GAO-06-323R DOD Security Clearances 

United States Government Accountability Office

Washington, DC 20548 

January 17, 2006 

The Honorable George V. Voinovich 

Chairman 

The Honorable Daniel K. Akaka 

Ranking Minority Member 

Subcommittee on Oversight of Government Management, 

 the Federal Workforce, and the District of Columbia 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

Subject: Questions for the Record Related to DOD’s Personnel Security Clearance 

Program and the Government Plan for Improving the Clearance Process 

On November 9, 2005, I testified before your subcommittee at a hearing on “Access 

Delayed: Fixing the Security Clearance Process, Part II.” This letter responds to three 

questions for the record that Senator Daniel K. Akaka posed. The questions and my 

responses follow.

1. The Government Accountability Office (GAO) in testimony before this 

Subcommittee in September 2004 and June 2005, indicated that the Office 

of Personnel Management (OPM) continues to use its investigations 

contractor to conduct personnel security clearance investigations for the 

contractor’s employees even though GAO raised an internal control 

concern about this practice during its 1996 review. Would you please 

elaborate on these concerns, and describe whether you believe OPM has 

taken sufficient steps to addressing the internal control and qualitycontrol problems identified by GAO? 

Although we have evidence that OPM has not taken steps to correct the cited internal 

control weakness that we identified nearly a decade ago, conclusions about the 

sufficiency of OPM’s specific quality control procedures must wait until we complete 

other work requested by this subcommittee and others. When OPM was privatizing its 

investigative function in 1996, we identified an internal control concern—OPM’s 

investigations contractor was conducting personnel security clearance investigations 
on its own employees.1

The February 2005 transfer of the Department of Defense’s 

(DOD) federal investigators to OPM resulted in OPM again having federal 

investigators available to correct this internal control weakness, but OPM has not yet 

used the federal investigators for that purpose.

2

 OPM officials have, however, 

indicated that they plan to have the federal investigators perform the personnel 

security clearance investigations of contract investigators starting in March 2006. If 

OPM follows through with this plan, it would correct the cited internal control 

weakness.

We have begun work requested by this subcommittee and others to obtain up-to-date 

information on the sufficiency of the specific procedures that OPM uses to monitor 

the quality of the investigative reports that it provides to its customers. Our 

examination of quality control procedures will include observing the training that 

investigators receive, conducting a site visit to OPM’s investigations processing

center to review the step-by-step process used to monitor quality, and reviewing a 

sample of the investigative reports that DOD adjudication facilities have used to 

determine eligibility for a security clearance.

2. Does GAO have a position on the use and measurement of timeliness for 

closed-pending investigative reports? 

In our February 2004 report, we noted that OPM’s issuance of closed pending cases—

investigations sent to adjudication facilities without one or more types of source 

data—causes ambiguity in defining and accurately estimating the backlog.3

In our 

October 1999 report examining the completeness of clearance investigations supplied 

by DOD’s Defense Security Service, we noted that risks to national security are posed 

when investigations do not fully comply with federal standards. To lessen the risk 

associated with incomplete investigative reports, we recommended DOD 

adjudication facility officials grant clearances only when all essential investigative 

work has been done. Adjudication facility officials said that they were reluctant to 

return incomplete investigations for further investigation because they were 

concerned about additional delays.

4

In fiscal year 2002 (the last year for which we have data), about 10 percent of the 

283,480 DOD cases fully closed by OPM were initially delivered to DOD adjudication 

facilities as closed pending cases. When measuring the timeliness of its contractors’ 

performance, OPM defined completed investigations as cases that (1) have the 

complete information required for the type of investigation, (2) are closed pending, or 

(3) have been discontinued. If the investigations have not been fully completed, we 

 1

See GAO, Privatization of OPM’s Investigations Service, GAO/GGD-96-97R (Washington, D.C.: Aug.

22, 1996). 2

According to OPM officials, these federal investigators are currently being used to help reduce the 

existing backlog of DOD security clearance investigations. 3

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). 4

GAO, DOD Personnel: Inadequate Personnel Security Investigations Pose National Security Risks, 

GAO/NSIAD-00-12 (Washington, D.C.: Oct. 27, 1999). 

Page 2 GAO-06-323R DOD Security Clearances 
believe that closed pending cases should be included in the investigative portion of 

the backlog.

3. What are some of the primary criteria that GAO uses to determine 

whether or not to remove a program from its high-risk list, and what is 

needed for security clearances to be off the list?

In order for DOD’s personnel security clearance program to be removed from our 

high-risk list, the program must address (1) the general criteria outlined in our fiscal 

year 2001 report and (2) the many recommendations that we have provided specific 

to DOD’s program. In our 2001 report, we identified the following general criteria that 

are considered in designating and removing programs from our high-risk list:5

 

• a demonstrated strong commitment and top leadership support to address the 

risk(s); 

• the capacity (that is, the people and other resources) to resolve the risk(s); 

• a corrective action plan that defines the root causes, identifies effective solutions, 

and provides for substantially completing corrective measures in the near term, 

including but not limited to steps necessary to implement solutions we have 

recommended; 

• a program instituted to monitor and independently validate the effectiveness and 

sustainability of corrective measures; and 

• the ability to demonstrate progress in having implemented corrective measures. 

Before removing the security clearance process from our high-risk list, we must 

determine whether DOD has satisfied all of the criteria we have established for 

removing a high-risk designation. As noted in our November 2005 testimony,6

 DOD 

must undertake many corrective actions to implement our recommendations and to 

correct previously identified problems before its personnel security clearance 

program can be removed from our high-risk list. Perseverance by the administration 

in implementing our recommended solutions regarding the personnel security 

clearance process and continued oversight and action by Congress are both essential.

When actions, including those in response to our recommendations, result in 

significant progress toward resolving a high-risk problem, we will remove the highrisk designation. 

 5

GAO, Determining Performance and Accountability Challenges and High Risks, GAO-01-159SP 

(Washington, D.C.: November 2000). 6

GAO, DOD Personnel Clearances: Government Plan Addresses Some Long-standing Problems with 

DOD’s Program, But Concerns Remain, GAO-06-233T (Washington, D.C.: Nov. 9, 2005). 

Page 3 GAO-06-323R DOD Security Clearances 
If you or other members of the subcommittee have any additional questions about 

DOD’s personnel security program, please contact me at (202) 512-5559 or 

stewartd@gao.gov. Contact points for our Offices of Congressional Relations and 

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

made major contributions to the correspondence are listed in the enclosure.

Sincerely yours, 

Derek B. Stewart 

Director, Defense Capabilities and Management 

Enclosure

Page 4 GAO-06-323R DOD Security Clearances 
Enclosure 

GAO Contact and Staff Acknowledgments

GAO Contact Derek B. Stewart, (202) 512-5559 or stewartd@gao.gov

Acknowledgments In addition to the contact above, Jack E. Edwards, Assistant 

Director, Kurt A. Burgeson, David Epstein, Sara Hackley, 

William J. Rigazio, and Jennifer Young made key contributions 

to this correspondence.

(350796)

Page 5 GAO-06-323R DOD Security Clearances 
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