Report to the Ranking Minority 

Member, Committee on Armed 

Services, House of Representatives 

United States General Accounting Office 

GAO 

February 2004 DOD PERSONNEL 

CLEARANCES 

DOD Needs to 

Overcome 

Impediments to 

Eliminating Backlog 

and Determining Its 

Size 

GAO-04-344 
www.gao.gov/cgi-bin/getrpt?GAO-04-344.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Derek Stewart, 

(202) 512-5559, stewartd@gao.gov. 

Highlights of GAO-04-344, a report to the 

Ranking Minority Member, Committee on 

Armed Services, House of 

Representatives 

February 2004

DOD PERSONNEL CLEARANCES 

DOD Needs to Overcome Impediments 

to Eliminating Backlog and Determining 

Its Size 

DOD did not know the size of its security clearance backlog at the end of 

September 2003 and has not estimated the size of the backlog since 

January 2000. DOD cannot estimate the size of its backlog of overdue 

reinvestigations that have not been submitted for renewal, but prior 

estimates of this portion of the backlog suggest it was sizeable. Using 

September 2003 data from DSS, OPM, and nine adjudication facilities, GAO 

calculated the size of investigative and adjudicative portions of the backlog 

at roughly 270,000 and 90,000 cases, respectively. Because these estimates 

were made using time-based goals that varied from agency to agency, the 

actual backlog size is uncertain. 

Several impediments hinder DOD’s ability to eliminate—and accurately 

estimate the size of—its clearance backlog. Four major impediments slowing 

the elimination of the backlog are (1) the large numbers of new clearance 

requests; (2) the insufficient investigator and adjudicator workforces; 

(3) the size of the existing backlog; and (4) the lack of a strategic plan for 

overcoming problems in gaining access to state, local, and overseas 

information needed to complete investigations. Two other factors have 

hampered DOD’s ability to develop accurate estimates of the backlog size. 

DOD has failed to provide adequate oversight of its clearance program, 

including developing DOD-wide backlog definitions and measures and using 

the measures to assess the backlog regularly. In addition, delays in 

implementing its Joint Personnel Adjudication System have limited DOD’s 

ability to monitor backlog size and track when periodic reinvestigations 

are due. 

DOD’s failure to eliminate and accurately assess the size of the backlog may 

have adverse effects. Delays in updating overdue clearances for command, 

agency, and industry personnel who are doing classified work may increase 

risks to national security. Slowness in issuing new clearances can increase 

the costs of doing classified government work. Finally, DOD’s inability to 

accurately define and measure the backlog and project future clearance 

requests that it expects to receive can adversely affect its ability to develop 

accurate budgetary and staffing plans. 

In December 2003, advisors to OPM’s Director recommended that the 

authorized transfer of DOD’s investigative functions and personnel to 

OPM should not occur for at least the rest of fiscal year 2004. That 

recommendation was based on uncertainties over financial risks that OPM 

might incur. An alternative plan being discussed by DOD and OPM calls for 

leaving investigative staff in DSS and giving them training for, and access 

to, OPM’s case management system. A DOD official estimated that using 

the OPM system, instead of DOD’s current system, would avoid about 

$100 million in update and maintenance costs during the next 5 years. 

Also, as of December 16, 2003, the Secretary of Defense had not provided 

Congress with certifications required prior to any transfer. 

Terrorist attacks and espionage 

cases have heightened national 

security concerns and highlighted 

the need for a timely, high-quality 

personnel security clearance 

process. However, GAO’s past 

work found that the Department of 

Defense (DOD) had a clearance 

backlog and other problems with 

its process. GAO was asked to 

address: (1) What is the size of 

DOD’s security clearance backlog, 

and how accurately is DOD able to 

estimate its size? (2) What factors 

impede DOD’s ability to eliminate 

the backlog and accurately 

determine its size? (3) What are the 

potential adverse effects of those 

impediments to eliminating DOD’s 

backlog and accurately estimating 

the backlog’s size? GAO was also 

asked to determine the status of 

the congressionally authorized 

transfer of Defense Security 

Service (DSS) investigative 

functions and personnel to the 

Office of Personnel Management 

(OPM). 

GAO recommends that DOD 

improve its personnel security 

clearance program’s management 

and oversight by matching 

workforce sizes to workloads; 

developing a strategic plan to 

overcome access to information 

problems; developing DOD-wide 

backlog definitions, measures, and 

reports; and completing work on 

the Joint Personnel Adjudication 

System. DOD concurred with three 

recommendations and partially 

concurred with one. 
Page i GAO-04-344 DOD Personnel Clearances 

Letter 1

Results in Brief 4

Background 6

DOD Unable to Estimate the Size of Its Clearance Backlog 8

Multiple Impediments Slow DOD’s Progress in Eliminating Its 

Backlog and Generating Accurate Backlog Estimates 13

Backlogs and Poor Estimates May Lead to Increased National 

Security Risks, Higher Costs, and Workload Uncertainties 22

Status Update on the Authorized Transfer of DSS Investigative 

Functions and Personnel to OPM 24

Conclusions 26

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 28

Appendix I Recent Recommendations Related to DOD’s 

Personnel Security Clearance Process 30 

Appendix II Scope and Methodology 36 

Appendix III Comments from the Department of Defense 39 

Appendix IV Related GAO Products 43 

Tables 

Table 1: Adjudicative Backlog Present at Each Central 

Adjudication Facility, as of September 30, 2003 12

Table 2: Targeted and Actual Numbers of Requests Submitted to 

DSS and OPM during Fiscal Years 2001-2003 15

Contents 
Page ii GAO-04-344 DOD Personnel Clearances 

Figures 

Figure 1: DOD’s Personnel Security Clearance Process 7

Figure 2: Estimated Backlog Size at Each Stage in the Personnel 

Security Clearance Process, as of September 2003 9

Abbreviations 

DOD Department of Defense 

DSS Defense Security Service 

JPAS Joint Personnel Adjudication System 

OPM Office of Personnel Management 

OASD (C3I) Office of the Assistant Secretary of Defense for Command, 

 Control, Communications, and Intelligence 

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

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Page 1 GAO-04-344 DOD Personnel Clearances 

February 9, 2004 

The Honorable Ike Skelton 

Ranking Minority Member 

Committee on Armed Services 

House of Representatives 

Dear Mr. Skelton: 

Recent events, such as the terrorist attacks on the United States on 

September 11, 2001, and several high-profile espionage cases have 

heightened national security concerns and underscored the need for a 

timely, high-quality personnel security clearance process. Each year, the 

Department of Defense (DOD) processes hundreds of thousands of 

security clearance requests for service members, government employees, 

and industry personnel who are conducting classified work for the 

department and other government agencies. These requests include 

(1) periodic reinvestigations for individuals who already hold security 

clearances or initial investigations for individuals who have not held 

security clearances in the past and (2) adjudications to determine whether 

or not individuals are eligible for clearances, based on information 

collected during the investigations and reinvestigations. 

Historically, DOD’s Defense Security Service (DSS) had conducted almost 

all of the department’s security clearance investigations. In 1999, however, 

DOD contracted with the Office of Personnel Management (OPM), and 

later with private-sector investigative firms, to process large numbers of 

new investigations and reinvestigations. Using information from the 

investigations, DOD’s 10 central adjudication facilities provide the 

eligibility-for-clearance determinations. 

Since at least the late 1990s, the timeliness of DOD’s personnel security 

clearance process has been at issue. In our October 1999 report,1

 for 

example, we identified serious problems with the adequacy of DOD’s 

investigations; this work prompted the department to declare its 

 1

 U.S. General Accounting Office, DOD Personnel: Inadequate Personnel Security 

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

Oct. 27, 1999). 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-04-344 DOD Personnel Clearances 

investigative function a systemic weakness2 under the Federal Managers’ 

Financial Integrity Act of 1982.3

 In our August 2000 report, we noted 

that DOD estimated it had a backlog of more than 500,000 overdue 

reinvestigations that had not yet been submitted for renewal and found 

that DOD had no established method for monitoring or estimating the total 

number of periodic reinvestigations that were overdue but not submitted.4

Moreover, in our 2001 report, we found that DOD’s adjudicators did not 

consistently document adverse security conditions, and we identified 

other factors that hindered the effectiveness of the adjudication process.5

Along with our reviews, several reports issued in 2000 and 2001 by the 

DOD Office of the Inspector General have also documented problems with 

various aspects of the security clearance process.6

 In agency comments to 

GAO and DOD Office of Inspector General recommendations (see app. I 

for recommendations), DOD identified many actions it had taken or 

planned to take to address problems in its investigative and adjudicative 

processes. For example, in response to a recommendation in our August 

2000 report, DOD noted that the Joint Personnel Adjudication System 

 2

 In DOD’s Annual Statement of Assurance, FY 1999 Volume I, DOD stated that “[i]n the 

upcoming annual assurance statement, Defense Security Service (DSS) will identify the 

Personnel Security Investigations Program as being a material weakness and will provide 

an action plan that addresses corrective actions needed to bring the program back into 

compliance with performance expectations and with existing security policies.” However, 

in both the fiscal year 2000 and 2001 Annual Statement of Assurance, the personnel 

security investigations program was listed as a systemic weakness. According to the fiscal 

year 2001 Statement of Assurance, “Material weaknesses are management control 

problems that affect only one Component and do not significantly impact mission 

accomplishment. Systemic weaknesses are management control problems that affect more 

that one DOD Component and may jeopardize the Department’s operations.” Department 

of Defense, Annual Statement of Assurance, Vol. I (Washington, D.C.: 1999). 

3

 Pub. L. 97-255 (Sept. 8, 1982). 

4

 U.S. General Accounting Office, DOD Personnel: More Actions Needed to Address 

Backlog of Security Clearance Reinvestigations, GAO/NSIAD-00-215 (Washington, D.C.: 

Aug. 24, 2000). 

5

 U.S. General Accounting Office, DOD Personnel: More Consistency Needed in 

Determining Eligibility for Top Secret Security Clearances, GAO-01-465 (Washington, 

D.C.: Apr. 18, 2001). 

