Office of Inspector General 

DEPARTMENT OF HOMELAND SECURITY 

A Review of Background Checks for 

Federal Passenger and Baggage 

Screeners at Airports 

OIG-04-08 January 2004

Office of Inspections, Evaluations, & Special Reviews 
 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was established by 

the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector General 

Act of 1978. This is one of a series of audit, inspection, investigative, and special reports prepared 

by the OIG periodically as part of its oversight responsibility with respect to DHS to identify and 

prevent fraud, waste, abuse, and mismanagement. 

This report is the result of an assessment of the strengths and weaknesses of the program, operation, 

or function under review. It is based on interviews with employees and officials of relevant agencies 

and institutions, direct observations, and a review of applicable documents. 

The recommendations herein, if any, have been developed on the basis of the best knowledge 

available to the OIG, and have been discussed in draft with those responsible for implementation. It 

is my hope that this report will result in more effective, efficient, and/or economical operations. I 

express my appreciation to all of those who contributed to the preparation of this report. 
Contents 

 Introduction.................................................................................................................................... 1 

Results in Brief .............................................................................................................................. 1 

 Background.................................................................................................................................... 3 

Purpose, Scope, and Methodology................................................................................................. 6 

Designating the Level of Risk and Depth of Investigation for Screener Positions ....................... 7 

Completing Screener Background Checks .................................................................................. 13 

Verifying Citizenship and Personal Identification....................................................................... 27 

Managing the Personnel Security Program.................................................................................. 28 

Appendices 

Appendix A: Management Comments ................................................................................ 37 

 Appendix B: OIG Evaluation of Management Comments.................................................. 49 

 Appendix C: Recommendations............................................................................................56 

Appendix D: 28 Disqualifying Convictions ....................................................................... 58 

Appendix E: Major Contributors to This Report ................................................................ 60 

Appendix F: Report Distribution ........................................................................................ 61 

Abbreviations 

 

ANACI Access National Agency Check and Inquiries 

ATSA Aviation and Transportation Security Act 

BI Background Investigation

BITS Background Investigation Tracking System

CITS Clearance Investigations Tracking System

COR Contracting Officer Representative

CPO TSA Credentialing Program Office 

DHS Department of Homeland Security 

DOT Department of Transportation 

FAIR Act Federal Activities Inventory Reform Act 

FBI Federal Bureau of Investigation 

FSD TSA Federal Security Director 

I-9 Employment Eligibility Verification Form

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page i 
Contents 

MBI Minimum Background Investigation 

NACI National Agency Check and Inquiries 

OF 306 Declaration for Federal Employment 

OIG Office of Inspector General 

OPF Official Personnel Folder 

OPM Office of Personnel Management 

SF 85P Questionnaire for Public Trust Positions 

SF 86 Questionnaire for National Security Positions 

SSBI Single Scope Background Investigation 

TSA Transportation Security Administration

USIS U.S. Investigations Services 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page ii 
OIG ISP 

Report

Department of Homeland Security 

Office of Inspector General 

 

Introduction 

 

In response to the September 11, 2001, terrorist attacks in the United States 

and in recognition of the potential for future attacks, Congress enacted the 

Aviation and Transportation Security Act, Public Law No. 107-71 (ATSA), 

which established the Transportation Security Administration (TSA). In 

February 2002, TSA officially assumed responsibility for civil aviation 

security functions and, in accordance with ATSA, began the task of hiring 

federal employees to perform passenger and baggage screening functions 

previously conducted by private sector employees hired by the aircraft and 

airport operators. 

Between February 2002 and December 2002, TSA reviewed an estimated 1.7 

million applications to hire 55,600 new federal appointees, successfully 

meeting congressionally mandated deadlines of November 19 and December 

31, 2002, for replacing commercial passenger and baggage screeners, 

respectively.1

 However, reports surfaced soon afterward that the background 

checks for screeners, which ATSA requires, were incomplete and possibly 

flawed. In response to these reports, the Office of Inspector General (OIG) 

initiated this review of screener background checks. 

Results in Brief 

TSA completed up to four background checks on each of 55,600 screener 

appointees and thousands of unsuccessful applicants—totaling over 360,000 

checks.2

 Although contractors performed the checks and helped TSA review 

most results, TSA was responsible for managing the contractors’ work, 

tracking background check progress and completion, making final suitability 

decisions, and terminating employees who failed the checks. The deadlines 

were short, and the scale of hiring was large. Despite contractor support, TSA 

was not able to manage the background checks in an orderly and consistent 

manner. We identified many issues that undermined the creation of a reliable 

federal screener staff that can ensure the security of commercial air 

transportation. 

1

 House Appropriations Subcommittee for Homeland Security, Hearing on TSA Screener Background Investigations, 

June 3, 2003. 

2

 In May 2003, TSA calculated the following totals for background checks completed: 122,508 fingerprints and 57,173 

Access National Agency Check and Inquiries (ANACIs) as of May 16, 2003; and 100,567 ChoicePoint Phase 1 checks 

and 84,613 ChoicePoint Phase 2 checks as of March 21, 2003. 
Managing the volume of checks overtaxed TSA’s personnel security office. 

Screeners were hired, trained, and, in some cases, put to work contrary to 

sound personnel security practices and the provisions of ATSA. We found 

that: 

• TSA did not assign an official position risk designation for screeners. 

Consequently, TSA either chose an appropriate, inadequate, or 

excessive level of investigation. 

• TSA did not maintain control over the quantity, quality, and timeliness 

of background check documentation and processing. TSA did not 

initiate timely final background checks and initiated unnecessary 

background checks on thousands of screeners. TSA’s inadequate 

oversight of its contractors contributed to more than 500 boxes of 

background check documentation remaining unprocessed for months. 

• TSA allowed some screeners to work without first completing a 

criminal history records check, and retained others with adverse 

background checks for weeks or months while processing the results 

of the background checks and terminations. 

• TSA’s personnel security office did not: (1) develop a comprehensive 

plan to administer the background checks effectively; (2) have 

sufficient staff to meet workload demands; (3) provide sufficient 

oversight of the contractors’ performance; and (4) develop an adequate 

information tracking system to manage the process. 

On June 3, 2003, the House Appropriations Subcommittee for Homeland 

Security directed TSA to eliminate the backlog of screener background checks 

by October 1, 2003. To meet the deadline and remove unsuitable screeners, 

TSA reorganized its personnel security office, added staff and contractor 

support, began developing policies, and modified several of its procedures. As 

of October 1, 2003, TSA substantially eliminated the backlog of cases. 

To improve its management of the background check process, we recommend 

that the TSA Administrator: 

1. Assign official position risk designations for all screeners; 

2. Complete the planned comparison of Office of Personnel Management 

and private sector background checks; 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 2 
 

3. Ensure that all screeners pass a fingerprint-based criminal history 

records check before beginning training and work; 

4. Resolve what role contract adjudicators perform and how TSA will 

oversee them; 

5. Improve controls to protect against terminations that are based on 

inaccurate information; 

6. Establish mechanisms to avoid further background checks on 

disqualified screeners; 

7. Strengthen procedures for processing the Employment Eligibility 

Verification Form (Form I-9). 

8. Adopt personnel security management policies and document 

departures from them; 

9. Improve workforce planning and staffing in the Credentialing Program

Office; 

10. Improve oversight of contract performance and costs; 

11. Develop accurate, timely, and integrated data on the status of security 

investigations; and 

12. Improve records management policies, procedures, and practices for 

the maintenance of personnel security case files. 

Background 

On November 19, 2001, Congress enacted the Aviation and Transportation 

Security Act, which established the Transportation Security Administration 

within the Department of Transportation (DOT).3 The ATSA directed TSA to 

hire federal employees to serve as passenger screeners by November 19, 2002, 

and baggage screeners by December 31, 2002. TSA met the formidable 

deadlines, hiring approximately 55,600 screeners.4

 During the height of its 

3

 TSA became part of the Department of Homeland Security on March 1, 2003. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 3 

4

 Counting employees has been an ongoing challenge for TSA due to discrepancies between the figures maintained by

TSA’s hiring contractors, TSA offices, and the Office of Personnel Management. 
 

activity in autumn 2002, TSA and its supporting contractors hired 

approximately 5,000 screeners per week. 

ATSA requires that screeners undergo a background investigation, including a 

criminal history records check and a review of available law enforcement 

databases and records of other governmental and international agencies to the 

extent determined practicable by the Under Secretary of Transportation for 

Transportation Security. TSA must ensure that screeners are U.S. citizens and 

have no convictions within the past ten years for any of 28 specific 

disqualifying felonies (see Appendix D). In addition, TSA must ensure that 

screeners are otherwise suitable for employment. 

TSA did not have an office equipped to meet the responsibilities imposed by 

ATSA. In 2001, DOT established a “Go-Team” committee for personnel 

security management to plan and initiate this background check process. With 

DOT support, TSA began to establish its own Office of Security in March and 

April 2002, although the checks had already begun. Four months later, in July 

2002, TSA hired the chairman of the Go-Team to direct the office. The Office 

of Security assumed full responsibility for personnel security functions in 

November 2002. Then, in May 2003, TSA moved the personnel security 

function out of the agency’s administrative branch and established it as part of 

a new Credentialing Program Office (CPO) under the TSA Chief of Staff. 

Partly because of its small personnel security infrastructure, TSA relied upon 

several public and private entities to help administer background checks. TSA 

obtained their services through a variety of contracts. These entities included 

the Office of Personnel Management (OPM); ChoicePoint5

; Systems Research 

and Development, a ChoicePoint subcontractor; DynCorp Systems & 

Solutions LLC; U.S. Investigations Services, Inc. (USIS); and NCS Pearson 

and its subcontractor PEC Solutions, Inc.6

 The pieced-together network lacked 

an organizational coherence that would have eased TSA’s management 

responsibilities. 

NCS Pearson assessed applicants and offered conditional employment; 

collected and submitted the documentation for the background checks; and 

maintained the screener staffing rosters used to initiate checks. PEC Solutions, 

Inc., collected and submitted electronic fingerprints, which OPM checked 

against national criminal history databases, including that of the Federal 

Bureau of Investigation (FBI). Using suitability criteria provided by TSA, 

5

 In October 2003, Kroll Government Services, Inc., replaced ChoicePoint.

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 4 

6

 In January 2003, CPS Human Resource Services and Accenture L.L.P. replaced NCS Pearson. 
 

DynCorp evaluated the results of background checks conducted by 

ChoicePoint and OPM checks to make recommendations whether screeners 

posed an acceptable risk to the government. This evaluation process is known 

as an “adjudication.” USIS investigated employees as an OPM contractor, but 

it also supported TSA directly by helping employees complete suitability 

forms, building electronic and paper personnel security files, and adjudicating 

cases. Systems Research and Development assisted ChoicePoint by checking 

applicants against a network of threat indices. 

OPM timelines for the conduct of background checks would predict that the 

check for a screener hired in December would be complete by late June. As of 

May 31, 2003, more than half of the screener pool had at least one check 

outstanding. In total, 38,065 of 160,515 checks required additional processing 

or adjudication.7

 TSA’s Administrator and supporting contractors agreed 

before the subcommittee to meet the following deadlines: 

• ChoicePoint would complete all of its Phase 1 checks by June 15; and 

DynCorp and TSA would adjudicate them by July 1. 

• OPM would complete all in-process Access National Agency Check & 

Inquiries (ANACIs) by August 15. OPM would complete ANACIs not 

yet scheduled within 70 days of receiving the request from TSA. 

• TSA, with support from DynCorp and other contractors, would 

adjudicate all remaining ANACIs and terminate screeners found 

unsuitable by October 1, 2003. 

