevant data, is valid. As we noted in our report, 

even agencies with delegated authority to conduct their own 

investigations are experiencing challenges meeting established timeliness 

objectives. We also noted that ODNI has not comprehensively revisited 

the investigation or adjudication timeliness objectives for initial security 

stemming from the implementation of the 2012 Federal Investigative 

Standards.

The executive branch’s challenges in meeting investigation timeliness 

objectives for initial personnel security clearances and periodic 

reinvestigations have contributed to a significant backlog of background 

investigations at the primary entity responsible for conducting background 

investigations, NBIB. 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. 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. In December 2017, we recommended that the 

Director of NBIB develop a plan, including goals and milestones, that 

includes a determination of the effect of the business process 

reengineering efforts on reducing the backlog to a “healthy” inventory of 

work, representing approximately 6 weeks of work. NBIB concurred with 

this recommendation.

NBIB documentation shows that the backlog of pending investigations 

increased from about 190,000 in August 2014 to more than 710,000 as of 

February 2018, as shown in figure 1. NBIB’s Key Performance Indicators 

report states that a “healthy” inventory of work is around 180,000 pending 

investigations, representing approximately 6 weeks of work, and would 

allow NBIB to meet timeliness objectives.

Backlog of Background 

Investigations Has 

Steadily Increased since 

2014
Page 10 GAO-18-431T 

Figure 1: National Background Investigations Bureau’s Backlog of Background 

Investigations, August 2014 to February 2018

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.

While NBIB has taken steps to increase its capacity to conduct 

background investigations by increasing its own investigator staff as well 

as awarding new contracts, in our December 2017 report we noted that 

NBIB officials have assessed four scenarios, from the status quo—

assuming no additional contractor or federal investigator hires—to an 
Page 11 GAO-18-431T 

aggressive contractor staffing plan beyond January 2018.16 The two 

scenarios that NBIB identified as most feasible would not result in a 

“healthy” inventory level until fiscal year 2022 at the earliest. In our 

December 2017 report, we recommended that the Director of NBIB

establish goals for increasing total investigator capacity—federal 

employees and contractor personnel—in accordance with the plan for 

reducing the backlog of investigations, as noted above. NBIB concurred 

with this recommendation.

We reported in November 2017 that the potential effects of continuous 

evaluation on executive branch agencies are unknown because future 

phases of the program and the effect on agency resources have not yet 

been determined.17 ODNI has not yet determined key aspects of its 

continuous evaluation program, which has limited the ability of executive 

branch agencies to plan for implementation in accordance with ODNI’s 

phased approach. For example, while ODNI has initiated the first phase 

of continuous evaluation in coordination with implementing executive 

branch agencies, it has not yet determined what the future phases of 

implementation will entail, or when they will occur. As we reported in 

November 2017, the uncertainty regarding the requirements and time

frames for the future phases of the program has affected the ability of 

executive branch agencies to plan to implement continuous evaluation 

and estimate the associated costs.

Although executive branch agencies have identified increased resources 

as a risk associated with implementing continuous evaluation, and ODNI 

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

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

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

implementing agencies, to address such effects, including modifying the 

scope or frequency of periodic reinvestigations or replacing periodic 

reinvestigations for certain clearance holders.

Moreover, the potential effect of continuous evaluation on periodic 

reinvestigations is unknown. Executive branch agencies have expressed 

varying views about potential changes to the periodic reinvestigation 

model:

 16GAO-18-29.

17GAO-18-117.

The Potential Effects 

of Continuous 

Evaluation on 

Executive Branch 

Agencies Are 

Unknown
Page 12 GAO-18-431T 

• DOD officials stated that with workload and funding issues, they see 

no alternative but to replace periodic reinvestigations for certain 

clearance holders with continuous evaluation, as the record checks 

conducted are the same for both processes.

• State Department officials expressed concerns that relevant 

information, such as state and local law-enforcement records that are 

not yet automated, would be missed if it did not conduct periodic 

reinvestigations.

• State Department officials, along with officials from the Departments 

of Justice and Homeland Security, stated it may be possible to 

change the frequency or scope of periodic reinvestigations at some 

point in the future.

• The Security Executive Agent Directive for continuous evaluation, 

issued since our report, clarified that continuous evaluation is 

intended to supplement but not replace periodic reinvestigations.

In our November 2017 report, ODNI officials stated that ODNI is not 

opposed to further improving the security clearance process, and that 

once continuous evaluation is operational, it plans to determine the 

efficiencies and mitigation of risks associated with the approach. 

Specifically, these officials stated that once continuous evaluation is 

further implemented and ODNI has gathered sufficient data—which they 

estimated would take about a year from May 2017—they can perform 

analysis and research to determine whether any changes are needed to 

the periodic reinvestigation model.

We recommended that the Director of National Intelligence 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. ODNI generally concurred 

with this recommendation. 

Finally, the National Defense Authorization Act for Fiscal Year 2018, 

enacted in December 2017, will have a significant impact on the 

personnel security clearance process. Among other things, the act 

authorized DOD to conduct its own background investigations and 
Page 13 GAO-18-431T 

requires DOD to begin carrying out a related implementation plan by 

October 1, 2020.18 It also requires the Secretary of Defense, in 

consultation with the Director of OPM, to provide for a phased transition.19

These changes could potentially affect timeliness, the backlog, and other 

reform initiatives but the effect is unknown at this time. DOD’s 

investigations represent the majority of the background investigations 

conducted by NBIB.

Chairman Burr, Vice Chairman Warner and Members of the committee, 

this concludes my prepared testimony. I look forward to answering any 

questions.

If you or your staff have any questions about this testimony, please 

contact Brenda S. Farrell at (202) 512-3604 or at farrellb@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this testimony. GAO staff who 

made key contributions to this testimony are Kimberly Seay (Assistant 

Director), James Krustapentus, Michael Shaughnessy, and John Van 

Schaik.

 18See Pub. L. No. 115-91, § 925(a), (b) (2017). Section 925(b) requires DOD to begin 

carrying out the implementation plan developed in response to section 951(a)(1) of the 

National Defense Authorization Act for Fiscal Year 2017, Pub. L. No. 114-328 (2016).

19§ 925(a)(2).

GAO Contact and 

Staff 

Acknowledgements

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