6

 Department of Defense, Office of Inspector General Audit Report, Program Management 

of the Defense Security Service Case Control Management System, Report No. D-2001-019 

(Arlington, Va.: Dec. 15, 2000); Department of Defense, Office of Inspector General Audit 

Report, Acquisition Management of the Joint Personnel Adjudication System, Report No. 

D-2001-112 (Arlington, Va.: May 5, 2001); and Department of Defense, Office of Inspector 

General Audit Report, Security Clearance Investigative Priorities, Report No. D-2000-111 

(Arlington, Va.: Apr. 5, 2000). 
Page 3 GAO-04-344 DOD Personnel Clearances 

(JPAS) would be implemented in fiscal year 2001 and would provide an 

automated means of tracking and counting overdue but-not-submitted 

requests for reinvestigation. 

More recently, the National Defense Authorization Act for Fiscal Year 2004 

authorized the transfer of DOD’s personnel security investigative functions 

and 1,855 investigative employees to OPM.7

 Under the Act, a transfer of 

functions can only be made after the Secretary of Defense certifies that 

certain conditions can be met and that the Director of OPM concurs with 

the authorized transfer. Among the conditions requiring Secretary of 

Defense certification are “[t]hat the Office of Personnel Management is 

fully capable of carrying out high-priority investigations required by the 

Secretary of Defense within a timeframe set by the Secretary of Defense” 

and “[t]hat the Office of Personnel Management has undertaken necessary 

and satisfactory steps to ensure that investigations performed on 

Department of Defense contract personnel will be conducted in an 

expeditious manner sufficient to ensure that those contract personnel are 

available to the Department of Defense within the timeframe set by the 

Secretary of Defense.” 

You asked us to conduct a follow-up review of DOD’s personnel security 

process. As agreed with your office, this report addresses three questions: 

(1) What is the size of DOD’s security clearance backlog, and how 

accurately is DOD able to estimate its size? (2) What factors impede DOD’s 

ability to eliminate the backlog and accurately determine its size? (3) What 

are the potential adverse effects of those impediments to eliminating 

DOD’s backlog and accurately estimating the backlog’s size? In addition to 

answering these three questions, you asked us to determine the status of 

the congressionally authorized transfer of DSS investigative functions and 

personnel to OPM. 

To conduct our work, we reviewed DOD and OPM regulations, 

instructions, policy guidance, and available empirical data and procedural 

information on the personnel security clearance process. In addition, we 

obtained information during meetings with DOD, OPM, and other officials 

who are responsible for the oversight, investigative, and adjudicative 

functions of the personnel security clearance process. We also referred to 

prior GAO, DOD Office of Inspector General, and congressional reports. 

We conducted our work from February through December 2003 in 

 7

 Pub. L. 108-136 § 906 (Nov. 24, 2003). 
Page 4 GAO-04-344 DOD Personnel Clearances 

accordance with generally accepted government auditing standards. 

Additional information on our scope and methodology is presented in 

appendix II. 

DOD did not know the size of its security clearance backlog at the end of 

September 2003 and has not estimated the size of the backlog since 

January 2000. DOD cannot estimate the size of its backlog of overdue 

reinvestigations that have not yet been submitted for renewal, but prior 

estimates of this portion of the backlog have been sizeable. For example, 

we noted in our 2000 report that DOD estimated its number of overduebut-not-submitted reinvestigations at 300,000 cases in 1986 and at 500,000 

cases in 2000. Based on September 2003 data that we obtained from DSS, 

OPM, and adjudication facilities, we estimated the potential size of DOD’s 

investigative and adjudicative backlogs to be roughly 270,000 and 90,000 

cases, respectively. Because these estimates were developed using time 

limits for completing investigations or adjudications that varied from 

agency to agency, uncertainty is present regarding the actual size of the 

backlog. 

A number of impediments hinder DOD’s ability to eliminate its security 

clearance backlog and accurately estimate the size of the backlog. Four 

major impediments have slowed DOD’s progress in eliminating the 

backlog. (1) The large number of new requests for clearances has 

hampered DOD’s efforts to draw down the number of cases already in 

DOD’s current backlog. (2) The sizes of the investigator and adjudicator 

workforces have not been sufficient to eliminate the backlog, even though 

DOD has taken steps to increase the number of requests that can be 

processed. For example, according to an OPM official, roughly 8,000 

full-time-equivalent investigative personnel are needed to eliminate the 

backlog, but our calculations showed that DOD and OPM have around 

4,200 full-time-equivalent government and contract investigative staff as of 

December 2003. (3) The mere size of the existing backlog has prevented 

the timely processing and completion of new requests for clearances. 

(4) The lack of a strategic plan for overcoming problems in gaining access 

to state, local, and overseas information has slowed the completion of 

investigations and thereby has impeded the reduction of the backlog. In 

addition, two other factors have hampered DOD’s ability to develop 

accurate estimates of the backlog. DOD has failed to provide adequate 

oversight for the security clearance program, including developing 

DOD-wide definitions and measures of the backlog and using the measures 

to assess the backlog regularly. In addition, delays in implementing JPAS 

Results in Brief 
Page 5 GAO-04-344 DOD Personnel Clearances 

have limited DOD’s ability to, among other things, monitor backlog size 

and track when periodic reinvestigations are due. 

DOD’s failure to eliminate its large security clearance backlog and to 

accurately estimate the size of the backlog may have adverse effects. For 

example, delays in updating overdue clearances for command, agency, and 

industry personnel performing classified government work may increase 

risks to national security. Similarly, delays in issuing initial clearances 

caused by the backlog and other impediments can increase the costs of 

doing classified government work. In addition, DOD’s inability to 

accurately define and measure the backlog and project the number of 

future clearance requests it expects to receive can adversely affect DOD’s 

ability to develop accurate budgetary and staffing plans. For example, 

DOD’s difficulty in estimating its workload was evidenced in fiscal year 

2002 when DOD expected 720,000 requests for investigations and actually 

received more than 850,000 requests—or 18 percent more. 

In December 2003, advisors to the Director of OPM recommended that the 

congressionally authorized transfer of DOD’s investigative functions to 

OPM should not take place for at least the rest of fiscal year 2004. That 

recommendation was based on uncertainty about the financial risks that 

OPM might incur from the transfer. The advisors recommended an 

alternative plan that is currently being discussed by DOD and OPM 

officials. The alternative plan would keep DSS’s investigative staff in DOD; 

provide DSS with access to OPM’s case management system, which, 

according to a DOD official, would save about $100 million in costs 

associated with continuing to update and maintain DOD’s current case 

management system; and train DSS staff to use that system. Also, as of 

December 16, 2003, the Secretary of Defense had not provided Congress 

with the certifications that are required before the transfer could take 

place. 

In order to eliminate the personnel security clearance backlog and 

increase the accuracy of DOD’s security clearance backlog estimates, we 

are recommending that DOD take steps to improve the management and 

oversight of the personnel security clearance program: match both 

investigative and adjudicative workforce sizes to workloads; develop a 

strategic plan to overcome access to information problems; develop 

DOD-wide backlog definitions and measures and monitor the backlog; and 

complete the implementation of JPAS. 
Page 6 GAO-04-344 DOD Personnel Clearances 

In commenting on a draft of this report, DOD fully concurred with three of 

our four recommendations and partially concurred with our 

recommendation to match workforce sizes to workloads. 

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

was created in 2002 with the passage of the Bob Stump National Defense 

Authorization Act for Fiscal Year 2003.8

 Among the responsibilities of 

OUSD (I) are the coordination and implementation of DOD policy for 

access to classified information. At the time of our earlier review on the 

clearance process, these responsibilities belonged to the Office of the 

Assistant Secretary of Defense for Command, Control, Communications, 

and Intelligence (OASD (C3I)). 

Classified information is categorized into three levels—top secret, secret, 

and confidential—to denote the degree of protection required for 

information according to the amount of damage that unauthorized 

disclosure could reasonably be expected to cause to national defense or 

foreign relations.9

 The degree of expected damage 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. To retain access 

to classified information, individuals must periodically go through the 

security clearance process. The time frames for reinvestigation are every 

5 years for top secret, 10 years for secret, and 15 years for confidential.10

DOD’s personnel security clearance process has three stages: 

preinvestigation, which includes determining if a requirement for access 

exists and submitting an investigation request; the actual personnel 

security investigation; and adjudication, a determination of eligibility for 

access to classified information (see fig. 1). Since 1997, all federal agencies 

 8

 Pub. L. 107-314 § 901 (Dec. 2, 2002). 

9

 Classification of National Security Information, 5 C.F.R. §1312.4 (2003). 

10 Adjudicative Guidelines for Determining Eligibility for Access to Classified Information, 

32 C.F.R. Part 147, Subpart B, Attach. A and Attach. C (2003). 

Background 
Page 7 GAO-04-344 DOD Personnel Clearances 

have been subject to a common set of personnel security investigative 

standards and adjudicative guidelines for determining whether service 

members, government employees, industry personnel, and others are 

eligible to receive a security clearance.11 In 1998, DOD formally 

incorporated these standards and guidelines into its regulations governing 

access to classified information.12

Figure 1: DOD’s Personnel Security Clearance Process 

The security officer begins the preinvestigation stage of the clearance 

process by determining whether a position requires access to classified 

information. If so, the current or future job incumbent completes a 

personnel security questionnaire that asks for detailed information 

about a wide range of issues. The impetus for an investigation request 

could be a need to (1) appoint, enlist, or induct an individual into the 

military; (2) staff a new program or contract with an individual who has 

a clearance; (3) replace a cleared job incumbent with someone else; 

(4) raise an existing clearance to a higher level; or (5) reinvestigate 

a previously cleared job incumbent whose clearance is due for 

reinvestigation. 

In the investigation stage, investigative staff members seek information 

pertaining to the subject’s loyalty, character, reliability, trustworthiness, 

honesty, and financial responsibility. The level of clearance is the primary 

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

(Washington, D.C.: Mar. 24, 1997). This memorandum approves the adjudicative guidelines, 

temporary eligibility standards, and investigative standards required by Executive Order 

12968, Access to Classified Information, Aug. 2, 1995. 