ChoicePoint, DynCorp, and OPM projected that they could complete their 

respective workloads and enable TSA to meet the October 1 deadline if they 

received cases within agreed upon timeframes. TSA reported that it 

substantially met the deadlines.8

7

 With 53,505 screeners employed as of May 31, 2003, TSA had a total of 160,515 fingerprint, ChoicePoint Phase 1, and 

ANACI checks to complete and adjudicate. Of the 160,515 checks, TSA reported that it had not yet completed 29,700 (1, 

015 fingerprint checks, 573 ChoicePoint Phase 1 checks, and 28,112 ANACI checks). In addition to these 29,700

incomplete checks, TSA and DynCorp needed to adjudicate thousands of completed checks. The ChoicePoint Phase 2

checks are not included in these numbers because TSA did not plan to complete the 41,076 outstanding ChoicePoint

Phase 2 checks by the October 1, 2003, deadline. TSA shifted its priorities away from the ChoicePoint Phase 2 checks in

March 2003. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 5 

8

 On September 26, 2003, TSA reported to the OIG that it met the October 1, 2003, deadline and had adjudicated all 

ANACIs for the 53,505 screeners employed as of May 1, 2003, with two exceptions. The results included 246 

incomplete cases for screeners on military leave and extended sick leave and 205 “interim eligible” cases based on 

partial ANACIs that OPM must first complete. 
Purpose, Scope, and Methodology 

The purpose of our review was to determine whether TSA processed 

background checks of its passenger and baggage screeners in an efficient and 

effective manner and according to applicable laws, federal regulations, 

guidelines, and standards. The scope of our review focused on background 

checks of passenger and baggage screeners and included administrative and 

programmatic activities from November 2001 to August 2003. 

We conducted interviews with staff from TSA, OPM, the Department of 

Justice, and four TSA contractors. At TSA, the combination of newly-arrived 

staff, job reassignments, and recent departures within the personnel security 

office complicated our attempt to gather insight on the full span of TSA’s

personnel security management efforts. 

We had planned a review of TSA’s personnel security files in order to assess 

the timeliness and effectiveness of different phases of the background checks 

and how well TSA’s hiring process met ATSA requirements. Specifically, we 

had planned to review: 

• TSA’s control and approval of forms used for background checks; 

• Efficiency of fingerprinting process; 

• Length of time to complete background checks; 

• Evidence that background checks were satisfactorily completed; and 

• TSA’s adherence to adjudication standards. 

However, TSA was in the process of organizing its first personnel security 

filing system, and headquarters files were inconsistent and incomplete. While 

we could not obtain a statistical sample of files, we reviewed a judgmental 

sample of background check documentation. This consisted of background 

check files or loose packets for 255 screeners and the corresponding 

fingerprint checks. Because TSA had not established uniform requirements for 

file content, some of our tests were limited to smaller samples based on the 

information available. We have reported sample size where appropriate. 

We also reviewed 25 Official Personnel Folders (OPFs) to determine whether 

TSA obtained adequate evidence of identity and citizenship. In addition, we 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 6 
 

compared the results of one airport operator’s checks of screener fingerprints 

against TSA’s fingerprint adjudications for the same employees, as contained 

in its Clearance Investigations Tracking System (CITS). 

Our inspection was conducted under the authority of the Inspector General 

Act of 1978, as amended, and according to the Quality Standards for 

Inspections issued by the President’s Council on Integrity and Efficiency, the 

association of federal Inspectors General. 

Designating the Level of Risk and Depth of Investigation for Screener 

Positions 

As an essential first step in planning background checks, agencies evaluate 

how much risk to the efficiency of the federal service or to the national 

security is involved in a job position. The evaluation leads to a written 

position risk designation. The position risk designation guides the decision on 

what kind of background checks an individual must pass to hold the position. 

TSA was unable to provide a position risk designation record for screeners. 

Moreover, TSA has made conflicting statements about which position risk

designation it is using for screeners. 

Risk determinations are based on two assessments. First, the agency assigns a 

suitability designation; this reflects the degree to which an unsuitable 

employee could harm the efficiency of federal service. Second, the agency 

assigns a security designation; this reflects the degree of damage to national 

security that an employee in a certain position could cause. The security

designation corresponds with the level of security clearance an employee may 

have for access to classified information. Generally, the security designation 

will determine the level of background investigation, although a higher 

suitability designation can be the determinant. Thus, while an agency makes 

two determinations on each position, one will determine the background 

check requirement. According to the DOT personnel security management

policies that TSA adopted, TSA should have solicited input from the 

personnel security office, Human Resources Office, and Aviation Operations 

before determining suitability and security designations. 9

The following table shows a simplified version of the DOT designations and 

investigation requirements that applied to TSA during FYs 2002-03: 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 7 

9 Personnel Security Management Manual (Department of Transportation Manual 1630.2b, May 30, 2001). The 

Department of Homeland Security plans to issue its own policy that will affect TSA in FY 2004. 
Suitability and Security 

Risk Designations 

Minimum 

Investigation 

Required10

Cost & 

Time 

per 

case11

Low Risk: Positions that involve responsibilities of limited 

relation to an agency or program mission, so the potential for 

impact on the integrity and efficiency of the service is limited. 

National Agency 

Check & Inquiries

(NACI)

$85 

75 

days 

Moderate Risk: Positions with the potential for moderate to 

serious impact on the integrity and efficiency of the service. 

Includes mid-level positions with responsibility for semiindependent action and positions delivering services that 

demand the public confidence or trust. 

NACI 

$85 

75 

days 

S 

U 

I 

T 

A 

B 

I 

L 

I 

T 

Y 

SF 

85P 

High Risk: Positions with the potential for exceptionally 

serious impact on the integrity and efficiency of the service. 

Includes positions with authority for independent action and 

positions with law enforcement, fiduciary, public contact, or 

other duties demanding the highest degree of public trust. 

Background 

Investigation (BI) 

$2,410 

120 

days 

Non-sensitive: Any position that has limited potential for 

adversely affecting an agency’s national security operations. 

Investigate according to 

suitability designation 

Non-critical Sensitive: Any position with the potential for 

significant or serious damage to the national security. 

Enables agency to grant confidential and secret clearances. 

Access National 

Agency Check &

Inquiries (ANACI) 

$130 

75 

days 

Critical Sensitive: Any position with the potential for 

exceptional or grave damage to the national security. 

Enables agency to grant top secret clearances. 

BI 

$2,410 

120 

days 

S 

E 

C 

U 

R 

I 

T 

Y 

SF 

86 

Special Sensitive: Any position an agency head determines 

to be at a higher level than Critical-Sensitive due to special 

requirements, such as need for access to sensitive 

compartmented information. 

Single Scope 

Background 

Investigation 

(SSBI) 

$2,725 

120 

days 

TSA staff was unable to provide the position risk designation record for TSA 

screeners.12 According to the DOT policy, both Aviation Operations and the 

Human Resources Office should have copies of the position risk designation 

records. TSA’s position descriptions and vacancy announcements also should 

reflect the designation. Notwithstanding the absence of this record, we found 

evidence of four different possible risk designations. In documentation 

prepared for the June 3, 2003, congressional hearing, TSA reported that the 

 

10 Ibid. 11 Costs are based on OPM prices for standard service during FY 2002, the period when TSA planned and began 

screener background checks. Time per case is approximate. OPM offers faster service for a fee, but in general, its 

investigations have encountered delays over the past two years due to an escalating volume of requests. Investigations

that require field investigation in addition to automated checks, such as the MBI and SSBI, have incurred greater delays. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 8 

12 TSA’s position risk designation record should be DOT Form 1630.2b. For many agency positions, TSA instead used

the position designation record from Appendix B of OPM’s Suitability Processing Handbook. However, TSA staff was 

unable to provide either form for screeners. 
designation is moderate risk and non-sensitive. Moderate risk is also the risk 

level that TSA coded on the background check form for screeners, the 

Questionnaire for Public Trust Positions (SF 85P). A second TSA designation 

appeared in a July 2003 vacancy announcement for part-time screeners, which 

increased the security risk from non-sensitive to critical sensitive. Following 

discussion with OIG inspectors, TSA deleted the critical sensitive designation 

from the announcement. A third variation appeared in job descriptions posted 

on the TSA website, which stated that screeners’ duties and responsibilities 

include “participat[ing] in information briefings concerning security-sensitive 

or classified information.” The responsibility would require a minimum 

security designation of non-critical sensitive. A fourth variation was noted in a 

September 2003 vacancy announcement, which labeled the positions as “Code 

1 public trust,” an OPM indicator that translates to low risk and non-sensitive, 

the lowest possible designation. 

Choosing the Investigation Type

TSA’s choice among the low risk, moderate risk, and non-critical sensitive 

designations has an impact on which background check the agency must 

conduct. In other words, TSA’s choice between the different types of 

investigations and supporting forms affected the depth of the background 

check and thus the level of security provided.

If low or moderate risk is the correct designation, TSA could have selected the 

NACI for screeners and conformed to DOT policy. The ANACI investigation 

that TSA chose is more intensive than the NACI. The ANACI adds a credit 

search and a field investigation of local law enforcement records, if the 

locality does not respond to a written inquiry. Interestingly, OPM 

recommends a more intensive investigation than DOT for moderate risk 

positions: the Minimum Background Investigation (MBI), which surpasses 

both the NACI and ANACI, adds a field investigator’s interview with the 

subject. The Chief of the Department of Homeland Security (DHS) Personnel 

Security Division said that DHS plans to require an MBI or a higher level of 

investigation for all its employees, including the TSA screeners, starting in FY 

2004. If non-critical sensitive is the correct designation, TSA’s ANACI 

investigation meets DOT, OPM, and DHS standards, with one qualification.13

The ANACI is used across the government for positions designated noncritical sensitive and requiring a security clearance. Agencies typically collect 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 9 

13 The DHS Personnel Security Division has proposed non-critical sensitive as the minimum designation for all DHS 

personnel in order to ensure all DHS employees are eligible for a secret clearance. DHS will accept the ANACI for 

employees investigated before October 1, 2003, according to its draft Interim Personnel Security Directive. 
information for the ANACI with the Questionnaire for National Security 

Positions (SF 86). However, TSA screeners used the Questionnaire for Public 

Trust Positions (SF 85P), which collects less detailed information about the 

subject’s foreign activities; relatives and associates; substance abuse history; 

and medical, military, court, and police records. With the SF 85P, the 

adjudicator receives less information to evaluate when deciding whether the 

screener poses acceptable risk to the government. To date, TSA has not 

granted security clearances to screeners. If TSA decides in the future to grant 

clearances to screeners, each will first have to complete the more detailed SF 

86, according to DOT and draft DHS policies. 

Costs vary for each investigation type. The cost differences between 

performing a NACI, ANACI, or MBI on all TSA screeners are in the millions 

of dollars. For 55,600 screeners, the difference between the NACI ($85) and 

ANACI ($130) is more than $2.5 million. The MBI ($405) costs about three 

times as much as the ANACI, a cost difference exceeding $15.2 million.

Adopting the MBI as a minimum investigation in FY 2004 could create a 

significant financial burden for DHS components. 

Investigation Options Outside OPM Services

The fingerprint check and ANACI generally met the background check 

requirements in ATSA. However, with the help of a contractor, TSA took 

another step to reduce the risk that a screener was connected to terrorist 

organizations. The contractor, ChoicePoint, added a feature called “link 

analysis.” In link analysis, ChoicePoint and its subcontractor Systems 

Research and Development compared information from ChoicePoint’s 

proprietary database with TSA, FBI, and publicly available terrorist 

watchlists. ChoicePoint also helped TSA meet its rapid hiring objectives by 

returning results from criminal history and credit checks weeks faster than the 

OPM ANACI did. 

TSA planned to use ChoicePoint’s Phase 1 check, where ChoicePoint

performed the link analysis, along with OPM’s fingerprint check to eliminate 

unsuitable applicants before hiring them. TSA would complete the remaining 

two checks on screeners after hiring. A complete background check consisted 

of four elements: 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 10 
Check Content Speed 

1. OPM fingerprint check FBI national criminal history records check 2-3 days 

2. ChoicePoint Phase 1 Name-based proprietary database and local 

criminal history checks; credit check; link analysis 

against selected terrorist watchlist databases 

7-10 days 

3. ChoicePoint Phase 2 Telephonic employment, education, and reference 

checks 

10-21 days 

4. OPM ANACI National agency records check incorporating 

fingerprint results; credit and local criminal history 

checks; written employment, education, and 

reference checks; citizenship verification 

45-70 days 

or longer 

With slight differences, both ChoicePoint and OPM checked the screener’s 

credit history; local law enforcement records; and education, employment, and 

references. In August 2002, the current, acting Director of TSA’s CPO and the 

former Director of the Office of Security notified the TSA Administrator of

the duplication between these checks. They proposed that TSA quickly 

complete a comparison study to determine which provider to use because 

“TSA does not have the money to pay for ‘duplicate’ investigations or to add 

the staff required to process, monitor, coordinate, adjudicate, and perform all 

the related tasks required to run a full-service security office.”14 TSA has not 

completed the comparison study. In March 2003, TSA shifted its processing 

emphasis from the ChoicePoint Phase 2 check to the ANACI, but some

overlap remains. 