12 Assistant Secretary of Defense for Command, Control, Communications, and 

Intelligence, “Personnel Security Investigations and Adjudications,” Memorandum 

(Washington, D.C.: Nov. 10, 1998). 
Page 8 GAO-04-344 DOD Personnel Clearances 

determinant of the types and sources of information gathered. For 

example, an investigation for a top secret clearance requires much more 

information than does the type of investigation required to determine 

eligibility for either a secret or confidential clearance. The types or 

sources of information might include an interview with the subject of 

the investigation, national agency checks (e.g., Federal Bureau of 

Investigations and immigration records), local agency checks (e.g., 

municipal police and court records), financial checks, birth date and place, 

citizenship, education, employment, public records for information such 

as bankruptcy or divorce, and interviews with references. 

In the adjudication stage of the security clearance process, government 

employees in 10 DOD central adjudication facilities13 use the information 

gathered at the investigation stage to approve, deny, or revoke eligibility to 

access classified information. Once adjudicated, the security clearance is 

then issued up to the appropriate eligibility level, or alternative actions are 

taken if eligibility is denied or revoked. 

DOD did not know the size of its personnel security clearance backlog and 

has not estimated the size of the backlog since January 2000. DOD was 

unable to estimate the size of its backlog for overdue reinvestigations that 

have not yet been submitted, but our estimates for overdue submitted 

investigation requests and overdue adjudications were roughly 270,000 and 

90,000 cases, respectively, at the end of September 2003. These estimates 

are not based on a consistent set of DOD-wide definitions 

 13 A Defense Personnel Security Research Center report provided the following distinctions 

in the roles of the 10 DOD central adjudication facilities. The Army, Navy, and Air Force 

facilities adjudicate all military and civilian clearances for their respective services, and the 

sensitive compartmented information clearances for industry employees working on the 

department’s contracts. The Washington Headquarters Service facility adjudicates all 

clearances, except for sensitive compartmented information, for civilians assigned to 

Defense agencies. The National Reconnaissance Office, National Security Agency, and 

Defense Intelligence Agency facilities adjudicate all sensitive compartmented information 

clearances for their own employees, and the Defense Intelligence Agency also does the 

same for other Defense agency civilians. The Joint Chiefs of Staff facility adjudicates 

clearances for its own personnel. The Defense Industrial Security Clearance Office 

adjudicates investigations that contain favorable or minor derogatory information for 

issuance of top secret, secret, and confidential clearances for industry personnel. Industry 

investigations that contain major derogatory information are transferred to the Defense 

Office of Hearings and Appeals for adjudication. Ralph M. Carney et al., Quality Assurance 

in Defense Adjudication: An Adjudicator Workshop for Defining and Assessing Quality, 

(Monterey, Calif.: Defense Personnel Security Research Center, Mar. 2003). 

DOD Unable to 

Estimate the Size of 

Its Clearance Backlog 
Page 9 GAO-04-344 DOD Personnel Clearances 

and measures; instead, the time limits for defining and measuring the 

backlog varied from agency to agency. 

DOD could not estimate the number of personnel who had not requested 

a reinvestigation, even though their clearances exceeded the 

governmentwide time frames for reinvestigation (see fig. 2). As we 

mentioned earlier, the governmentwide time frames for renewing 

clearances are 5, 10, or 15 years depending on an individual’s clearance 

level. We, therefore, defined this portion of the backlog as any request for 

reinvestigation that had not been submitted within those time frames. 

Figure 2: Estimated Backlog Size at Each Stage in the Personnel Security Clearance Process, as of September 2003 

In our 2000 report, we indicated that DOD estimated its overdue but-notsubmitted reinvestigation backlog at 300,000 cases in 1986 and 500,000 

cases in 2000.14 Our 2000 report also noted that the 500,000-case backlog 

estimate was of questionable reliability because of the ad hoc methods 

used to derive it. Between 2000 and 2002, DOD took a number of steps to 

reduce this backlog, including mandating the submission of requests and 

requiring senior service officials to provide monthly submission progress 

reports. On February 22, 2002, DOD concluded this backlog reduction 

 14 GAO/NSIAD-00-215. 

DOD Unable to Estimate 

the Number of Overdue 

Reinvestigations Not Yet 

Submitted 
Page 10 GAO-04-344 DOD Personnel Clearances 

effort by issuing an OASD (C3I) memorandum directing that “[b]y 

September 30, 2002, if a clearance is not based upon a current or pending 

investigation, or if the position does not support a requirement for a 

clearance, the clearance must be administratively terminated or 

downgraded without prejudice to the individual.” DOD is unable to show 

that the overdue but-not-submitted reinvestigations backlog was 

eliminated by these actions. 

At the end of September 2003, the investigative portion of the backlog 

consisted of roughly 270,000 submitted requests for either reinvestigation 

or initial investigation that had not been completed within a prescribed 

amount of time. We calculated this estimate from information provided in 

response to the data requests that we made to DSS and OPM. This number 

represents an estimated 163,000 cases at DSS and 107,000 cases contracted 

to OPM that had not been completed within the time limits. In our August 

2000 report, DOD stated that a vast majority of 94,000 submitted requests 

for reinvestigation were overdue for completion, and those cases were 

not part of DOD’s estimate of 500,000 overdue but-not-submitted 

reinvestigations discussed in the prior section. At that time, DOD had not 

included either submitted reinvestigations or initial investigations that 

exceeded specified time limits as part of the DOD-wide backlog. An 

estimate of the initial investigations exceeding the time limit was not a 

focus of that work. 

The existence of varying sets of time limits for completing investigations 

makes it difficult to develop accurate estimates of the size of DOD’s 

investigative backlog. 

• DSS’s performance goals are 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.15 In addition, some requests for investigations receive priorities 

over other requests. 

• OPM has timeliness categories that DOD and other agencies use to 

request various types of investigations. The timeliness categories are 

 15 DSS’s performance goal is to complete at least 75 percent of each type of investigation 

within the specified time limits, but monitoring of the backlog requires a determination of 

whether each investigation was completed by the time limit—not whether an aggregate 

performance goal was met for a particular type of investigation. 

Roughly 270,000 Submitted 

Requests for Investigations 

Overdue for Completion 
Page 11 GAO-04-344 DOD Personnel Clearances 

35 days for priority investigations, 75 days for accelerated 

investigations, 120 days for standard investigations, and 180 days for 

extended service agreements.16

The lack of a standard set of time limits is a long-standing problem. In 

1994, the Joint Security Commission reported on this issue, and among 

other things (1) found there was no performance standard for timeliness in 

completing investigations and adjudications, (2) stated it repeatedly heard 

from the customer community that 90 days is an appropriate standard for 

completing an average investigation and adjudication, and (3) 

recommended “[s]tandard measurable objectives be established to assess 

the timeliness and quality of investigations, adjudications, and 

administrative processes and appeals performed by all such organizations 

within DOD and the Intelligence Community.”17

OPM’s issuance of closed pending cases—investigations sent to 

adjudication facilities without one or more types of source data—presents 

another ambiguity in defining and accurately estimating the backlog. In 

our October 1999 report, we found that DSS had similarly delivered 

incomplete investigations to DOD adjudicators.18 After we recommended 

that DOD adjudication facility officials grant clearances only when all 

essential investigative work has been done, DSS monitored the cases 

returned from the adjudication facilities and identified reasons for the 

returns. Overall, about 10 percent of the 283,480 DOD cases fully closed by 

OPM in fiscal year 2002 were initially delivered to central adjudication 

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

contractors’ performance, OPM defines 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 within OPM-contracted time 

limits, we believe that closed pending cases should be included in the 

investigative portion of the backlog. 

 16 OPM’s performance goals for its contractor are to complete 90 percent of the 35-day 

service requests by the agency date, 92 percent of the 75-day service requests by the agency 

date, 95 percent of the 120-day service requests by the agency date, and 95 percent of the 

extended service agreements by the agency date. 

17 Joint Security Commission, Redefining Security: A Report to the Secretary of Defense 

and the Director of Central Intelligence (Washington, D.C.: Feb. 28, 1994). 

18 GAO/NSIAD-00-12. 
Page 12 GAO-04-344 DOD Personnel Clearances 

Central adjudication facilities’ responses to our request for adjudicative 

backlog estimates as of September 30, 2003, indicated that roughly 

90,000 completed investigations had not been adjudicated within 

prescribed time limits (see table 1). Differences in the sizes of the backlog 

at the various central adjudication facilities are due to a combination of 

factors. For example, the military service departments generally perform 

more adjudications than do DOD agencies; some facilities have increased 

their staffing of government employees to decrease the backlog; and some 

facilities have contracted for support services to decrease the backlog. We 

later discuss the large number of requests that have resulted over the last 

few years. DOD officials attributed this extra adjudicative workload to, 

among other things, increased operations related to the war on terrorism. 

Table 1: Adjudicative Backlog Present at Each Central Adjudication Facility, as of 

September 30, 2003 

Central Adjudication Facility Size of Adjudicative Backlog 

Army 35,226 

Air Force 25,493 

Defense Industrial Security Clearance Office 12,793 

Navy 12,606 

Defense Office of Hearings and Appeals 4,487 

Washington Headquarters Services 1,296 

Defense Intelligence Agency 1,046 

National Security Agency 0 

Joint Staff does not track 

Total 92,947 

Source: DOD. 

Note: We did not attempt to gather information from the National Reconnaissance Office because of 

the sensitive nature of its mission. 

An ambiguous picture of the adjudicative backlog size is present because 

the central adjudication facilities use different time limits to define 

when cases become part of the backlog. Applying the backlog criteria 

of one central adjudication facility to the completed investigations 

waiting adjudication at another facility could increase or decrease the 

estimated size of the DOD-wide adjudicative backlog. For instance, 

the Defense Industrial Security Clearance Office’s goals for completing 

adjudications are 3 days for initial investigations and 30 days for periodic 

reinvestigations, and any cases exceeding these amounts are considered a 

backlog. In contrast, the Defense Office of Hearings and Appeals’ goal is to 

DOD-Wide Estimate of 

Adjudicative Backlog 

Exceeds Roughly 90,000 

Cases 
Page 13 GAO-04-344 DOD Personnel Clearances 

maintain a steady workload of adjudicating 2,150 cases per month within 

30 days of receipt, and it considers a backlog to exist when the number of 

cases on hand exceeds its normal workload. Thus, if the Defense 

Industrial Security Clearance Office’s stricter time limit were applied to 

the initial investigations awaiting adjudication at the Defense Office of 

Hearings and Appeals, the latter office’s backlog would be larger than that 

currently reported. 

We have identified four major impediments that have slowed DOD’s 

progress in eliminating its clearance backlog and two impediments that 

have hindered its ability to produce accurate backlog estimates. 

In our review of documents and discussions with officials from DOD, 

OPM, industry associations, and investigator contractors, we identified 

four major impediments that have hampered DOD’s ability to eliminate its 

current security clearance backlog. These are: (1) the large number of 

new requests for clearances, (2) inadequate investigator and adjudicator 

workforces, (3) the mere size of the existing backlog, and (4) the lack of a 

strategic plan for overcoming problems by government and contractor 

investigators in gaining access to information from state, local, and 

overseas sources. 

The large number of requests for security clearances hinders DOD’s efforts 

to draw down the number of cases in its current clearance backlog. In 

fiscal year 2003, the Secretary of Defense annual report to the President 

and Congress noted that defense organizations annually request more than 

1 million security checks. These checks include investigations that are part 

of the personnel security clearance process as well as other investigations 

such as those used to screen some new recruits entering the military. 

Other federal agencies are also requesting a growing number of 

background investigations according to OPM. In our November 2003 

Multiple Impediments 

Slow DOD’s Progress 

in Eliminating Its 

Backlog and 

Generating Accurate 

Backlog Estimates 

Large Number of 

Clearance Requests, 

Limited Staffing, Existing 

Backlog, and No Strategic 

Plan for InformationAccess Problems Slow 

DOD’s Efforts to Eliminate 

the Backlog 

Large Number of Requests for 

Clearances 
Page 14 GAO-04-344 DOD Personnel Clearances 

report on aviation security,19 we noted that OPM had stated that 

(1) it received an unprecedented number of requests for background 

investigations governmentwide since September 2001 and (2) the large 

number of requests was the primary reason for delayed clearance 

processing. 

Historically, almost all of DOD’s requests for investigations were 

submitted to DSS. Starting in 1999, DOD contracted with OPM to complete 

a large number of requests for investigations as part of DOD’s effort to 

expand its investigative capacity and decrease its investigative 

backlog. OUSD (I) estimated that DOD spent over $450 million for the 

investigations submitted to DSS and OPM in fiscal year 2003. As table 2 

shows, OUSD (I) reported that the actual number of requests submitted 

for investigations were approximately 700,000 in fiscal year 2001, more 

than 850,000 in fiscal year 2002, and more than 775,000 in fiscal year 2003.20

In fiscal year 2003, DSS had responsibility for a larger percentage of the 

total DOD investigations workload than it had in the prior 2 fiscal years. 

DSS supplemented its federal workforce with contracts to three privatesector investigations firms. As table 2 also indicates, the number of 

targeted submissions versus the actual number of submissions that DOD 

received varied considerably from year to year. In fiscal year 2001, DOD 

received fewer requests than it had expected (82 percent), and in fiscal 

years 2002 and 2003, it received more requests than projected (119 and 

113 percent, respectively). 

 19 U.S. General Accounting Office, 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.: Nov. 19, 2003). 

20 In our October 1999 report on investigations, table 9 showed that during fiscal years 

1991-1998, DSS opened a low of 126,000 cases in fiscal year 1996 and a high of 271,000 

cases in fiscal year 1992. We believe that differences in investigative procedures and other 

conditions at DSS then versus now make findings from any such comparison of prior and 

current investigative workloads tenuous. GAO/NSIAD-00-12. 
Page 15 GAO-04-344 DOD Personnel Clearances 

Table 2: Targeted and Actual Numbers of Requests Submitted to DSS and OPM 

during Fiscal Years 2001-2003 

 FY 2001 FY 2002 FY 2003 

Requests 

submitted to Target Actual Target Actual Target Actual 

DSS 435,734 416,233 408,539 438,093 530,271 603,460 

OPM 413,033 283,963 312,248 418,181 157,004 173,984 

Total 848,767 700,196 720,787 856,274 687,275 777,444 

Percent of actual at 

DSS 

 59 % 51 % 78 % 

Percent of target 82 % 119 % 113 % 

Source: OUSD (I). 

Note: Table 2 shows when investigations began, but the investigations may not be completed in the 

same fiscal year. 

DOD personnel, investigations contractors, and industry officials told us 

that the large number of requests for investigations could be attributed to 

many factors. For example, they ascribed the large number of requests to 

heightened security concerns that resulted from the September 11, 2001, 

terrorist attacks. They also attributed the large number of investigations to 

an increase in the operations and deployments of military personnel and 

to the increasingly sensitive technology that military personnel, 

government employees, and contractors come in contact with as a part of 

their job. While having a large number of cleared personnel can give the 

military services, agencies, and industry a large amount of flexibility 

when assigning personnel, the investigative and adjudicative workloads 

that are required to provide the clearances further tax DOD’s already 

overburdened personnel security clearance program. 

A change in the level of clearance being requested also increases the 

investigative and adjudicative workloads. A growing percentage of all 

DOD requests for clearances is at the top secret level. For example, in 

fiscal years 1995 and 2003, 17 percent and 27 percent, respectively, of the 

clearance requests for industry personnel were at the top secret level. This 

increase of 10 percentage points in the proportion of investigations at the 

top secret level is important because top secret clearances must be 

renewed twice as often as secret clearances (i.e., every 5 years versus 

every 10 years). According to OUSD (I), top secret clearances take eight 

times the investigative effort needed to complete a secret clearance and 

three times the adjudicative effort to review. The doubling of frequency 
Page 16 GAO-04-344 DOD Personnel Clearances 

along with the increased effort to investigate and adjudicate each top 

secret reinvestigation adds costs and workload for DOD. 

• Cost. In fiscal year 2003, the costs of investigations that DOD obtained 

through DSS were $2,640 for an initial investigation for a top secret 

clearance, $1,591 for a periodic reinvestigation of a top secret 

clearance, and $328 for the most commonly used investigation for a 

secret clearance. The cost of getting and maintaining a top secret 

clearance for 10 years is approximately 13 times greater than the cost 

for a secret clearance. For example, an individual getting a top secret 

clearance for the first time and keeping the clearance for 10 years 

would cost DOD a total of $4,231 in current year dollars ($2,640 for the 

initial investigation and $1,591 for the reinvestigation after the first 

5 years). In contrast, an individual receiving a secret clearance and 

maintaining it for 10 years would cost a total of $328 ($328 for the 

initial clearance that is good for 10 years). 

• Time/Workload. The workload is also affected by the scope of 

coverage in the various types of investigations. Much of the 

information for a secret clearance is gathered through electronic files. 

The investigation for a top secret clearance, on the other hand, requires 

the information needed for the secret clearance as well as data 

gathered through time-consuming tasks such as interviews with the 

subject of the investigation request, references in the workplace, and 

neighbors. 

Another impediment to eliminating the large security clearance backlog 

is the inadequate size of the federal and private-sector investigative 

workforces relative to the large workloads that they face. The Deputy 

Associate Director of OPM’s Center for Investigations Services estimated 

that roughly 8,000 full-time-equivalent investigative personnel would be 

needed by OPM and DOD (together) to eliminate backlogs and deliver 

investigations in a timely fashion to their customers. The rough estimate 

includes investigators and investigative technicians. However, changes in 

the numbers or types of clearance requests, different levels of productivity 

by investigators, and other factors could greatly affect this estimated 

workforce requirement. 

As of December 2003, we calculated that DOD and OPM have around 

4,200 full-time-equivalent investigators available as federal employees or 

currently under contract. Of this number, DSS indicated that it has about 

1,200 investigators and 100 investigative technicians. In addition, DSS has 

the equivalent of 625 full-time investigative staff, based on 2,500 mostly 

Inadequate Investigative and 

Adjudicative Workforces 

Hinder Efforts to Eliminate 

Backlog 
Page 17 GAO-04-344 DOD Personnel Clearances 

part-time investigators, from its three contractors. DSS equates four of the 

part-time investigators to one full-time investigator. Finally, although OPM 

has almost no investigative staff currently, its primary contractor has 

approximately 2,300 full-time investigators. OPM reported that its primary 

contractor is adding about 100 investigators per month, but turnover is 

about 70 employees per month. 

We believe that DSS’s estimate of the number of full-time-equivalent 

investigators working for its contractors is imprecise because (1) an 

investigator may work part-time for more than one contractor and 

(2) the amount of time devoted to conducting investigations can vary 

substantially. These part-time investigators work different amounts of time 

each month, according to both their own preference and the number of 

assignments they receive from investigation contractor(s). Sometimes they 

are unavailable to work for one contractor because they are conducting 

investigations for another contractor. Officials from DSS’s investigations 

contractors told us that they intend to continue relying largely on staff 

employed on an as-needed basis. Some of the private-sector officials 

stated that they would incur additional financial risks if they were to use 

full-time investigators. 

Inadequate adjudicator staffing also causes delays in issuing eligibility-forclearance decisions. Since we issued our report on DOD adjudications in 

2001, the number of eligibility-for-clearance decisions has risen for 

reasons such as an increase in the number of completed investigations 

stemming from DOD’s contract with OPM and the improved operation of 

DSS’s Case Control Management System. 

Central adjudication facilities with adjudicative backlogs have taken 

various actions to eliminate their backlog. The Defense Office of Hearings 

and Appeals hired 46 additional adjudicators on 2-year term appointments, 

contracted for administrative functions associated with adjudication, and 

is seeking permission from the Office of the Secretary of Defense to 

hire some of its term adjudicators permanently. The Navy’s central 

adjudication facility contracted with three companies to provide support 

and hired an additional 27 full-time-equivalent civilian and military 

adjudicators, which helped the Navy eliminate much of its adjudicative 

backlog that had grown to approximately 60,000 cases by December 2002. 