TSA may be on a collision course with DHS regarding the extent to which it 

must use OPM investigations. TSA is contemplating ceasing to use OPM 

services altogether. The central question is whether ATSA exempts TSA from

Executive Order 10450, Security Requirements for Government Employment. 

TSA believes it does. In May 2003, the TSA Office of Chief Counsel wrote 

that TSA is not required to use OPM investigations. According to ATSA and 

49 U.S.C. 44936, screeners must undergo “an employment investigation, 

including a criminal history records check and a review of available law 

enforcement data bases and records of other governmental and international 

agencies to the extent determined practicable by the Under Secretary of 

Transportation for Transportation Security.” TSA interprets this and other 

portions of its statute to grant the TSA Administrator broad flexibility to 

determine the scope of screener background checks, including freedom not to 

use OPM’s services. 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 11 

14 Besides increasing costs, the duplicate checks increase the burden on TSA to submit the request paperwork, monitor

the process, and review the results in order to approve or disapprove the screener. 
On the other hand, both DOT policy and the draft DHS Interim Personnel 

Security Directive set OPM investigations as their minimum. Their 

requirements are based in part on section 3(a) of Executive Order 10450, 

which requires agencies at a minimum to conduct national agency checks and 

inquiries for all government civilian employees. OPM’s NACI investigation 

satisfies this requirement, because it includes a search of OPM’s 

Security/Suitability Investigations Index, the Department of Defense 

Clearance Investigations Index, and FBI fingerprint- and name-based files. 

Private sector background checks do not include these searches, and TSA does 

not have the infrastructure in place to collect this information itself. According 

to the DHS Personnel Security Division Chief, TSA must meet Executive 

Order 10450 standards by conducting the national agency checks. 

Whether or not ATSA exempts TSA from the Executive Order, TSA does not 

have to avail itself of the exemption. It can enhance the security of its 

background check process by taking account of the derogatory information 

that national agency checks reveal. However, TSA must first resolve the issue 

of what background checks satisfy requirements for the position risk 

designation it chooses. It might be possible for TSA to combine private sector 

background checks with national agency checks in a way that meets EO 

10450 and DHS standards, enhances security, and promotes cost efficiency by 

eliminating duplication. 

We recommend that the TSA Administrator: 

Recommendation 1: Complete screener position risk designations with input 

from the personnel security officials of the Department of Homeland Security 

and from appropriate TSA offices, including the Credentialing Program

Office, Human Resources Office, and Aviation Operations. Screener position 

risk designation records, position descriptions, and vacancy announcements 

should reflect the correct designation. 

Recommendation 2: Complete the comparison study of the effectiveness of 

Office of Personnel Management and private sector background checks. 

Incorporating the review’s results, the Administrator should modify screener 

background checks as needed to ensure they suit the position risk designation, 

meet Department of Homeland Security standards, and are cost-efficient. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 12 
Completing Screener Background Checks 

The four background checks that TSA chose fit into a larger framework to 

make up TSA’s background check process. Overall, the process consisted of 

four steps: 1) collecting applicants’ background information; 2) performing 

the four background checks; 3) evaluating the results of the checks to decide 

whether the screener posed acceptable risk to the government (adjudication); 

and 4) disseminating the results so that disapproved employees did not train or 

work. The following table shows generally how TSA and its supporting 

contractors completed the steps:

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 13 
c Collecting 

information 

d Checking 

backgrounds 

e Evaluating the results of 

the checks (adjudication) 

f Disseminating 

the results 

OPM 

Fingerprint 

NCS Pearson’s 

subcontractor, 

PEC Solutions, 

collected electronic 

fingerprints from

applicants and 

sent them to OPM. 

OPM compared fingerprints with the 

FBI’s national criminal history 

database and returned results to 

TSA electronically. 

Reviewing results through an 

Internet database, TSA 

adjudicators decided to approve 

or disapprove the screener. 

ChoicePoint 

Phase 1 

ChoicePoint used “link analysis” to

compare the screener with selected 

terrorist watchlists. ChoicePoint 

also checked the screener against 

its proprietary database, collected

local law enforcement records, and 

ran a credit check. 

 ChoicePoint 

Phase 2 

Applicants 

completed the SF 

85P, which NCS 

Pearson reviewed 

and sent to 

ChoicePoint as an 

electronic copy.

ChoicePoint telephoned employers, 

references, and schools. 

ChoicePoint posted cases to an 

Internet database. DynCorp 

adjudicated cases as ineligible, 

decisional, or eligible. DynCorp 

printed the first two types for 

TSA adjudicators to review and 

provide final approval or 

disapproval. 

OPM 

ANACI 

NCS Pearson sent 

to OPM the 

applicant’s original, 

paper copy of the 

SF 85P, along with 

a copy of the 

Declaration for 

Federal 

Employment (OF 

306) and 

employment 

application. 

OPM entered information from the 

SF 85P into its automated system

and sent inquiries to local law 

enforcement agencies, employers, 

schools, and others. OPM 

incorporated the fingerprint results 

and ran a credit check. OPM also 

requested records from state 

bureaus of vital statistics and the

Departments of Defense, State, 

Justice (FBI), and Homeland 

Security (Bureau of Citizenship and 

Immigration Services). OPM mailed 

completed packets to TSA. 

TSA sent the ANACI packets to 

DynCorp, which adjudicated 

them as ineligible, decisional, or 

eligible before returning the 

packet to TSA. TSA 

adjudicators made the final 

decision to approve or 

disapprove cases that DynCorp 

adjudicated as ineligible or 

decisional. TSA also reviewed 

some of DynCorp’s eligible 

cases. In July 2003, TSA added 

U.S. Investigations Services to 

adjudicate along with DynCorp. 

After approving 

screeners’ fingerprint 

and ChoicePoint

Phase 1 checks, TSA 

requested that the 

Department of 

Transportation print 

and deliver access 

badges so the 

employees could 

begin training and 

work. 

For employees who 

failed checks, TSA’s 

personnel security 

office sent written 

requests for 

termination to TSA’s 

Human Resources 

Office. The Human 

Resources Office 

wrote and sent 

termination letters for 

Federal Security 

Directors to deliver to 

screeners. 

Upon request, TSA’s 

personnel security 

office compiled and 

sent reports to airports 

on the status of 

screener background 

checks. 

 

This process set a more rigorous background check standard than had been in 

place for screeners. Before TSA established its screener workforce, only the 

fingerprint check was required.15 TSA used its authority under ATSA to set 

new standards for screener background checks. As we have described, TSA 

has argued that it is not obliged to meet standards in OPM’s suitability 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 14 

15 Rules issued after 9/11 required the fingerprint check to be conducted routinely. Prior to 9/11, the airlines had to

conduct an employment investigation, and if the results warranted, an FBI fingerprint-based criminal history records

check. 
regulations and Executive Order 10450. We have nevertheless referred to 

these standards in order to illustrate requirements and handling times that are 

considered reasonable and applicable throughout government. We also refer to 

the standards set for background checks on the commercial screeners before 

TSA’s hiring of federal screeners. 

During the hiring process, TSA gave applicants a conditional job offer, 

pending approval of background checks. TSA planned to require employees to 

pass the OPM fingerprint and ChoicePoint Phase 1 checks before beginning 

training, receiving a badge, and working in the airport. TSA expected these 

two checks would reduce the risk of employing screeners who had links to 

terrorist organizations or who had criminal histories covered by the 28 

disqualifying convictions, while still enabling TSA to meet its November and 

December 2002 deadlines. TSA and its contractors had originally planned to 

complete the longer ChoicePoint Phase 2 and OPM ANACI checks after the 

screener began working in the airport. 

TSA’s plan for completing the screener background checks could not 

withstand the increasing volume of background checks. The table below 

depicts the number of incomplete cases as of May 31, 2003:16 

Completed Outstanding 

1. FBI fingerprint checks 52,490 1,015 

2. ChoicePoint Phase 1 checks 51,935 1,570 

3. ChoicePoint Phase 2 checks 12,429 41,07617

4. OPM ANACI 18,025 35,480 

Some of the outstanding cases consisted of checks that had been conducted, 

but required adjudication. TSA had a backlog of 7,368 cases to adjudicate, 

and DynCorp had a backlog of an additional 37,669 cases that had not yet 

been sent to TSA. 

Weaknesses in all four parts of the background check process contributed to 

the number of incomplete cases. First, TSA did not maintain control over the 

background information its contractors collected and submitted to begin the 

checks. Submissions inconsistently matched the roster of applicants TSA 

hired, and many submissions were untimely and of low quality. Second, some

check results were neither as rapid nor as definitive as projected. Third, the 

 

16 We counted checks that required adjudication as incomplete. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 15 

17 In March 2003, TSA changed its priorities to emphasize completing ANACIs rather than ChoicePoint Phase 2 cases. 

As of May 31, 2003, 14,442 screener employees had outstanding ChoicePoint Phase 2 checks, and 26,634 had completed 

checks that required adjudication. 
high volume of checks created backlogs in adjudication. Since the deployment 

of screeners to airports did not pause, screeners began training and working 

before TSA reviewed their fingerprint and ChoicePoint Phase 1 checks. To 

manage the backlog, TSA came to depend on contract adjudicators for whom

TSA provided limited oversight. Fourth, TSA headquarters did not notify the 

Federal Security Directors (FSDs) 18 and airport operators promptly about 

disqualifications, and screeners who failed checks continued to work. Further, 

some of the disqualifications were based on inaccurate information, and 

required that terminated screeners be reinstated. 

Collecting and Submitting Background Information

TSA did not maintain control over the quantity, quality, and timeliness of 

information collected by contractors and submitted to ChoicePoint or OPM 

during the critical March-December 2002 hiring period. As a result, TSA’s 

contractors initiated thousands of unnecessary checks for applicants TSA did 

not hire, contributing to the backlog in adjudication. Furthermore, TSA’s 

contractors did not initiate thousands of checks on screeners who were hired. 

In addition, some background information submissions were untimely and 

incomplete. 

NCS Pearson and PEC Solutions collected the SF 85P, OF 306, employment 

application, and fingerprint chart and forwarded them to ChoicePoint and 

OPM. As of June 3, 2003, PEC Solutions forwarded 115,331 fingerprint files, 

including some duplicates, to OPM for the fingerprint checks; and 

ChoicePoint processed 112,278 ChoicePoint Phase 1 cases. TSA planned to 

process extra applicants for these two checks because some applicants would 

fail and drop out of the hiring pool. 

Since TSA planned to complete ChoicePoint Phase 2 and ANACI checks after 

hiring screeners, TSA could have controlled the number of those checks by 

comparing employee rosters with rosters of active investigations, preventing 

or aborting checks on applicants who were not hired. However, 45,550 of the 

84,613 ChoicePoint Phase 2 checks, or 54 percent, occurred for applicants 

who were not on the screener payroll as of May 31, 2003.19 Similarly, 31,780 

of 57,173 ANACIs, or 56 percent, occurred for applicants who were not 

employed. We conservatively estimated that unnecessary checks cost TSA 

more than $7 million. 

 

18 TSA’s 159 Federal Security Directors and their staffs are responsible for security, including management of the 

screener workforce, at over 400 U.S. airports. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 16 

19 Some of these applicants may have been on the payroll before May 31, 2003. 
 

Also, TSA did not use the employee rosters to review the status of checks on 

screeners who were hired. Thus, TSA’s personnel security office did not know 

whether the four checks were initiated, in process, or complete for screener 

employees. In February 2003, TSA staff collected over 500 boxes of 

background check documentation from NCS Pearson, whose contract ended in 

December 2002. To TSA’s surprise, the boxes contained unsorted, original 

background check forms for more than 20,000 screeners. NCS Pearson never 

submitted the forms to OPM, which meant OPM never scheduled thousands 

of ANACIs. With the help of U.S. Investigations Services, TSA began to 

identify screeners whose ANACI had not begun and to consolidate, complete, 

and submit their background check forms. As of June 3, 2003, TSA had not 

yet initiated ANACIs on 17,506 screeners. 