Because the DOD Office of Inspector General is examining whether the 

Navy adjudicative contracts led the contractor’s staff to perform an 

inherently governmental function—adjudication—it is unclear whether the 

Army and Air Force central adjudication facilities will be able to use 

similar contracting to eliminate their backlogs. 
Page 18 GAO-04-344 DOD Personnel Clearances 

The 10 DOD central adjudication facilities are funded by different agencies 

and operate independently of one another. As a result, OUSD (I) cannot 

transfer backlogged cases from one facility to eliminate an adjudicative 

backlog at another facility. In our April 2001 report on DOD 

adjudications,21 we noted that studies issued by the Defense Personnel 

Security Research Center, the Joint Security Commission, and the DOD 

Office of the Inspector General between 1991 and 1998 had concluded 

that the decentralized structure of DOD’s adjudication facilities had 

drawbacks. Two of the studies had recommended that DOD consolidate 

its adjudication facilities (with the exception of the National Security 

Agency because of the sensitive nature of its work) into a single entity. 

Currently, OUSD (I) is exploring the possibility of assigning all industry 

adjudications to the Defense Industrial Security Clearance Office instead 

of having it share this responsibility with the Defense Office of Hearing 

and Appeals. 

The current size of the investigative backlog impedes DOD’s ability to 

process new security clearance requests within the prescribed time 

limits. A new request might remain largely dormant for months in the 

investigations queue until other requests that were received earlier have 

been completed. This point can be illustrated by examining the results of 

miscommunications between OASD (C3I) and DSS regarding assigning 

priorities to investigations between March 2002 and March 2003. During 

that period, DSS placed a higher priority on completing new—versus old—

requests. From March through September 2002, DSS averaged 97 days to 

open and complete initial investigation requests for top secret clearances; 

100 days, for top secret reinvestigation; 43 days, for secret; and 44 days, for 

confidential. For three of the four types of investigations, DSS’s average 

completion times were faster than its time-based goals (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). Starting in March 2003, DSS again 

assigned a higher priority to older requests. However, during those 

12 months, from March 2002 to February 2003, the average age of the older 

cases increased, and it is impossible to say how much of the increase was 

due to the miscommunication regarding priorities, a change in the number 

of requests that DSS received, or some other factor. 

 21 GAO-01-465. 

Size of Existing Backlog 

Impedes Prompt Opening of 

New Requests for Investigation 
Page 19 GAO-04-344 DOD Personnel Clearances 

DSS staff told us that the delays in starting investigations could lead to 

additional delays in processing the case, particularly for military personnel 

who were being deployed or were moving. Therefore, DSS instituted a 

procedure to attempt to meet with individuals requesting an investigation 

before they deploy or go on extended training. Delays in starting 

investigations can result in extra investigative work to find the individuals 

at their new addresses or additional delays if investigators wait for the 

individuals to return from deployment or training. In some cases, however, 

DOD commands, agencies, and contractors have been able to obtain some 

investigations quickly by assigning higher priorities to certain individual 

investigations or types of investigations. 

The absence of a strategic plan for overcoming problems in gaining access 

to information from state and local agencies also slows the speed of 

personnel security clearance investigations and, thereby, impedes 

reducing the size of the backlog. Investigators face delays in conducting 

background checks because of the lack of automated records in many 

localities, state and local budget shortfalls that limit how much time 

agency staff have to help investigators, and privacy concerns (e.g., access 

to conviction records from the courts instead of the preferred arrest 

records from law enforcement). This problem of accessibility to state and 

local information was identified in an October 2002 House Committee on 

Government Reform report.22 The report recommended that the Secretary 

of Defense and the Attorney General jointly develop a system that allows 

DSS and OPM investigators access to state and local criminal history 

information records. In addition, representatives from one investigations 

contractor noted that the Security Clearance Information Act23 gives only 

certain federal agencies access to state and local criminal records, and 

therefore private-sector investigators are put at a disadvantage relative to 

federal investigators. 

Another barrier to the timely closure of an investigation is a limited 

investigative capacity overseas, which causes delays in obtaining 

information from overseas investigative sources. DSS, OPM, and privatesector investigations contractors do not maintain staffs overseas to 

investigate individuals who are currently or were formerly stationed 

 22 Committee on Government Reform, Defense Security Service: The Personnel Security 

Investigations (PSI) Backlog Poses a Threat to National Security, H.R. 107-767 

(Washington, D.C.: Oct. 24, 2002). 

23 Security Clearance Information Act, 5 U.S.C. § 9101 (2003). 

No Strategic Plan for 

Overcoming InformationAccess Problems Slows 

Investigative Process 
Page 20 GAO-04-344 DOD Personnel Clearances 

overseas, who have traveled or lived overseas, or who have relatives living 

in foreign countries. Officials at DSS and the central adjudication facilities 

told us that they typically ask overseas-based DOD criminal investigations 

personnel or State Department and Central Intelligence Agency employees 

to supply this type of investigative information as a collateral duty. 

DOD has no strategic plan for overcoming access to information problems 

and the delays that result, but DOD has made efforts to address selective 

aspects of the access problem. For example, DOD supplied us with draft 

legislation proposing to provide access to a central repository for driver 

licensing records. DOD proposed that this information be used in 

personnel security investigations and determinations as well as personnel 

investigations with regard to federal employment security checks. Also, an 

OUSD (I) official noted that DOD proposed a legislative change for the 

fiscal year 2001 authorization bill to allow easier access to records of 

criminal history information. 

OUSD (I) and its predecessor OASD (C3I) have not provided the oversight 

needed to monitor and accurately estimate the various parts of the 

backlog that are present throughout DOD. Also, as we documented earlier, 

backlog estimates are not based on a consistent set of DOD-wide 

definitions and measures. Knowing the accurate size of the backlog is an 

important step towards effectively managing and eventually eliminating 

the backlog. When we asked for all investigative backlog reports produced 

since 2000, OUSD (I) supplied January 2000 estimates as its most recent 

report, and the report included only reinvestigations. This finding 

regarding the infrequency of reporting contradicts DOD’s concurrence 

with our October 1999 recommendation for OASD (C3I) to improve its 

oversight of the investigations program and our August 2000 

recommendation to design routine reports to show the full extent of 

overdue reinvestigations. Our April 2001 report similarly concluded that 

OASD (C3I) needed to provide stronger oversight and better direction to 

DOD’s adjudication facility officials. After a review of DOD’s personnel 

security investigations program, an October 2002 report by the House 

Government Reform Committee recommended, “The Secretary of Defense 

should continue to report the personnel security investigations program 

Oversight Problems and 

Automation Delays Hinder 

Accurate Monitoring of 

Backlog Size 
Page 21 GAO-04-344 DOD Personnel Clearances 

including the adjudicative process as a material [sic] weakness24 under the 

Federal Managers’ Financial Integrity Act to ensure needed oversight is 

provided to effectively manage and monitor the personnel security 

process from start to finish.”25 DOD concurred with our October 1999 

recommendation to declare its investigations program as a material 

weakness to ensure that needed oversight is provided and that actions are 

taken. For fiscal years 2000 through 2003, DOD listed the personnel 

security program as a systemic weakness, which is a weakness that affects 

more than one DOD component and may jeopardize the department’s 

operations.26

Delays in implementing the joint adjudication system, JPAS, have greatly 

inhibited OUSD (I)’s ability to monitor overdue reinvestigations and 

generate accurate estimates for that portion of the backlog. Among JPAS’s 

intended purposes are to consolidate DOD’s security clearance data 

systems and provide various levels of near real-time input and retrieval of 

clearance-related information to OUSD (I), investigators, adjudicators, and 

security officers at commands, agencies, and industrial facilities. The DOD 

Chief Information Officer identified JPAS as a critical mission system. 

When we reported on the reinvestigations backlog in August 2000, the 

Assistant Secretary of Defense for Command, Control, Communications, 

and Intelligence stated that JPAS would be fully implemented in fiscal year 

2001 and would be capable of providing recurring reports showing the 

accurate number of cleared personnel requiring a periodic reinvestigation 

by component and type of investigation. In early December 2003, an OUSD 

(I) official said current plans are to have JPAS fully operational by January 

2004. The delays are caused by problems such as loading adjudicative data 

from each central adjudication facility’s internally developed database and 

historical data from the Defense Clearance and Investigation Index. 

 24 While the October 2002 House Committee on Government Reform report does indeed 

make this recommendation, the DOD’s annual statements of assurance for fiscal year 2000 

and for fiscal year 2001 and its annual performance and accountability reports for fiscal 

year 2002 and for fiscal year 2003 report the personnel security investigations program as a 

“systemic weakness.” Committee on Government Reform report, Oct. 24, 2002. 

25 Committee on Government Reform report, Oct. 24, 2002, p. 36. 

26 Department of Defense Annual Statement of Assurance, Fiscal Year 2000 and Fiscal 

Year 2001; Department of Defense Performance and Accountability Report, Fiscal Year 

2002 (Jan. 31, 2003) and Fiscal Year 2003 (Dec. 23, 2003). 
Page 22 GAO-04-344 DOD Personnel Clearances 

DOD’s failure to eliminate its backlog of overdue reinvestigations may 

heighten the risk of national security breaches. Also, backlog-related 

delays in issuing initial security clearances may raise the cost of doing 

classified work for the U.S. government. In addition, DOD’s inability to 

accurately determine the actual size of its clearance backlog and project 

the number of clearances needed results in inaccurate budget requests and 

staffing plans. 

Delays in completing reinvestigations caused by the backlog and other 

impediments may lead to a heightened risk of national security breaches. 

Such breaches involve the unauthorized disclosure of classified 

information, which can have effects that range from exceptionally grave 

damage to national security for top secret information to damage for 

confidential information.27 In 1999, the Joint Security Commission reported 

that delays in initiating reinvestigations create risks to national security 

because the longer individuals hold clearances the more likely they are to 

be working with critical information systems.28

Delays in completing initial security clearances may have an economic 

impact on the cost of performing classified work within or for the 

U.S. government. Although estimates of the total economic costs of delays 

in granting clearances are dated, they reflect the extent of an ongoing 

problem. In a 1981 report, we estimated that the DOD investigative 

backlog could cost nearly $1 billion per year in lost productivity.29 More 

than a decade later, the Joint Security Commission report noted that the 

costs directly attributable to investigative delays in fiscal year 1994 could 

be as high as several billion dollars because workers were unable to 

perform their jobs while awaiting a clearance.30 While newer overall cost 

 27 Classification of National Security Information, 5 C.F.R. §1312.4 (2003). 

28 Joint Security Commission II, Report of the Joint Security Commission II, (Aug. 24, 

1999), p. 5-6. 

29 U.S. General Accounting Office, Faster Processing of DOD Personnel Security 

Clearances Could Avoid Millions in Losses, GAO/GGD-81-105 (Washington, D.C.: 

Sept. 15, 1981). 

30 Joint Security Commission, Redefining Security: A Report to the Secretary of Defense 

and the Director of Central Intelligence, Chapter 4, Personnel Security—The First and 

Best Defense (Washington, D.C.: Feb. 28, 1994). 

Backlogs and Poor 

Estimates May Lead 

to Increased National 

Security Risks, Higher 

Costs, and Workload 

Uncertainties 

Continued Failure to 

Eliminate Backlog May 

Lead to Increased National 

Security Risks and 

Unnecessary Costs 
Page 23 GAO-04-344 DOD Personnel Clearances 

estimates are not available, the underlying reasons—the backlog and 

clearance delays that prevent the employment—for the costs still exist 

within DOD. For instance, DSS reported that the average time required to 

complete an initial investigation for a top secret clearance was 454 days 

for fiscal year 2002 and 257 days for October 2002 through February 2003. 

The impact of delays in completing initial clearances affects industry,31

which relies on DOD to provide clearances for their employees. 

Representatives from one company with $1 billion per year in sales stated 

that their company offers a $10,000 bonus to its employees for each person 

recruited who already has a security clearance. Such operating costs are 

then passed on to government customers in the form of higher bids for 

contracts. In turn, the recruit’s former company may need to back-fill a 

position, as well as possibly settle for a lower level of contract 

performance while a new employee is found, obtains a clearance, and 

learns the former employee’s job. Also, industry representatives discussed 

instances where their companies gave hiring preference to personnel who 

could do the job but were less qualified than others who did not possess a 

clearance. The chair of the interagency Personnel Security Working Group 

noted that a company might hire an employee and begin paying that 

individual, but not assign any work to the individual until a clearance is 

obtained. Also, the head of the interagency group noted that commands, 

agencies, and industry might incur lost-opportunity costs if the individual 

chooses to work somewhere else rather than wait to get the clearance 

before beginning work. 

DOD’s inability to accurately project its personnel security clearance 

workload requirements have created budgeting and staffing difficulties for 

DOD units involved in the clearance process. For example, in fiscal year 

2000, the services and defense agencies had to limit the number of overdue 

reinvestigations that they submitted for investigation because they had not 

budgeted the additional funds needed to cover the costs of the increased 

workload. Differences between the targeted and actual number of 

investigations for fiscal years 2001 to 2003 (see table 2) also document 

problems with the current procedures used to project clearance 

requirements. Inaccurate projections of personnel security clearance 

 31 We have an ongoing effort for the House Government Reform Committee that is 

examining the backlog of industry requests for clearances, the timeliness of clearance 

determinations, and the steps that DOD might take to make its process more efficient. 

Poor Estimates Can Result 

in Inadequate Budget and 

Staffing 
Page 24 GAO-04-344 DOD Personnel Clearances 

workloads may have also caused the backlog to be bigger than it might 

otherwise be because DSS and the central adjudication facilities did not 

adequately plan for increases in workloads. 

In December 2003, advisors to the Director of OPM recommended that the 

congressionally authorized transfer of DSS investigative functions and 

personnel to OPM not occur—at least for the rest of fiscal year 2004—due 

primarily to concerns about the financial risks associated with the 

transfer. The advisors recommended an alternative plan that is currently 

being discussed by DOD and OPM officials. The alternative plan proposes 

that DSS investigative functions and employees stay in DOD; use the OPM 

case management system, which according to a DOD official would save 

about $100 million in costs associated with continuing to update and 

maintain DOD’s current case management system; and receive training to 

use that system from OPM. As of December 16, 2003, the Secretary of 

Defense had not provided Congress with the certifications required before 

the transfer can take place. 

On February 3, 2003, a DOD news release announced that the Deputy 

Secretary of Defense and the Director of the OPM had signed an 

agreement that would allow DOD to divest its personnel security 

investigative functions and OPM to offer positions to DSS investigative 

personnel. The proposal for the transfer of functions and personnel was 

included in DOD’s The Defense Transformation for the 21st Century Act 

when that legislative proposal was submitted to Congress on April 10, 

2003. Also, the Secretary of Defense’s annual report to the President and 

to Congress for 2003 cited the transfer as an effort to “[r]eengineer the 

personnel security program by seeking statutory authority to transfer the 

personnel security investigation function currently performed by the 

Defense Security Service to the Office of Personnel Management, thus 

streamlining activities and eliminate redundancy.”32 The projected savings 

were estimated to be approximately $160 million over the fiscal year 2004 

to 2009 time frame. 

On November 24, 2003, the National Defense Authorization Act for Fiscal 

Year 2004 authorized the transfer of DSS’s personnel security investigative 

 32 Donald H. Rumsfeld, Secretary of Defense, Annual Report to the President and to 

Congress 2003, p. 64. 

Status Update on the 

Authorized Transfer 

of DSS Investigative 

Functions and 

Personnel to OPM 

Background of the 

Authorized Transfer 
Page 25 GAO-04-344 DOD Personnel Clearances 

functions and its 1,855 investigative employees to OPM.33 Before the 

transfer can occur, the Secretary of Defense must certify in writing to the 

House and Senate Armed Services Committees that the following five 

conditions have been met: 

• OPM is fully capable of carrying out high-priority investigations 

required by the Secretary of Defense within a time frame set by the 

Secretary of Defense; 

• OPM has undertaken necessary and satisfactory steps to ensure that 

investigations performed on DOD contract personnel will be conducted 

in an expeditious manner sufficient to ensure that those contract 

personnel are available to DOD within a time frame set by the 

Secretary of Defense; 

• DOD will retain capabilities in the form of federal employees to 

monitor and investigate DOD and contractor personnel as necessary to 

perform counterintelligence functions and polygraph activities of the 

department; 

• The authority to adjudicate background investigations will remain with 

DOD, and the transfer of DSS personnel to OPM will improve the speed 

and efficiency of the adjudicative process; and 

• DOD will retain within DSS sufficient personnel and capabilities to 

improve DOD industrial security programs and practices. 

The Director of OPM may accept the transfer, but such a transfer may be 

made only after a period of 30 days has elapsed from the date on which the 

defense committees receive the certification. 

Senior OPM officials recommended that the Director of OPM should not 

accept the transfer of DSS’s investigative functions and personnel, at least 

for the rest of fiscal year 2004. The OPM officials reported that OPM is not 

currently prepared to accept DSS’s investigative functions and staff 

because of concerns about financial risks associated with the authorized 

transfer. OPM stated that under its current system of contracting out all 

investigations, the contractor assumes all financial risk for completing 

investigations at agreed-upon prices. OPM does not believe that current 

productivity data for DSS staff is sufficient to indicate whether DSS staff 

could provide the services at the price that OPM charges its customers. 

Also, OPM believes that the documentation for the financial costs of 

automobile leases, office space, and so forth are not currently adequate to 

 33 Pub. L. 108-136 § 906 (Nov. 24, 2003). 

Current Status of the 

Authorized Transfer 
Page 26 GAO-04-344 DOD Personnel Clearances 

provide OPM with the assurance that it needs to accept 1,855 personnel 

into an agency that currently has about 3,000 employees—more than a 

60 percent growth in the number of OPM employees. 

In a memorandum of understanding that is being finalized at OPM and 

DOD, OPM is offering an alternative plan for DSS’s investigative 

functions and staff. While we were not provided a copy of the document, 

OPM officials described its contents to us orally. Among other things, the 

plan—if approved—would include the following: 

• DSS’s investigative functions and staff would remain part of DOD; 

• DSS’s investigative staff would receive training from OPM on the use of 

OPM’s investigative procedures and OPM’s investigations management 

system; and 

• OPM would allow DOD to use OPM’s investigations management 

system and thereby negate the need for DSS’s investigations 

management system, which an OUSD (I) official indicated could cost 

about $100 million to update and maintain over the next 5 years. 

A senior OPM official with whom we spoke was optimistic that the 

alternative plan will go to DOD for review and signature before the end of 

December 2003. If DOD proposes changes, the plan will need to undergo 

re-staffing at OPM and possibly DOD. OPM’s position described above was 

verified with the same OPM official on December 16, 2003. 

After learning of the alternative plan and the draft memorandum of 

understanding, we discussed both with an OUSD (I) official who has been 

a key negotiator with OPM. The official verified that OPM had voiced the 

concerns regarding risk and was preparing an alternative plan. That DOD 

official is optimistic that DOD will be able to provide the assurances that 

are needed for the authorized transfer to occur before the end of fiscal 

year 2004. DOD’s position was verified with the same OUSD (I) official on 

December 16, 2003. 

DOD continues to have a personnel security clearance backlog that 

probably exceeds roughly 360,000 cases by some unknown number. 

This situation may increase risks to national security and monetary 

costs associated with delays in granting clearances. DOD faces many 

impediments as it attempts to eliminate its backlog, and these weaknesses 

are material to the prompt completion of clearance requests at all stages of 

the personnel security process. The large number of clearance requests 

being submitted may be the impediment that is least amenable to change. 

Conclusions 
Page 27 GAO-04-344 DOD Personnel Clearances 

As we mentioned earlier, worldwide deployments, contact with sensitive 

equipment, and other security requirements underpin the need for 

personnel to be cleared for access to classified information. Other 

impediments to eliminating the backlog are formidable, but more 

tractable. Shortages of investigative and adjudicative staff prevent DOD 

from quickly completing cases in the existing backlog as well as the 

hundreds of thousands of new clearance requests that have been 

submitted during each of the last 3 years. Using the rough estimates 

provided by an OPM official, the shortage of over 3,500 full-time-equivalent 

investigative staff illustrates one area in the clearance process where 

supply of personnel is inadequate to meet the demand for services. DOD 

has not developed a strategic plan for overcoming problems in accessing 

information locally, at the state level, and overseas during investigations; 

and this lack of a strategy hinders DOD efforts to quickly complete cases 

and efficiently eliminate the clearance backlog. 