With little control over when its contractors submitted background check 

information, TSA was not timely in initiating the ANACI. The federal 

standard for initiating an ANACI is within 14 days of hiring; however, as of 

June 3, 2003, TSA still needed to initiate ANACIs for about a third of its 

screeners, who had been employed 150 days or longer. Additionally, agencies 

are required to submit the SF 85P within 120 days of the applicant’s or 

employee’s signing it, to ensure the information remains current. On average, 

TSA or its contractor submitted the form within about 50 days, but 3,945 

forms were submitted late.20 After discovering the forms in the 500 boxes 

from NCS Pearson, TSA personnel security office staff negotiated with OPM, 

and OPM agreed to accept outdated forms. 

Also, TSA did not meet the timeliness standard it set for itself to complete the 

fingerprint and ChoicePoint phase 1 checks before training screeners and 

allowing them to work in airports. As of May 31, 2003, TSA had not yet 

completed fingerprint checks on 1,015 screeners and ChoicePoint Phase 1 

checks on 573 screeners. As of May 16, 2003, TSA had not performed either 

check on 146 screeners. The inadequate manner in which TSA’s personnel 

security office monitored the status of employee investigations contributed to 

these lapses.

Another problem with this phase of the background check process was the 

poor quality of documentation that NCS Pearson submitted to ChoicePoint 

and OPM. ChoicePoint ran 16,987 “partial checks” based on incomplete SF 

85Ps it received from NCS Pearson. OPM rejected as incomplete more than a 

quarter of the SF 85Ps it received. TSA’s personnel security office did not 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 17 

20 Based on 62,936 SF 85Ps submitted from March 2002 to July 2003.
provide sufficient quality control over the SF 85P submission. TSA could 

have exercised more control over this step by reviewing, signing, and dating 

the agency portion of the SF 85Ps. However, TSA’s personnel security office 

did not have an onsite presence at the assessment centers, and TSA allowed 

NCS Pearson to submit SF 85Ps directly to ChoicePoint and OPM without 

approving many of them. TSA signed and dated four SF 85Ps out of the 34 

files in our review that contained at least the front page of the form.

21 

Checking Screeners’ Background

The checking portion of the process (fingerprint, ChoicePoint Phase 1 and 

Phase 2 checks, and OPM ANACI) experienced delays or contained 

deficiencies that also hindered background check completion. Some

fingerprints took longer than usual to process, especially cases involving 

“unclassifiable” fingerprints. Furthermore, fingerprint results often did not 

provide information about the outcome of an arrest, which is critical for 

adjudication. We were unable to verify whether ChoicePoint met its own time 

standards for processing its checks. We determined, however, that OPM did 

not always meet its standard for processing ANACIs. 

The fingerprint check is the first step of the background check and identifies 

individuals with criminal records in the FBI’s fingerprint-based criminal 

history database. During the June 3, 2003, congressional hearing, OPM 

explained that fingerprint checks take two to three days to process. Our file 

review supported that statement. Of the 250 dated fingerprint checks in our 

sample, OPM completed 230 within three days. The median time to process a 

fingerprint check was one day. However, eight of the 250 fingerprint checks 

took longer than a week to process.22 

“Unclassifiable” fingerprints, which are too poor in quality to be compared 

with the FBI’s criminal history database, also delay the fingerprint check 

process. TSA often did not identify unclassifiable results and re-fingerprint 

applicants in a timely manner. Our file review showed ten instances in which 

screeners’ first fingerprints were unclassifiable. TSA took from 132 to 246 

 

21 As of July 2003, TSA did not have a standard policy for what to retain in the personnel security files. At different 

points, TSA retained or discarded the SF 85P. This reduced the number of files in our sample with SF 85Ps. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 18 

22 This delay may have occurred in part because five states do not participate fully in the FBI’s fingerprint-based 

criminal history database. Florida, New Jersey, North Carolina, Oregon, and Montana participate in Department of 

Justice’s National Fingerprint File program, which allows them to submit only first arrest fingerprints to the FBI and 

then maintain all other records at the state level to be shared upon request. Screeners from these states underwent more 

time-consuming, name-based FBI checks. 
 

days to re-fingerprint four of these screeners.23 Four other screener employees 

still had no classifiable fingerprint results on file as of July 16, 2003. The 

remaining two screeners were separated, having remained employees without 

re-fingerprinting for 107 and 221 days before their separation. We also found 

two cases in which screeners appeared never to have been fingerprinted at all; 

one was still a TSA employee. One cause of these delays was the inability of

TSA’s web-based CITS to produce reports of applicants who require refingerprinting. TSA recently added a mechanism to CITS that notifies Federal 

Security Directors of unclassifiable results, so that an FSD can quickly submit 

new fingerprints. 

A significant shortcoming of the fingerprint check is the limited depth of 

information it provides. About 15 percent of the fingerprint check results 

suggest screeners may have a criminal record.24 But the FBI’s results often

show a screener’s arrests without indicating whether the arrest resulted in a 

conviction, acquittal, dropped charge, or other outcome. The results also do 

not clearly indicate whether listed crimes, which have different local labels 

and codes, are among the 28 felonies that preclude screener employment 

under ATSA. When the disposition of an arrest record is unclear, adjudicators 

must make inquiries, which add delays and are not always fruitful. 

In spring 2003, media reports noted that some airport operators, doubting the 

fingerprint results from TSA’s personnel security office, re-fingerprinted 

screeners and discovered disqualifying criminal histories among passenger 

and baggage screeners. We reviewed one set of re-fingerprinting results. For 

38 screeners whom the airport operator considered to have disqualifying 

criminal histories, we found 32 fingerprint results that showed arrests without 

a disposition. TSA’s personnel security office disqualified ten of the 32 after 

further research. Only one of the 38 records showed a clearly disqualifying 

conviction, which TSA’s personnel security office also discovered, but not 

before the airport operator revoked the screener’s access badge. 

We also attempted to validate the timeliness of ChoicePoint’s and OPM’s 

checks. ChoicePoint reported that its Phase 1 checks take 7-10 days while the 

Phase 2 checks take 10-21 days. We were unable to verify this claim. We also 

examined the time required to complete ANACIs. OPM reported that ANACI 

cases take 45-70 days to complete. However, less than half of the 208 dated 

ANACI case files that we reviewed met that standard. The median time to 

23 Two of the four had completed fingerprint checks that were awaiting TSA adjudication for more than 30 days. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 19 

24 Based on 17,702 of 116,261 screener fingerprint checks that OPM reported completing between March 2002 and July

2003. 
process the ANACIs in our sample was 86 days, with cases ranging from 31 

to 241 days to complete. OPM reported to the OIG that since June 1, 2003, it 

completed over 12,000 ANACIs in an average of 67 days. 

Because OPM depends on other federal, state, and local agencies to supply 

background information, OPM’s results are dependent on their timeliness. 

When OPM completes the bulk of its review but still lacks some responses 

from sources beyond its control, it may return the case to TSA as “closedpending” and send the remaining information to TSA when available. DOT 

personnel security management policies allow TSA to accept closed-pending 

cases for adjudication. Most missing information carries little risk of revealing 

issues that could disqualify the subject. Of the 211 ANACI-based cases we 

reviewed, DynCorp and/or TSA recorded 200 cases as closed-pending when 

they adjudicated them. The majority of the cases were missing employer or 

reference inquiries. However, we found eight that were missing fingerprintbased checks or local law enforcement checks, steps that are more critical to 

the identification of disqualifying information. 

Adjudicating the Results of the Checks

A trained adjudicator must evaluate the information obtained during the 

background checks to determine whether the screener is suitable or unsuitable 

for federal employment. Specifically, an adjudicator must rule on each of the 

four background checks. TSA did not accomplish its objective of approving 

the fingerprint and ChoicePoint Phase 1 checks before allowing screeners to 

train and work. Despite assistance from contract adjudicators, TSA built up

backlogs and did not meet timeliness standards. 

TSA applied OPM’s suitability standards, augmented by ATSA and TSA 

guidance, to help adjudicators identify and judge disqualifying criminal 

offenses, patterns of offenses, credit issues, and other adverse information. 

Two criteria dominate the standards to disqualify applicants: convictions 

within the past 10 years for the 28 crimes listed in ATSA, and bad debt in 

excess of $5,000. Credit issue cases take longer to adjudicate because the Fair 

Credit Reporting Act requires adjudicators to give the applicant or employee 

written notice; TSA gives screeners an opportunity to resolve the matter 

within 14 days before the adjudicator can make an adverse finding. TSA does 

not require its adjudicators to question the applicant or employee about other 

adverse information; adjudicators may approve or disapprove the screener 

based on the check results alone. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 20 
 

Before passenger and baggage screeners became TSA employees, the Federal 

Aviation Administration’s regulations required aircraft operators to complete 

a fingerprint-based criminal history check for screeners. For screeners 

employed prior to December 6, 2001, the aircraft operator had 45 days from

receipt of the fingerprint record in which to evaluate potentially disqualifying 

arrests and to suspend disqualified screeners. For new screeners, the aircraft 

operator was required to evaluate the potentially disqualifying arrests before 

allowing individuals to perform screening functions. 25 TSA did not follow 

these standards while hiring its screener workforce. Of the fingerprint checks 

we reviewed, about two-thirds of the screeners began working before their 

fingerprints were adjudicated.26 In addition, ten screeners had criminal records 

that TSA did not adjudicate within 45 days of receiving the fingerprint results. 

When fingerprint checks showed criminal records but not clear convictions, 

TSA conducted further research that sometimes delayed adjudications. TSA 

adjudicators contacted localities to verify arrest outcomes. They also 

compared fingerprint results with SF 85Ps to determine whether screeners had 

falsely answered questions about their criminal histories. However, TSA’s 

personnel security office did not receive an independent copy of the SF 85Ps; 

instead, the office waited for copies processed by ChoicePoint and OPM. 

Additionally, TSA had insufficient staff to adjudicate both fingerprint checks 

and ChoicePoint Phase 1 checks before hiring new screeners. TSA believed 

the ChoicePoint Phase 1 check was an important step to reduce the security 

risk before hiring because the check included link analysis, which compared 

an applicant’s background data against data from terrorist watchlists. With 

TSA’s adjudicators focusing on fingerprint checks during the last critical 

months of hiring, TSA contracted with DynCorp to obtain help processing 

adjudications. However, TSA did not ensure that the adjudicators completed 

both reviews, and many ChoicePoint Phase 1 checks were not adjudicated 

before screeners were hired. DynCorp adjudicated several thousand 

ChoicePoint Phase 1 checks in February 2003 alone, and almost 1,000 still 

needed adjudication as of May 31, 2003. This reduced the benefit of the Phase 

1 check because applicants were hired, trained, and put to work without 

undergoing the link analysis. 

As of May 31, 2003, the backlog for employed screeners included 26,634 

ChoicePoint Phase 2 adjudications and 17,406 ANACI adjudications.27

25 49 C.F.R. 1544.229. 26 Based on 131 of 193 cases in which both entry-on-duty and adjudication dates were available. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 21 

27 In March 2003, TSA changed its priorities to emphasize completing ANACIs rather than ChoicePoint Phase 2 cases, 

and TSA did not plan to complete the ChoicePoint Phase 2 adjudications for the October 1, 2003, deadline. 
Because TSA hand-marked on some adjudication sheets the date it received 

the case from DynCorp, we were able to approximate how long DynCorp took 

to adjudicate some ANACIs.28 The 130 dated cases in our file review took 

DynCorp between two and 235 days to return to TSA, with the median time at 

85 days. DynCorp can complete 400-500 ANACI adjudications per day 

without building a backlog, if staff is not also processing other TSA 

adjudications or reports. TSA sometimes instructed DynCorp to focus on 

certain adjudications to the exclusion of others, such as ChoicePoint 

adjudications during February and early July 2003, which increased 

DynCorp’s ANACI backlog. A new, July 2003 contract requires DynCorp to 

adjudicate ANACIs within 72 hours of receipt at a rate of 400 per day. 