Basic to designing an efficient means for overcoming the impediments is 

obtaining and using accurate information regarding the backlog. Clear 

pictures of the backlog size will continue to be elusive if components 

continue to use varying backlog definitions and measures. The presence of 

a backlog of an imprecise size and impediments throughout the clearance 

process suggest systemic weaknesses in DOD’s personnel security 

clearance program. Key to generating those reports is the implementation 

of the overdue JPAS with its ability to track when reinvestigations are due. 

Because of continuing concerns about the size of the backlog and its 

accurate measurement and the personnel security clearance program’s 

importance to national security, we recommend that the Secretary of 

Defense direct the Under Secretary of Defense for Intelligence take the 

following four actions: 

• Identify and implement steps to match the sizes of the investigative and 

adjudicative workforces to the clearance request workload; 

• Develop a strategic plan for overcoming problems accessing data 

locally, at the state level, and overseas; 

• Develop DOD-wide backlog definitions and measures, and monitor the 

backlog at each of the three clearance-process stages using the 

DOD-wide measures; and 

• Complete the implementation of the Joint Personnel Adjudication 

System. 

Recommendations for 

Executive Action 
Page 28 GAO-04-344 DOD Personnel Clearances 

In written comments on a draft of this report, OUSD (I) concurred with 

three of our four recommendations and partially agreed with our 

recommendation to match workforces with workload. OUSD (I) noted 

that (1) DOD is developing tools to predict and validate investigative 

requirements; (2) staffing, budgeting, and management of the investigative 

and adjudicative resources are the purview of the affected DOD 

component and investigative providers; and (3) growing a capable 

workforce takes time. We agree with these points, but they do not change 

the fact that DOD has historically had a backlog and that these issues must 

be dealt with timely and effectively to eliminate the backlog. As our report 

points out, implementation delays—such as that with JPAS—hamper 

efforts to accurately estimate the backlog and eliminate it. While it is true 

that the resources provided by DOD components play an important role in 

eliminating the backlog, OUSD (I) also has a critical leadership role 

because of its responsibility for the coordination and implementation of 

DOD policy for accessing classified information. Finally, the historical and 

continuing void between workload demand and capacity suggests that 

OUSD (I) needs to take supplemental steps to grow capable investigative 

and adjudicative workforces as we have recommended. 

DOD’s comments are reprinted in appendix III. DOD also provided 

technical comments that we incorporated in the final draft as appropriate. 

As arranged with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 15 days from 

its issue date. At that time, we will send copies of this report to the 

Secretary of Defense, the Office of Management and Budget, and the 

Office of Personnel Management. We will also make copies available to 

appropriate congressional committees and to other interested parties on 

request. In addition, the report will be available at no charge at the GAO 

Web site at http://www.gao.gov. 

Agency Comments 

and Our Evaluation 
Page 29 GAO-04-344 DOD Personnel Clearances 

If you or your staff have questions about this report, please contact me at 

(202) 512-5559 or stewartd@gao.gov. Key staff members contributing to 

this report were Jack E. Edwards, Robert R. Poetta, Frank Bowen, and 

Nancy L. Benco. 

Sincerely yours, 

Derek B. Stewart 

Director, Defense Capabilities and Management 
Appendix I: Recent Recommendations Related 

to DOD’s Personnel Security Clearance 

Process 

Page 30 GAO-04-344 DOD Personnel Clearances 

This appendix lists the personnel clearance process recommendations 

found in recent reports from GAO, the DOD Office of Inspector General, 

and the House Committee on Government Reform. These verbatim 

recommendations are arranged according to the issuance dates of the 

reports. At the end of each set of recommendations, we provide comments 

on whether DOD concurred with the recommendations and the rationale 

for nonconcurrences. 

Recommendations from U.S. General Accounting Office, DOD 

Personnel: Inadequate Personnel Security Investigations Pose 

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

October 27, 1999. 

Because of the significant weaknesses in the DOD personnel security 

investigation program and the program’s importance to national security, 

we recommend that the Secretary of Defense direct the Assistant 

Secretary of Defense (Command, Control, Communications, and 

Intelligence) to 

• report the personnel security investigation program as a material 

weakness under the Federal Managers’ Financial Integrity Act to 

ensure that the needed oversight is provided and that actions are taken 

to correct the systemic problems in the Defense Security Service 

personnel security investigation program; 

• improve its oversight of the Defense Security Service personnel 

security investigation program, including approving a Defense Security 

Service strategic plan; and 

• identify and prioritize overdue reinvestigations, in coordination with 

other DOD components, and fund and implement initiatives to conduct 

these reinvestigations in a timely manner. 

In addition, we recommend that the Secretary of Defense instruct the 

Defense Security Service Director, with oversight by the Assistant 

Secretary of Defense (Command, Control, Communications, and 

Intelligence) to 

• develop a corrective action plan as required under the Federal 

Managers’ Financial Integrity Act that incorporates corrective actions 

and milestones for addressing material weaknesses in the Defense 

Security Service personnel security investigative program and 

performance measures for monitoring the progress of corrective 

actions; 

Appendix I: Recent Recommendations 

Related to DOD’s Personnel Security 

Clearance Process 
Appendix I: Recent Recommendations Related 

to DOD’s Personnel Security Clearance 

Process 

Page 31 GAO-04-344 DOD Personnel Clearances 

• establish a strategic plan that includes agency goals, performance 

measures, and procedures for tracking progress in meeting goals in 

accordance with sound management practices and the Government 

Performance and Results Act; 

• conduct analyses needed to (1) determine an appropriate workload 

that investigators and case analysts can manage while meeting federal 

standards and (2) develop an overall strategy and resource plan to 

improve the quality and timeliness of investigations and reduce the 

number of overdue reinvestigations; 

• review and clarify all investigative policy guidance to ensure that 

investigations comply with federal standards; 

• establish a process for identifying and forwarding to the Security Policy 

Board suggested changes to policy guidance concerning the 

implementation of the federal standards and other investigative policy 

issues; 

• establish formal quality control mechanisms to ensure that Defense 

Security Service or contracted investigators perform high-quality 

investigations, including periodic reviews of samples of completed 

investigations and feedback on problems to senior managers, 

investigators, and trainers; 

• establish a training infrastructure for basic and continuing investigator 

and case analyst training that includes formal feedback mechanisms to 

assess training needs and measure effectiveness, and as a high priority, 

provide training on complying with federal investigative standards for 

investigators and case analysts; and 

• take steps to correct the case management automation problems to 

gain short-term capability and develop long-term, cost-effective 

automation alternatives. 

Further, we recommend that the Secretary direct all DOD adjudication 

facility officials to (1) grant clearances only when all essential 

investigative work has been done and (2) regularly communicate with the 

Defense Security Service about continuing investigative weaknesses and 

needed corrective actions. 

DOD concurred with all of the recommendations and described many 

actions already planned or underway to implement the 

recommendations. 

Recommendations from U.S. General Accounting Office, More 

Actions Needed to Address Backlog of Security Clearance 

Reinvestigations, GAO/NSIAD-00-215, Washington, D.C., August 24, 

2000. 
Appendix I: Recent Recommendations Related 

to DOD’s Personnel Security Clearance 

Process 

Page 32 GAO-04-344 DOD Personnel Clearances 

To improve the management of DOD’s personnel security reinvestigation 

program, we recommend that the Secretary of Defense direct the Assistant 

Secretary of Defense (Command, Control, Communications, and 

Intelligence) to 

• design routine reports with key data from the Joint Personnel 

Adjudication System database to show the full extent of overdue 

reinvestigations, including those overdue but not yet submitted for 

update and those in process and 

• develop appropriate incentives to encourage agency security managers 

to keep information in the database current and to submit 

reinvestigation requests on time. Changes in existing regulations, 

policies, and procedures may be necessary to provide such incentives. 

DOD concurred with all of the recommendations. In their comments, 

DOD stated that those personnel who have not had a request for their 

periodic reinvestigation submitted to the Office of Personnel 

Management or the Defense Security Service by September 30, 2002, 

would have their security clearances downgraded or canceled. 

Recommendations from Department of Defense, Office of Inspector 

General Audit Report, Security Clearance Investigative Priorities, 

Report No. D-2000-111, Arlington, Va., April 5, 2000. 

• We recommend that the Assistant Secretary of Defense (Command, 

Control, Communications, and Intelligence) establish an Integrated 

Process Team to 

• Develop criteria for determining the highest priority mission-critical 

and high-risk positions based on their impact on mission-critical 

programs. The criteria must also include a review of the special 

projects at the Defense Security Service. 

• Develop a process for relating specific clearance requests to 

mission-critical and high-risk positions. This process must identify 

specific individuals as they are submitted for initial investigations 

and periodic reinvestigations. The process should continually adjust 

the highest priority mission-critical and high-risk positions to 

actions that may impact them. 

• We recommend that the Director, Defense Security Service, establish 

the process and metrics to ensure expeditious processing of personnel 

security clearance investigations in accordance with established 

priorities. 
Appendix I: Recent Recommendations Related 

to DOD’s Personnel Security Clearance 

Process 

Page 33 GAO-04-344 DOD Personnel Clearances 

The Assistant Secretary of Defense (Command, Control, 

Communications, and Intelligence) non-concurred with the first 

recommendation, stating that the recommendations are beyond the 

scope and ability of his Office to implement, especially in the near 

future. However, the Defense Security Service concurred with the intent 

of the recommendation. 

DOD and DSS concurred with the second recommendation. 

Recommendations from U.S. General Accounting Office, DOD 

Personnel: More Consistency Needed in Determining Eligibility 

for Top Secret Security Clearances, GAO/NSIAD-01-465, 

Washington, D.C., April 18, 2001.