TSA’s adjudicators also maintained a backlog in processing the cases 

DynCorp sent to TSA for final review and action. Of the 90 ANACI cases in 

our file review with dates showing when TSA received the case from

DynCorp and when it completed adjudication, TSA completed 53 

adjudications on the same day as receipt. But 35 adjudications took from

seven to 92 days to complete. Our file review showed that the overall time 

from when OPM completed an ANACI, to when TSA incorporated 

DynCorp’s work and documented a final adjudication, was between 14 and 

224 days for 177 dated cases. The federal standard for adjudicating and 

completing final processing for a background check is 90 days.29 TSA met 

this standard for 115 of the 177 cases (65 percent). 

Question of How Much Adjudication Responsibility Contractors May 

Assume

According to the TSA Administrator, TSA intended to make final 

adjudication decisions for all appointees while its contractors merely assisted 

in the process. However, we identified cases that TSA did not adjudicate and 

question whether TSA provided adequate oversight of its contract 

adjudicators. In March 2003, DynCorp contractors began issuing final 

decisions for cases adjudicated favorably. DynCorp signed and forwarded to 

Accenture completed Certifications of Investigation and sent the Report of 

Agency Adjudicative Action (OFI 79A) to OPM to populate OPM’s Security 

Investigations Index database.30 Our file review showed instances of this 

contractor work. Allowing DynCorp to fully adjudicate and document 

 

28 Our sample did not provide clear information regarding the time to process ChoicePoint checks. 29 Security Requirements for Government Employment (Executive Order 10450, April 27, 1953); 5 C.F.R. 732.302(b). 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 22 

30 Accenture maintains TSA’s Official Personnel Folders for all TSA employees except the executive staff. 
 

favorable cases lightened the workload for TSA’s backlogged adjudication 

staff. 

In the past, federal agencies have considered making final adjudication 

decisions to be an “inherently governmental” function that contractors may 

not perform.

31 For example, in a 1999 proposed rule, OPM noted, “With 

OPM’s Investigations Service privatization effort, OPM has contracted much 

of its adjudicative case processing, with close OPM oversight. However, OPM 

has retained all decision making responsibility, which it views as an inherently 

governmental function.” 32 OPM’s General Counsel continues to support this 

stance. While TSA was a part of DOT in 2002, the department listed the 

function code for personnel security clearances and background 

investigations, which includes adjudication, as inherently governmental on its 

FAIR Act inventory. 

In August 2003, the TSA Office of Chief Counsel produced a legal opinion 

concluding that contractors may complete favorable adjudications as long as 

TSA completes adverse cases and provides “close agency oversight.” TSA 

noted that, according to OPM’s draft guidelines, Suitability Overview for 

Federal Agencies, “Adverse decision making is considered an inherently 

governmental function and may not be contracted. Agencies will be permitted 

to contract or re-delegate other portions of the adjudicative process but must 

ensure they do so with close oversight.” 

However, TSA has not provided close, consistent oversight of its contract 

adjudicators. First, although TSA retained final decision-making 

responsibility for adverse and uncertain cases, which DynCorp reviewed and 

returned to TSA for completion, we noted two instances where a contractor at 

TSA headquarters signed the TSA final adjudication sheet for an unfavorable 

adjudication. Second, TSA’s contracting officer representative does not 

provide quality checks of the adjudication contractors’ work. Third, TSA’s 

on-site oversight and quality control has been inconsistent. At first, a TSA 

representative went to DynCorp once a week to answer questions and review a 

sample of 100 favorable cases. That is about four percent of DynCorp’s 

adjudications, which averaged 500 a day. However, TSA’s representative 

ceased oversight visits for a period of six weeks in May and June before 

31 The Federal Activities Inventory Reform Act of 1998, P.L. No. 105-270 (FAIR Act), defines an inherently 

governmental function as “a function that is so intimately related to the public interest as to require performance by

Federal Government employees.” Inherently governmental activities “require either the exercise of discretion in applying

Federal Government authority or the making of value judgments in making decisions for the Federal Government”; and 

they include oversight of monetary transactions or entitlements and the appointment of U.S. employees. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 23 

32 “Suitability,” 64 Federal Register 4336, 4337 (proposed January 28, 1999)(to be codified at 5 C.F.R. Part 731). 
resuming them in July. For comparison, OPM provides full-time, on-site 

representatives for its contract adjudicators. Also, DHS Personnel Security 

Division provides a 100 percent review of contractors’ adjudications. 

Disseminating the Results of the Checks

The adjudication from TSA’s personnel security office determined whether 

TSA would terminate the employment of screeners whom TSA hired 

conditionally, pending the completion of a background check. For screeners 

who failed a background check, the personnel security office advised TSA’s 

Human Resources Office to draft a termination letter, which Federal Security 

Directors delivered. However, the notification process did not unfold as TSA 

envisioned. Screeners who failed checks continued to work in airports. 

Terminated screeners challenged hundreds of adjudications as erroneous, and 

TSA reversed many of their terminations upon reconsideration. Finally, TSA 

allowed OPM to begin or continue checks on screeners that TSA had already 

disqualified. 

During the June 3, 2003, congressional hearing, the TSA Administrator 

reported that, as soon as the adjudicators identified employees as ineligible, 

TSA removed them from the airport and put them on administrative leave 

until their terminations were complete. However, TSA staff reported to the 

OIG that screeners with adverse adjudications continued to work in the 

airports until TSA delivered termination letters. Only for the most serious 

cases did TSA staff immediately inform the FSDs to place screeners on 

administrative leave, according to the draft screener credentialing process map 

that the TSA Human Resources Office was using in July 2003. Our 

comparison of the fingerprint check results at one airport and at TSA 

headquarters confirmed that there were notification delays. For 12 of 13 

disqualified screeners, it took from 89 to 255 days from the time TSA 

disapproved the fingerprint check to the time the airport operator deactivated 

the screener’s badge.33 In four of those cases, TSA’s personnel security office 

had no record of notifying the FSD or airport operator about the adverse 

fingerprint results, and the airport operator claims to have removed the 

screeners through its own initiative. Additionally, in our review of the 255 

files at TSA headquarters, 23 of 65 disqualified screeners had no recorded 

separation date. TSA did not meet the federal standard of removing an 

employee within five work days of making its final decision.34 

 

33 For the remaining case, the airport operator discovered the screener had a disqualifying conviction and deactivated his 

badge before TSA adjudicated his fingerprint check. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 24 

34 5 C.F.R. 731.404. 
 

Another significant issue for TSA during this portion of the background check 

process was the number of screeners who claimed that TSA terminated them

erroneously. From approximately March to July 2003, 309 screeners 

challenged their terminations. Of the 309 terminated screeners, TSA reinstated 

129 screeners after further review, reversing its adjudications 42 percent of the 

time. A second Human Resources Office database shows 40 other 

reinstatements in addition to the 129, yielding a total of 169.35

Were TSA to provide its screeners with the opportunity to explain or refute 

unfavorable information before termination, the number of reconsiderations 

would likely decrease. For most of this period, TSA did not have a defined 

policy for managing screeners’ requests for reconsideration. In August 2003, 

TSA developed a termination letter that permits screeners to seek 

reinstatement with back pay if they can disprove the background check 

findings within ten days. By not providing screeners with an opportunity to 

contest the adjudication before they are terminated, TSA’s policy contradicts 

the DOT personnel security management policies that TSA adopted. The DOT 

manual obligates TSA to “provide all applicants, employees, and contractor 

personnel the opportunity to explain or refute any unfavorable information 

before the department uses the information as a basis for any adverse 

personnel, security, or similar action against them.” [emphasis added] 

According to the DOT manual, “This practice ... prevents errors which might 

otherwise result from mistakes in identity or erroneous information and 

provides the applicant or employee the opportunity to present mitigating 

information that may be unknown to the adjudicating officials.” Not 

surprisingly, a number of TSA’s reversals have been based on information 

that screeners provided to show mistaken identity or other errors. 

TSA also did not have a defined procedure for managing requests for 

reconsideration. Requests came daily to TSA’s Human Resources Office from

FSDs, TSA’s Office of the Ombudsman, and screeners themselves. For the 

requests that the Human Resources Office began tracking in May 2003, the 

median time the personnel security office took to re-adjudicate a screener’s 

request was 24 days, and processing times ranged from 0 to 74 days. Overall, 

the personnel security office reviewed cases within 72 hours less than 10 

percent of the time, although this is the adjudication standard TSA set for 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 25 

35 In May 2003, TSA’s Human Resources Office began a spreadsheet to monitor requests for reconsideration, and the 

309 cases it tracked spanned this period. TSA’s central human resources database has always noted reinstatements; 

however, since it does not track the total number of requests made, we could not calculate the rate of reinstatement prior

to May 2003. 
itself in “Evaluation and Adjudication Requirements for TSA Screeners to 

Meet Congressional Deadlines.”36 Terminating screeners based on inaccurate 

or incomplete information not only affects morale but also takes a toll on both 

the screeners and understaffed airports as capable screeners wait to return to 

work. 

We note one additional administrative weakness in TSA’s notification 

process. Although OPM’s investigation guidance encourages agencies to 

discontinue background checks as soon as the agency makes an adverse 

finding against a person, TSA initiated and continued background checks on 

screeners who had already failed the fingerprint or ChoicePoint checks. 

During two of our file reviews, we noted that TSA continued to process 

ANACIs for 16 of 32 screeners disqualified by a fingerprint or ChoicePoint 

check (50 percent). Besides adding expense, this practice needlessly increased 

the processing and adjudication workload. 

We recommend that the TSA Administrator: 

Recommendation 3: Ensure, without exception, that all screeners undergo a 

fingerprint-based criminal history records check and receive a favorable 

adjudication before they begin training and work. 

Recommendation 4: Incorporating guidance from the Department of 

Homeland Security, define the role that contract adjudicators will play in 

TSA’s background check process and the minimum requirements that TSA 

must meet to fulfill its oversight responsibilities.

Recommendation 5: Institute precautions to protect against terminations that 

are based on incorrect information. 

Recommendation 6: Establish mechanisms to prevent and abort background 

checks on applicants and employees whom TSA disqualifies. 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 26 

36 Based on 17 of 274 records with sufficient date information to be assessed (6.2 percent). This figure includes screener

adjudications that TSA both reversed and sustained. For only the cases reversed, resulting in the screener’s returning to

work, the personnel security office completed 11 of 110 dated requests within 72 hours (10 percent). 
 

Verifying Citizenship and Personal Identification 

U.S. citizenship is a job qualification and requires verification before hiring. 

Prior to August 2002, TSA had little assurance that it was hiring citizens 

because it was not requiring adequate evidence of citizenship. In August 2002, 

TSA recognized this problem and its personnel security office added 

citizenship verification to the ANACI by requiring checks with the 

appropriate bureaus of vital statistics. To its credit, TSA required the checks 

for screeners already hired, as well as for new hires.37 This continues as a 

specific requirement on screener cases referred by TSA for the ANACI. 

The Immigration Reform and Control Act of 1986 requires all U.S. employers 

to verify the identity and employment eligibility of those hired to work in the 

United States after November 6, 1986. Every new employee is required to 

complete the Employment Eligibility Verification Form (Form I-9). The form

requires employees to provide personal identification and attest that they are 

eligible for U.S. employment, and it requires employers to certify that the 

identification presented matches the individual who submitted it. When the 

Form I-9 is completed, the hiring agency must certify and retain it for a 

minimum of three years.38 

In a judgmental sample of 25 OPFs drawn from the 255 cases of employees 

selected for examination of processing data, only 22 had completed the Form

I-9. Of the 22, a TSA contractor signed and dated 20. Of the two not signed 

and dated, both lacked dates and one lacked a signature. Any absent or 

incomplete forms are troublesome as they reveal flaws in the hiring process. 

Furthermore, we found 20 Form I-9s for which the applicants presented a 

combination of a driver’s license and Social Security card or birth certificate. 

While these documents are authorized for use with the Form I-9, we note that 

they are all easily counterfeited documents.39 The checks with bureaus of vital 

statistics that TSA now uses provide more reliable verification of citizenship. 

While we found no evidence that TSA hired ineligible applicants, we 

concluded that TSA could improve its procedures for processing the Form I-9. 