1

To provide better direction to DOD’s adjudication facility officials, 

improve DOD’s oversight, and enhance the effectiveness of the 

adjudicative process, GAO recommends that the Secretary of Defense 

direct the Assistant Secretary of Defense (Command, Control, 

Communications, and Intelligence) to 

• establish detailed documentation requirements to support adjudication 

decisions, including all significant adverse security conditions and the 

mitigating factors relevant to each condition; 

• require that all DOD adjudicators use common explanatory guidance, 

such as that contained in the Adjudicative Desk Reference; 

• establish common adjudicator training requirements and work with the 

Defense Security Service Academy to develop appropriate continuing 

education opportunities for all DOD adjudicators; and 

• establish a common quality assurance program to be implemented by 

officials in all DOD adjudication facilities and monitor compliance 

through annual reporting. 

DOD concurred with all of the recommendations and described the 

actions it planned to take to improve its guidance, training, and quality 

assurance program. 

 1

 The recommendations from this report on DOD adjudication were included because 

(1) the adjudications rely heavily on high-quality, complete personnel security 

investigations and (2) the 2002 House Committee on Government Reform report 

recommended including the adjudicative portion of the clearance process as a material 

weakness. 
Appendix I: Recent Recommendations Related 

to DOD’s Personnel Security Clearance 

Process 

Page 34 GAO-04-344 DOD Personnel Clearances 

Recommendations from Department of Defense, Office of Inspector 

General Audit Report, Tracking Security Clearance Requests, 

Report No. D-2000-134, Arlington, Va., May 30, 2000. 

• We recommend that the Director, Defense Security Service, track all 

security clearance requests from the time they are received until the 

investigative cases are opened. Security clearance requests that are not 

opened to investigative cases, and those investigative cases that are 

opened without electronic requests should be included in the tracking 

process. 

• Post, weekly, the names and social security numbers of all cases in 

process on the Extranet for Security Professionals. This entry for each 

name should include, at a minimum, the date that the request was 

loaded into the Case Control Management System, the date that the 

investigative case was opened, and the date that the case was closed. 

DOD and DSS concurred on these recommendations. 

Recommendation from Department of Defense, Office of Inspector 

General Audit Report, Program Management of the Defense 

Security Service Case Control Management System, Report No. 

D-2001-019, Arlington, Va., December 15, 2000. 

We recommend that the Assistant Secretary of Defense (Command, 

Control, Communications, and Intelligence) and the Director, Defense 

Security Service, prior to making further decisions on the future system 

architecture, analyze whether the investment for the Case Control 

Management System and the Enterprise System provides the best business 

solution when compared to alternative solutions for opening, tracking and 

closing personnel investigation cases. 

DOD and DSS concurred with this recommendation. 

Recommendations from U.S. House of Representatives, Committee 

on Government Reform, Defense Security Service: The Personnel 

Security Investigations [PSI] Backlog Poses a Threat to National 

Security, Report 107-767, Washington, D.C., October 24, 2002. 

• The Secretary of Defense should continue to report the personnel 

security investigations program including the adjudicative process as a 

material weakness under the Federal Managers’ Financial Integrity Act 
Appendix I: Recent Recommendations Related 

to DOD’s Personnel Security Clearance 

Process 

Page 35 GAO-04-344 DOD Personnel Clearances 

to ensure needed oversight is provided to effectively manage and 

monitor the personnel security process from start to finish. 

• The Secretary of Defense should set priorities and control the flow of 

personnel security investigation requests for all DOD components. 

• The Secretary of Defense should closely monitor the interface between 

JPAS and CCMS to ensure effective management of investigative and 

adjudicative cases and avoid further backlogs. 

• The National Security Council should promulgate Federal standards for 

investigating and adjudicating personnel security clearances in a timely 

manner. 

• The Secretary of Defense and the Attorney General jointly should 

develop a system, which allows DSS and OPM investigators access to 

state and local criminal history information records. 

DOD indicated that it does not plan to respond to these 

recommendations. 
Appendix II: Scope and Methodology 

Page 36 GAO-04-344 DOD Personnel Clearances 

To estimate the size and accuracy of the Department of Defense-wide 

(DOD) personnel security clearance backlog, we obtained separate 

estimates of the investigative and adjudicative backlogs from the Defense 

Security Service (DSS), the Office of Personnel Management (OPM), and 

DOD’s central adjudication facilities. Also, we obtained some DOD-wide 

information from the Office of the Under Secretary of Defense for 

Intelligence (OUSD (I)). As part of the estimation process, we observed 

the steps used to capture and process investigative information at DSS and 

OPM. We obtained additional information regarding issues such as number 

of days required to complete an investigation or adjudication, time limits 

(i.e., criteria) for completing investigations and adjudications, and data 

reliability from DSS, OPM, and the central adjudication facilities during 

site visits, through questionnaires, and by interviews. We conducted this 

work at OUSD (I), Washington, D.C.; DSS, Fort Meade, Maryland; OPM, 

Washington, D.C., and Boyers, Pennsylvania; Army, Navy, Air Force, 

National Security Agency, Defense Intelligence Agency, Joint Staff, and 

Washington Headquarters Services central adjudication facilities located 

in the Washington, D.C., metropolitan area; the Defense Industrial Security 

Clearance Office, Columbus, Ohio; and the Defense Office of Hearings and 

Appeals, Arlington, Virginia, and Columbus, Ohio. We did not request data 

from the National Reconnaissance Office central adjudication facility 

because of the sensitive nature of its operations. Reviews of GAO, House 

Government Reform Committee, and Joint Security Commission reports 

provided a historical perspective for the report. Additional context for 

understanding DOD’s personnel security program was obtained through a 

review of DOD regulations (e.g., DOD 5200.2-R), federal investigative 

standards, and federal adjudicative guidelines. 

To identify the factors that impede DOD’s ability to eliminate its backlog 

and accurately estimate the backlog size, we reviewed prior GAO, DOD 

Office of Inspector General, House Government Reform Committee, 

Defense Personnel Security Research Center, and Joint Security 

Commission reports. DSS and OPM provided procedural manuals and 

discussed impediments while demonstrating their automated case 

management systems and provided other information such as workload 

data in responses to written questions and in interviews. Interviews 

regarding impediments were also held with officials from OUSD (I); nine 

central adjudication facilities; the Defense Personnel Security Research 

Center; the Chair of the Personnel Security Working Group of the National 

Security Council, Washington, D.C.; investigations contractors at their 

Appendix II: Scope and Methodology 
Appendix II: Scope and Methodology 

Page 37 GAO-04-344 DOD Personnel Clearances 

headquarters: US Investigations Services, Inc.; ManTech; and DynCorp; 

and associations representing industry:1

 Aerospace Industries Association, 

Information Technology Association of America, National Defense 

Industrial Association, and Northern Virginia Technology Council. Our 

General Counsel’s office supplied additional context for evaluating 

potential impediments through its review of items such as the Security 

Clearance Information Act and Executive Order 12968, Access to 

Classified Information. 

To identify the potential adverse effects of the impediments to eliminating 

the backlog and accurately estimating its size, we reviewed prior GAO and 

Joint Security Commission reports. We supplemented this information 

with recent data from DSS and OPM regarding the number of days that it 

took to complete various types of investigations. Also, an interview with 

the Chair of the Personnel Security Working Group of the National 

Security Council provided a governmentwide perspective on the effects of 

delays and backlogs. Industry representatives cited above provided other 

perspectives on the economic costs of delays in obtaining eligibility-forclearance determinations. 

For our update on the status of the authorized transfer of DSS’s 

investigative functions and staff to OPM, we reviewed the National 

Defense Authorization Act for Fiscal Year 2004 and GAO reports on DSS 

and OPM operations. In addition, we reviewed planning documents such 

as those describing the various transfer-related action teams that OPM and 

DOD created; these teams included one that sought to reconcile 

differences in the procedures used to conduct personnel security 

investigations. We also conducted interviews in December with DOD and 

 1

 Information from industry associations was obtained as part of an ongoing GAO 

engagement examining DOD’s personnel security clearance process as it applies to 

industry personnel. More specifically, the engagement examined the size of the backlog, 

timeliness of eligibility-for-clearance decisions, and steps that DOD is taking to decrease 

the time required for those decisions. 
Appendix II: Scope and Methodology 

Page 38 GAO-04-344 DOD Personnel Clearances 

OPM to determine up-to-date perspectives regarding the authorized 

transfer from officials representing both agencies. 

We conducted our review from February 2003 through December 2003 in 

accordance with generally accepted government auditing standards. 
Appendix III: Comments from the Department 

of Defense 

Page 39 GAO-04-344 DOD Personnel Clearances 

Appendix III: Comments from the 

Department of Defense 
Appendix III: Comments from the Department 

of Defense 

Page 40 GAO-04-344 DOD Personnel Clearances 
Appendix III: Comments from the Department 

of Defense 

Page 41 GAO-04-344 DOD Personnel Clearances 

Note: Page numbers in 

the draft report may differ 

from those in this report. 
Appendix III: Comments from the Department 

of Defense 

Page 42 GAO-04-344 DOD Personnel Clearances 
Appendix IV: Related GAO Products 

Page 43 GAO-04-344 DOD Personnel Clearances 

DOD Personnel: More Consistency Needed in Determining Eligibility for 

Top Secret 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. 

Military Recruiting: New Initiatives Could Improve Criminal History 

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

Background Investigations: Program Deficiencies May Lead DEA to 

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

September 7, 1999. 

Executive Office of the President: Procedures for Acquiring Access 

to and Safeguarding Intelligence Information. GAO/NSIAD-98-245. 

Washington, D.C.: September 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. 

Personnel Security: Pass and Security Clearance Data for the 

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

October 19, 1995. 

Appendix IV: Related GAO Products 
Appendix IV: Related GAO Products 

Page 44 GAO-04-344 DOD Personnel Clearances 

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.: Aug. 12, 1993. 

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. 

Personnel Security: Efforts by DOD and DOE to Eliminate 

Duplicative Background Investigations. GAO/RCED-93-23. 

Washington, D.C.: May 10, 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. 

Security Clearances: Due Process for Denials and Revocations by 

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

May 6, 1992. 

Due Process: Procedures for Unfavorable Suitability and Security 

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

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