37 Since OPM does not automatically verify citizenship status as part of the ANACI, TSA must request the search. OPM

provides this service for $15 per case, to cover the cost of obtaining records from bureaus of vital statistics. 38 Employers must retain the Form I-9 and make it available for inspection by the Departments of Homeland Security, 

Labor, and/or Justice, for three years after hiring employees, or one year after terminating their employment, whichever 

is later. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 27 

39 The documents are authorized pursuant to 8 C.F.R. § 2742.2. However, in Counterfeit Identification Raises Homeland 

Security Concerns, the General Accounting Office reported that it easily produced or obtained counterfeit birth 

certificates, driver’s licenses, and Social Security cards. Government employees and others did not recognize the 

counterfeit documents (GAO-04-133T, October 1, 2003).
We recommend that the TSA Administrator: 

Recommendation 7: Strengthen procedures for completing and retaining the 

Employment Eligibility Verification Form (Form I-9). 

Managing the Personnel Security Program 

The November 19 and December 31, 2002, deadlines mandated by Congress 

drove TSA's hiring of passenger and baggage screeners. These deadlines in 

the ATSA were extremely ambitious, forcing TSA concurrently to establish 

itself as a new agency and to assess, hire, train, equip, and deploy a new 

federal screener workforce.40 Although contractors performed the background 

checks and helped TSA review most results, TSA was responsible for 

planning and guiding the process; managing the contractors’ work; tracking 

background check progress and completion; making final suitability decisions; 

and terminating people who failed the checks. With no comprehensive plans, 

responsibilities for several other major programs, a limited number of 

adjudicators, and no comprehensive database or filing system, TSA’s 

personnel security office was overwhelmed. It could not meet quality and 

timeliness standards while processing the volume of background checks. In 

effect, TSA was hiring screeners before it was organized to do so. In the rush 

to meet the statutory hiring deadlines, TSA abridged management practices 

and processing requirements normally considered essential to well-managed, 

established organizations. 

 

Planning

TSA officials were not prepared to manage the volume of screener 

background checks. TSA had no comprehensive plan for administering 

background checks that described how the different participants, resources, 

policies and procedures, and milestones would intersect to meet security 

goals. TSA’s planning framework consisted of a few short-term, partial plans 

that presupposed that the personnel security office would receive additional 

resources to meet its mission. The policies and procedures consisted of DOT 

and OPM manuals that TSA selectively followed, sometimes supplemented by 

TSA guidance. Plans changed as TSA revised its hiring plans to obtain almost 

twice as many screeners as it originally contracted to hire. Without a guiding 

framework to unify the personnel security office’s efforts and to indicate 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 28 

40 TSA faced ten major deadlines within one year of passage of ATSA. 
 

potential shortfalls, TSA did not keep pace with the background check 

workload. 

TSA’s written plans for the background checks consisted of documents that 

partially discussed or charted operations. For example, we obtained a copy of 

a five-page August 2002 memorandum that outlined background check 

procedures and recommended steps to improve checks.The memorandum 

revealed that aspects of the process, such as how to reduce the duplication 

between OPM and ChoicePoint services, were unresolved. TSA also provided 

to the OIG two samples of internal outlines, dated February and March 2003, 

regarding tasks and issues for the personnel security office.41 However, these 

outlines focused on short-term solutions to identified problems, such as 

finding missing security information on screeners. TSA appeared not to have a 

formal, organizational reference. Furthermore, although the documents 

addressed the personnel security office’s need for greater staff, contract, and 

information support, the office received little of the support needed to 

implement the plans at the time. 

For carrying out the plans, TSA pointed to OPM and DOT personnel security 

management manuals as its adopted procedures; however, it is unclear how 

much DOT or OPM policies and procedures governed personnel security 

management.

42 TSA staff and contractors used a mixture of OPM and TSA 

guide sheets to manage the results of the background checks. On the other 

hand, TSA also made exceptions to DOT and OPM guidance by virtue of the 

broad authority granted under ATSA. For example, TSA did not follow DOT 

and OPM procedures to complete screener position risk designations, or DOT 

procedures to grant due process to applicants and employees during 

adjudication. We did not locate documentation where TSA indicated its intent 

to depart from adopted practice. TSA staff informed us that internal directives 

existed but were unable to furnish them. 

Even if TSA had begun background checks with a clearly stated plan and 

policy, it probably would have had to alter them. The instability of TSA’s 

workforce projections partly explains the difficulties TSA encountered while 

completing background checks. Although TSA originally contracted with 

NCS Pearson to hire 30,000 screeners, management soon envisioned a need 

for a much larger workforce to include a more robust checked baggage 

41 “Plan for Going Forward,” (February 26, 2003); later version, March 6, 2003. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 29 

42 On May 6, 2002, DOT delegated to TSA the authority to administer its own personnel security program under DOT 

personnel security orders and manuals. Implementing DOT policies in ways different from the orders and manuals would 

have required separate approval.
 

screening function. The workforce grew to approximately 55,600 screeners by 

the end of the first round of hiring on December 31, 2002.43 As TSA revised 

its workforce estimates, in one manager’s words, “The whole plan 

changed...the entire methodology and process changed.” TSA initiated 

numerous modifications to its contracts based on revised workload 

projections. 

One clear example of TSA’s poor planning involved the process TSA used to 

certify that screeners had passed a background check and were approved to 

begin training and work. TSA planned to adjudicate the results of the 

fingerprint check, print the screener’s identification badge, and forward it 

overnight to the airport before the screener could begin training. This 

management control would prevent disapproved applicants from training, 

because they would never receive badges. However, TSA inadequately 

forecasted the logistics it would need to implement the plan. The DOT 

Badging Office that supported TSA could produce only 200 badges a day, and 

a backlog arose even before TSA’s hiring accelerated to 5,000 screeners a 

week. Even if TSA and DOT had accurately forecasted the hiring surge, it is 

not clear that an operation producing 200 badges per day could have adapted 

to handle 1,000 per day. With deadlines to train and deploy the screeners, and 

screeners who needed badges in the airports, TSA instructed airport operators 

to issue badges independently. This planned solution eliminated the 

management control, and screeners who had not passed a criminal history 

records check received badges and went to work. In May 2003, TSA 

established its own badging unit to regain control over badges issued. 

TSA staff acknowledged there were significant problems with the 

administrative elements of the background check process, and TSA is 

addressing them. The TSA Administrator created a new CPO to continue the 

administration of the background checks. Senior officials produced a draft 

charter for the CPO, which recognizes the organizational challenges and 

provides a foundation for improved operations. The draft charter 

acknowledges, “To date, these programs have moved forward in a largely 

uncoordinated fashion. Specifically, organizational alignment around overall 

TSA strategy, policy development, and resource sharing has not existed to 

date.” Among its priorities, TSA plans to regain management control of all 

background checks and build a sufficient organizational infrastructure.

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 30 

43 This number continues to fluctuate. First, to meet a ceiling of 45,000 permanent full-time employees set by Congress, 

TSA began reducing its workforce by 6,000 during FY 2003, with further cuts contemplated for FY 2004. At the same

time, TSA has been adjusting the distribution of screeners among airports and selectively augmenting its workforce. For

example, in July 2003, TSA announced its intent to recruit 1,300 part-time screeners and 600 permanent full-time

screeners for its mobile National Screening Force. 
Personnel

TSA began hiring screeners in March 2002, before it built a personnel security 

office to manage their background checks. In July 2002, a month before TSA 

began to hire at a pace of 5,000 screeners per week, the TSA personnel 

security office consisted of a supervisor, four adjudicators, and a new director. 

Personnel security staff correctly predicted that the office was understaffed 

and would fall behind schedule. One manager assessed that by August 2002, 

the personnel security office had ten staff but needed 50. A year later, TSA 

was still working to overcome the processing backlogs caused by staffing 

shortfalls. 

The screener adjudication workload was a significant burden on the personnel 

security office staff, but it was not the only one. Since TSA did not use 

contract support to adjudicate fingerprint checks, its staff adjudicated all 

screener fingerprint records, plus they planned to review the adjudications 

contractors completed for the other checks. As TSA’s hiring accelerated, the 

personnel security office could not keep pace with the number of screener 

adjudications required. With adjudication backlogs, TSA did not ensure that 

staff approved fingerprint and ChoicePoint Phase 1 adjudications before 

screeners began training and work. The personnel security office also 

accumulated backlogs for ChoicePoint Phase 2 and ANACI checks. By May 

31, 2003, TSA’s adjudication backlog was 7,368 screener checks. However, at 

the same time, the personnel security office staff was responsible for 

completing the background checks for other populations, such as FSDs and 

staff, Federal Air Marshals, Federal Flight Deck Officers, Security 

Identification Display Area workers, TSA headquarters employees, and 

others. TSA developed an additional adjudication backlog for Federal Air 

Marshals. Furthermore, in addition to adjudicating, personnel security office 

staff compiled status reports on background checks for FSDs and airport 

operators, a time-consuming process since the office lacked the capability to 

generate automated reports. 

As early as August 2002, TSA officials informed TSA senior management 

that the personnel security office needed more staff. However, several issues 

inhibited the office’s effort to acquire staff. First, all TSA offices were 

competing to build up their infrastructure. Second, TSA began FY 2003 under 

a continuing resolution, and the absence of a fiscal appropriation limited 

TSA’s staffing and spending flexibility for several months. Third, although 

Congress gave TSA significant freedom to manage by exempting it from

many personnel requirements, the type of personnel appointments that TSA 

could offer under its authority were less competitive in attracting adjudicators. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 31 
Fourth, turnover disrupted the continuity of personnel security management. 

After June 2003, two officials responsible for the personnel security function 

left TSA headquarters, and TSA just recently reassigned their responsibilities. 

The first director of the new office that oversees personnel security 

management, the CPO, departed in July 2003; and TSA had not named a 

permanent director. 

 

As of August 2003, the personnel security office had 19 adjudicators. Senior 

managers asserted that if needed, more adjudicators were available to help 

TSA meet the October 1 deadline. TSA’s personnel security management

responsibilities will increase considerably as the agency adds programs, such 

as background checks for alien flight students and hazardous materials 

transportation workers. TSA must develop a workforce plan that realistically 

projects personnel security workload and staffing requirements to meet these 

responsibilities. 

Contractor Oversight

With its small personnel security infrastructure, TSA relied heavily on several 

contractors and subcontractors to accomplish the screener background checks. 

However, TSA had insufficient staff and systems to monitor contractor 

performance and spending. Further, frequent tasking changes and contract 

growth also made oversight more difficult. Difficulties with contract

management contributed to TSA’s inability to complete background checks. 

There was insufficient TSA staff to monitor contractor work. Because of staff 

shortages, the responsibilities of Contracting Officer Representatives (CORs) 

shifted often, preventing them from serving as a consistent point of authority 

on contracts and providing continuous oversight. This also led to confusion 

about their authority over contracts. Managers undermined CORs’ efforts to 

monitor contractor work by directly tasking the contractor without the CORs'

knowledge. This practice created multiple problems for the COR, chief among 

them being whether the COR could effectively review contractor invoices. 

CORs reported to the OIG that there were instances where they would not 

approve an invoice because it was thinly supported and the CORs were 

uncertain what they were paying for. 

In addition, TSA did not consistently request or employ status reports to 

manage contractors' work. Some contractors provided weekly reports, while 

others did not. One key contractor provided few reports, and it did not provide 

statistical information we requested. We have reported TSA’s inability to 

track and monitor the status of background checks, and given the volume of 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 32 
checks, it is inexplicable that TSA did not regularly obtain and use production 

data from all of its contractors. 

TSA senior managers and staff were consistent in their remarks that TSA has 

not effectively managed its contractors.44 Despite contract management 

weaknesses, TSA intends to continue to rely upon contract support rather than 

build an infrastructure to replace functions currently performed by contractors. 

TSA is developing a strategy for acquiring future contractor support, and it 

plans to improve COR training and delegations of authority. 

Management Information

Until recently, the personnel security office did not have adequate information 

systems in place to document, track, manage, and report on the status of 

screener background investigations. One TSA official called the absence of a 

tracking system “our biggest shortfall.” As of June 3, 2003, TSA had no 

hardcopy files and no reliable database for screener investigations other than 

CITS, which tracks only the fingerprint check. Most of the documentation that 

TSA did possess lay in unsecured boxes of investigation packets, not 

organized in a manner that enabled TSA to locate a particular individual’s 

records. The personnel security office’s electronic records consisted of CITS; 

spreadsheets that adjudicators developed for individual use, which had 

become corrupted; and an incomplete database replacing the automated 

spreadsheets, which could not support all TSA’s adjudicators simultaneously. 

As a result, TSA had no comprehensive picture of the status of investigations, 

nor did TSA have adequate information to control ongoing investigations or a 

ready means of reporting on screeners’ checks. These systems were wholly 

inadequate for TSA to manage the volume of background checks. 

With contractors and the TSA Human Resources Office controlling 

employment data, the personnel security office staff had difficulty identifying 

how many screeners TSA actually employed and how many needed 

background checks. One TSA official commented that payroll lists did not 

match contractor processing lists and “It was impossible to figure out how 

may screeners there were.” Furthermore, the personnel security office had 

little information about the status of background checks its contractors were 

performing. For example, the office did not begin comparing OPM's roster of 

ANACI investigations to TSA’s employee roster until 2003. TSA also did not 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 33 

44 Following audits by TSA’s Office of Internal Affairs and Program Review and DOT OIG, TSA reported contract 

management as a material weakness in its December 2002 Federal Managers Financial Integrity Act report to Congress 

and the Office of Management and Budget. 
have comprehensive status information for cases that the personnel security 

office referred to the Human Resources Office for termination. The Human 

Resources Office did not begin to maintain data on screeners’ requests for 

reconsideration until May 2003; before that, TSA has no information on how 

many screeners made requests, only on the number of actual reinstatements. 

TSA needs a comprehensive data system that unifies Human Resources Office 

data, such as appointments and terminations, with the contractor and 

personnel security office data on the status of checks. 

Without an integrated, automated system to track all four checks, TSA has no 

automatic mechanism to abort checks on screeners who fail an earlier check. 

TSA also is unable to abort duplicate checks in some cases. For example, 

when ChoicePoint posted results to a website for DynCorp to adjudicate, 

ChoicePoint occasionally reposted old cases under new case numbers. This 

caused DynCorp to repeat adjudications unnecessarily. TSA was unable to 

fulfill DynCorp’s request to resolve the issue. 

TSA’s new screener files have inconsistent, incomplete, and unconsolidated 

information. Although TSA began hiring screeners in March 2002, it was not 

until August 2002 that the personnel security office asked NCS Pearson to

share daily rosters of appointees so that the personnel security office could 

create investigative files. Actual file creation did not begin until June 2003. 

Furthermore, TSA has not maintained or enforced a standard policy for what 

to retain in the personnel security file. During our file review, we found 23 SF 

85Ps in 117 completed files; TSA staff explained that the personnel security 

office varied its policy on retaining the SF 85P. Of the 117 files, 32 had 

missing or incomplete Certification of Investigation forms. Further, we 

discovered instances where TSA filed duplicate folders for screeners, which 

will confuse efforts to retrieve information from the files. We also noted 

instances where TSA filed disqualified screeners in folders color-coded for 

qualified ones, and vice versa. Finally, we observed that TSA does not secure 

the cabinets and loose files, though they contain sensitive and Privacy Act 

information, including criminal histories. 

One FSD complained that the TSA personnel security office could not provide 

accurate, current status reports for the background checks on screeners. When 

FSDs or other TSA staff requested reports on the status of screener 

background checks, personnel security office staff compiled the reports by 

hand because they lacked the capability to generate them automatically. Even 

after populating the two databases in June and July 2003, TSA still compiles 

reports on fingerprint checks by hand, assembling individual records that staff 

query by Social Security number. This is a time-consuming and laborReview of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 34 
intensive process. One staff member reported taking two days to research the 

fingerprint check status of about 1,000 screeners at one airport. Partly because 

some did not trust TSA’s information or assurances, at least one airport 

operator began checking screeners independently. 

By 2003, the personnel security office was aware of the need for a functioning 

database and filing system in order to manage the amount of background 

check information. However, when security officials requested financial 

support to collaborate with the Information Technology Office in establishing 

a database, management denied the request, citing limited funds. Then, in 

March 2003, DHS advised components to suspend individual plans to develop 

personnel security databases in favor of plans for a comprehensive, low-cost 

system that all components would share.45 Because of its pressing need, 

TSA’s personnel security office continued to pursue database development. In 

May 2003, TSA management approved the creation of a database. Shortly 

after June 3, 2003, management allowed the office to obtain contract support 

to begin entering data in order to create a more robust database. Contractors 

also helped TSA begin a paper filing system. However, as contractors nearly 

completed the database, TSA realized it needed additional information to 

monitor the screener background checks for the October 1, 2003, deadline; 

therefore, TSA derived a second database from the first. Neither system tracks 

the investigations on populations other than screeners, including all other TSA 

employees, Secure Identified Designated Area workers, Federal Flight Deck 

Officers, and others.46 The personnel security office staff said that they 

planned to add this data in the future. TSA will not be able to manage the 

volume of data involved in these personnel security programs without 

comprehensive, automated information management systems. 

We recommend that the TSA Administrator: 

Recommendation 8: Implement personnel security management policies and 

procedures and document departures from them. 

Recommendation 9: Document the Credentialing Program Office workload 

and then plan and hire staff to meet workload requirements. 

 

45 After researching this possibility, the DHS Personnel Security Division decided that the proposed system did not meet 

the department’s needs. DHS abandoned the plan to require all components to use the same database, and instead it plans 

to develop an interface to unify the individual databases components use.

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 35 

46 Future background checks required for the full range of existing and planned TSA programs will number in the 

millions. The CPO plans to conduct background checks on between three and four million hazardous material

transportation workers. Other credentialing efforts may target merchant mariners, maritime industry workers, Armed 

Law Enforcement Officer Credentialing, and the Registered Traveler program.
Recommendation 10: Ensure that TSA program managers formally 

document contract modifications and instructions, maintain a substantive 

presence with contractors in order to provide guidance and oversight, and 

require status reports to track mission accomplishment. 

Recommendation 11: Create a personnel security management tracking 

system that provides management with accurate, timely, and integrated 

information on the status of security investigations. The information should 

reflect the complete cycle of personnel security management, including data 

on incoming staff, separations, and reconsiderations. 

Recommendation 12: Improve records management policies, procedures, and 

practices governing the content, organization, and storage of personnel 

security management case files. 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 36 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 37 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 38 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 39 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 40 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 41 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 42 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 43 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 44 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 45 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 46 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 47 
Appendix A 

Management Comments 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 48 
Appendix B

OIG Evaluation of Management Comments

The OIG evaluated TSA’s written comments and made changes to the draft 

report where deemed appropriate. Below are a summary of TSA’s response to 

the report’s recommendations and the OIG analysis of TSA’s response. 

Recommendation 1: Complete screener position risk designations with 

input from the personnel security officials of the Department of 

Homeland Security and from appropriate TSA offices, including the 

Credentialing Program Office, Human Resources Office, and Aviation 

Operations. Screener position risk designation records, position 

descriptions, and vacancy announcements should reflect the correct 

designation.

TSA agreed to complete the screener position risk designations and update the 

position risk designation records, position descriptions, and vacancy 

announcements by mid-January 2004. TSA reported that it has convened a 

group with representatives from CPO, Aviation Operations, and Human 

Resources Office to complete the designations. 

Once complete, these actions will address the bulk of the recommendation. 

However, the OIG maintains that TSA should include input from the DHS 

Personnel Security Division in selecting the designations in order to ensure 

that TSA’s chosen designation does not conflict with DHS guidance. DHS’s 

draft Interim Personnel Security Directive sets forth non-critical sensitive as 

the minimum designation and the MBI as the standard minimum

investigation. If TSA finds a lesser designation and investigation to be 

appropriate, TSA must resolve any conflict with DHS before completing the 

screener position risk designations. 

Recommendation 2: Complete the comparison study of the effectiveness 

of Office of Personnel Management and private sector background 

checks. Incorporating the review’s results, modify screener background 

checks as needed to ensure they suit the position risk designation, meet 

Department of Homeland Security standards, and are cost-efficient. 

TSA does not plan to conduct the comparison study as recommended. TSA 

stated that the CPO lacks the resources to complete the study; moreover, TSA 

believes that checks are currently conducted in the most efficient manner 

possible. TSA maintains that the Office of Personnel Management and private 

sector background checks are complementary rather than duplicative. TSA 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 49 
Appendix B

OIG Evaluation of Management Comments

stated that the checks serve two different functions, with the private sector 

checks providing the rapid information needed to evaluate applicants before 

hiring, and the more in-depth OPM checks providing the information needed 

to retain screeners hired on a probationary basis. Currently, TSA is examining 

alternatives to the OPM ANACI investigation that may prove quicker and less 

costly. TSA expects to complete the analysis in early 2004. 

The OIG believes that TSA’s examination of ANACI alternatives may satisfy 

the intent of this recommendation. For that to occur, TSA’s revised process 

should continue to meet the requirement of EO 10450 to conduct national 

agency checks and inquiries; should eliminate or justify duplicative checks, 

such as two separate credit checks; and should conform to Department of 

Homeland Security personnel security standards. 

Recommendation 3: Ensure, without exception, that all screeners 

undergo a fingerprint-based criminal history records check and receive a 

favorable adjudication before they begin training and work. 

TSA commented that it is current TSA policy to complete a favorably 

adjudicated criminal history records check before offering employment to job 

candidates. TSA stated that it has put in place processes, procedures, and

systems to ensure that both fingerprint and preliminary background checks are 

complete before candidates are hired. TSA added that the CPO and Human 

Resources Office collaborate in administering this process. 

The OIG accepts TSA’s response. TSA should describe in its action plan what 

processes, procedures, and systems have been established and note which 

office holds responsibility for implementing them. 

Recommendation 4: Incorporating guidance from the Department of 

Homeland Security, define the role that contract adjudicators will play in 

TSA’s background check process and the minimum requirements that 

TSA must meet to fulfill its oversight responsibilities. 

TSA reported that it no longer relies on contractors to conduct adjudications 

and that CPO employees now complete the adjudications. Additionally, the 

TSA Office of Chief Counsel has advised that contractors may perform initial 

adjudications, subject to close oversight by TSA. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 50 
Appendix B

OIG Evaluation of Management Comments

The OIG accepts TSA’s response and notes that the Office of Chief Counsel’s 

current advice, allowing contractors to make initial and not final adjudication 

decisions, brings TSA in line with DHS practice. If TSA resumes use of 

contract adjudicators in the future, it will be important for TSA to define its 

minimum oversight requirements. 

Recommendation 5: Institute precautions to protect against terminations 

that are based on incorrect information. 

TSA has instituted two measures to guard against erroneous terminations.

TSA has added a quality assurance check for all unfavorable adjudications 

before referring the cases to the Human Resources Office for termination. In 

addition, CPO will send interrogatory letters to screeners with potentially

disqualifying issues in order to allow screeners to explain, refute, or mitigate 

the unfavorable information before CPO recommends termination. 

The OIG accepts TSA’s response. In its action plan, TSA should describe the 

process, including parties responsible, for conducting the quality assurance 

checks on unfavorable adjudications and for handling interrogatory letters and 

replies. 

Recommendation 6: Establish mechanisms to prevent and abort 

background checks on applicants and employees whom TSA disqualifies. 

TSA reported that it established and began using mechanisms to abort OPM 

background checks on disqualified screeners in mid-summer 2003. 

The OIG agrees that aborting OPM background checks on disqualified 

screeners will eliminate a substantial amount of unnecessary case processing. 

TSA may have a further opportunity to reduce unnecessary case processing by 

aborting adjudications on screeners already disqualified by either a 

fingerprint-based criminal history records check or ChoicePoint-type check. 

The OIG accepts TSA’s response and anticipates reviewing TSA’s latest 

procedures in its action plan. 

Recommendation 7: Strengthen procedures for completing and retaining 

the Employment Eligibility Verification Form (Form I-9).

TSA responded that it has revised its procedures for completing and retaining 

the Employment Eligibility Verification Form (Form I-9). TSA is conducting 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 51 
Appendix B

OIG Evaluation of Management Comments

a systematic review to ensure the forms’ completeness as it establishes a new 

filing system, separate from the OPFs, for retaining these records. 

The OIG accepts TSA’s response. TSA should describe in its action plan the 

process and parties responsible for reviewing and filing the Employment 

Eligibility Verification Forms. TSA should also note the expected completion 

date for the review of previously collected forms. 

Recommendation 8: Implement personnel security management policies 

and procedures and document departures from them. 

TSA stated that the CPO is developing a “standardization guide” that captures 

all essential guidelines for screener adjudications, including processes for 

initiating and adjudicating screener background checks, performance metrics, 

and work standards. TSA also plans to conduct internal audits to ensure 

compliance with its documented standards and policies. 

The OIG agrees that developing clearer guidelines for screener background 

checks, and auditing for compliance with them, are positive steps. However, 

the OIG is concerned that TSA’s response does not fully address the 

recommendation. Before October 1, 2003, TSA nominally operated under 

DOT personnel security management policies, which include a manual that 

comprehensively addresses personnel security aspects such as personnel 

security responsibilities across the agency, position risk designation methods, 

investigation requirements including reciprocity standards, and procedures for 

adverse security actions. Adjudication guidelines, like those TSA plans to 

develop in response to this recommendation, are also one element contained in 

the manual. As the OIG reported, TSA inconsistently followed the DOT 

policies and did not document the instances in which TSA chose not to follow 

DOT policy. 

The OIG holds that the TSA personnel security management program should 

operate under guidelines with a breadth similar to DOT personnel security 

management policies. Currently, the DHS draft Interim Personnel Security 

Directive can provide much of this structure for TSA, but it is incumbent upon 

TSA to elaborate how it will implement the general policy. DHS has noted 

that component agencies are not prohibited from exceeding the minimum 

standards set within the Interim Personnel Security Directive. Screener 

adjudication guidelines address one of the personnel security management

areas in which TSA may develop more specific policies to implement the 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 52 
Appendix B

OIG Evaluation of Management Comments

general DHS policy. TSA should describe in its action plan the steps the CPO 

is taking to adopt policies and procedures for personnel security management. 

Recommendation 9: Document the Credentialing Program Office 

workload and then plan and hire staff to meet workload requirements. 

TSA responded that the CPO has completed an analysis of its workload. TSA 

found that significant, additional personnel and budgetary resources would be 

required to meet the office’s multiple program requirements. TSA reported 

that the CPO received additional personnel allocations and is working to fill 

vacancies. In addition, the CPO continues to measure and document its 

workload in order to assist in future resource allocation. 

It is not clear to the OIG that TSA’s staffing plans will enable the CPO to 

adapt to a high workload, like the one that helped cause the backlog of 

thousands of screener background checks. Although it is unlikely TSA will 

repeat hiring screeners at such high volume, it is likely that other credentialing 

programs, such as background checks for hazardous materials transportation 

workers, will cause the CPO workload to swell. In its action plan, TSA should 

include the CPO workload analysis and a copy of the hiring plan based on that 

analysis. 

Recommendation 10: Ensure that TSA program managers formally 

document contract modifications and instructions, maintain a substantive 

presence with contractors in order to provide guidance and oversight, 

and require status reports to track mission accomplishment. 

TSA responded that several steps have been taken to improve control over the 

work of TSA contractors. Coordinating with the TSA Contracting Office, the 

CPO has implemented a policy for documenting contract modifications. 

Second, TSA reported that CPO maintains contractor oversight through 

meetings, desk audits, and reviewing reports; also, TSA illustrated previous

examples of the onsite assistance to contractors that CPO provided. Finally, 

TSA noted that it incorporated performance reporting requirements in its 

newly awarded contract with Kroll Government Services, Inc. 

The OIG accepts TSA’s response. In support of its action plan, TSA should 

provide the OIG with a copy of the policy for documenting contract 

modifications and instructions and a copy of the performance reporting 

requirements set for Kroll Government Services, Inc. TSA should also explain 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 53 
Appendix B

OIG Evaluation of Management Comments

in greater detail its practices for monitoring the quality of contractor work 

related to the background check process. 

Recommendation 11: Create a personnel security management tracking 

system that provides management with accurate, timely, and integrated 

information on the status of security investigations. The information 

should reflect the complete cycle of personnel security management, 

including data on incoming staff, separations, and reconsiderations.

TSA described the Background Investigation Tracking System (BITS) 

database that the CPO developed to consolidate and manage personnel 

security information. BITS currently contains information on the screener 

background checks, and the CPO is expanding it to incorporate additional 

information about CPO workload and status. TSA also stated that it plans to 

coordinate its database for tracking security clearances with that of the DHS 

Personnel Security Division, a task DHS is requiring of all components. 

TSA agreed with the OIG that the CPO needs a comprehensive and integrated 

database and tracking system, but TSA stated that it lacks available 

informational technology support to provide them. 

The OIG acknowledges that over the past few months the CPO has made 

significant progress in automating its personnel security information. 

However, TSA’s response insufficiently addresses the recommendation. Our 

report suggested that many of the weaknesses in tracking the screener 

background checks arose from the poor link between Human Resources data, 

including that on incoming staff, separations, and reconsideration requests, 

and CPO data. The OIG affirms the recommendation that TSA develop a 

stronger system for linking this data. If TSA’s informational technology 

resources are insufficient to provide a comprehensive solution at this time, 

then TSA should pursue an interim solution. In its action plan, TSA should 

describe the steps it is taking to ensure that the CPO develops and receives the 

information necessary to track and manage personnel security investigations 

in an accurate and timely manner, including at a minimum key Human 

Resources data. 

Recommendation 12: Improve records management policies, procedures, 

and practices governing the content, organization, and storage of 

personnel security management case files. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 54 
Appendix B

OIG Evaluation of Management Comments

TSA stated that it has undertaken a variety of actions to improve the handling 

and storage of personnel security files. TSA is developing standards for the 

content of personnel security files and quality assurance mechanisms to ensure 

the standards are met. TSA also plans to reorganize personnel security files 

and to store them securely. Furthermore, TSA noted that it has improved the 

handling and storage of disciplinary files containing personnel security 

information. With input from the Human Resources Office, TSA revised its 

procedures for storing and safeguarding these disciplinary files, and TSA is 

auditing them to ensure proper content. 

The OIG accepts TSA’s response. TSA should begin securing the personnel 

security files at the earliest possible opportunity. Developing standards for the 

content of personnel security files will be another important step in improving 

TSA’s policies for managing personnel security records. In support of its 

action plan, TSA should provide the OIG with a copy of the standards for 

content, organization, and storage of the personnel security files. TSA should 

also note its timeline for implementing the standards and any quality 

assurance reviews or audits planned to ensure the standards are met. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 55 
Appendix C

Recommendations 

We recommend that the TSA Administrator: 

Recommendation 1: Complete screener position risk designations with input 

from the personnel security officials of the Department of Homeland Security 

and from appropriate TSA offices, including the Credentialing Program

Office, Human Resources Office, and Aviation Operations. Screener position 

risk designation records, position descriptions, and vacancy announcements 

should reflect the correct designation. 

Recommendation 2: Complete the comparison study of the effectiveness of 

Office of Personnel Management and private sector background checks. 

Incorporating the review’s results, the Administrator should modify screener 

background checks as needed to ensure they suit the position risk designation, 

meet Department of Homeland Security standards, and are cost-efficient. 

Recommendation 3: Ensure, without exception, that all screeners undergo a 

fingerprint-based criminal history records check and receive a favorable 

adjudication before they begin training and work. 

Recommendation 4: Incorporating guidance from the Department of 

Homeland Security, define the role that contract adjudicators will play in 

TSA’s background check process and the minimum requirements that TSA 

must meet to fulfill its oversight responsibilities.

Recommendation 5: Institute precautions to protect against terminations that 

are based on incorrect information. 

Recommendation 6: Establish mechanisms to prevent and abort background 

checks on applicants and employees whom TSA disqualifies. 

Recommendation 7: Strengthen procedures for completing and retaining the 

Employment Eligibility Verification Form (Form I-9). 

Recommendation 8: Implement personnel security management policies and 

procedures and document departures from them. 

Recommendation 9: Document the Credentialing Program Office workload 

and then plan and hire staff to meet workload requirements. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 56 
Appendix C

Recommendations 

Recommendation 10: Ensure that TSA program managers formally 

document contract modifications and instructions, maintain a substantive 

presence with contractors in order to provide guidance and oversight, and 

require status reports to track mission accomplishment. 

Recommendation 11: Create a personnel security management tracking 

system that provides management with accurate, timely, and integrated 

information on the status of security investigations. The information should 

reflect the complete cycle of personnel security management, including data 

on incoming staff, separations, and reconsiderations. 

Recommendation 12: Improve records management policies, procedures, and 

practices governing the content, organization, and storage of personnel 

security management case files. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 57 
Appendix D 

28 Disqualifying Convictions

Pursuant to 49 U.S.C. § 44936(b) and 49 C.F.R. § 1542.209(d), applicants 

convicted of one or more of the following 28 felony crimes within the past ten 

years are not eligible to serve as screeners: 

1. Forgery of certificates, false marking of aircraft, and other aircraft 

registration violation, 49 U.S.C. 46306; 

2. Interference with air navigation, 49 U.S.C. 46308; 

3. Improper transportation of a hazardous material, 49 U.S.C. 46312; 

4. Aircraft piracy, 49 U.S.C. 46502; 

5. Interference with flight crew members or flight attendants, 49 U.S.C. 

46504; 

6. Commission of certain crimes aboard aircraft in flight, 49 U.S.C. 46506; 

7. Carrying a weapon or explosive aboard aircraft, 49 U.S.C. 46505; 

8. Conveying false information and threats, 49 U.S.C. 46507; 

9. Aircraft piracy outside the special aircraft jurisdiction of the United States,

49 U.S.C. 46502(b); 

10. Lighting violations involving transporting controlled substances, 49 

U.S.C. 46315; 

11. Unlawful entry into an aircraft or airport area that serves air carriers or 

foreign air carriers contrary to established security requirements, 49 

U.S.C. 46314; 

12. Destruction of an aircraft or aircraft facility, 18 U.S.C. 32; 

13. Murder; 

14. Assault with intent to murder; 

15. Espionage; 

16. Sedition;

17. Kidnapping or hostage taking; 

18. Treason; 

19. Rape or aggravated sexual abuse; 

20. Unlawful possession, use, sale, distribution, or manufacture of an 

explosive or weapon; 

21. Extortion; 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 58 
Appendix D 

28 Disqualifying Convictions

22. Armed or felony unarmed robbery; 

23. Distribution of, or intent to distribute, a controlled substance; 

24. Felony arson; 

25. Felony involving a threat; 

26. Felony involving: 

a) willful destruction of property; 

b) importation or manufacture of a controlled substance; 

c) burglary; 

d) theft; 

e) dishonesty, fraud, or misrepresentation; 

f) possession or distribution of stolen property; 

g) aggravated assault; 

h) bribery; or 

i) illegal possession of a controlled substance punishable by a 

maximum term of imprisonment of more than one year; 

27. Violence at international airports, 18 U.S.C. 37; 

28. Conspiracy or attempt to commit any of the criminal acts listed above. 

 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 59 
Appendix E 

Major Contributors to This Report 

Melissa M. Howard, Ph.D., Chief Inspector 

William J. McCarron, Senior Inspector 

E. Wynne Krause, Inspector 

In addition, Marcia M. Hodges, Senior Inspector, and Meredith Megles, 

Senior Inspector, provided valuable contributions to the research for this 

report. 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 60 
Appendix F 

Report Distribution 

Department of Homeland Security

 Deputy Secretary 

Under Secretary, Border and Transportation Security 

Chief, Personnel Security Division 

 DHS OIG Liaison 

Transportation Security Administration

 Administrator, Transportation Security Administration 

Director, Credentialing Program Office 

Director, Human Resources Office 

Director, Aviation Operations 

OIG Audit Liaison, Office of Transportation Security Policy 

Office of Management and Budget

Homeland Bureau Chief

OIG Budget Examiner 

Congress

 

Congressional Oversight and Appropriations Committees as appropriate 

Review of Background Checks for Federal Passenger and Baggage Screeners at Airports Page 61 
Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General (OIG) at (202) 

254-4100, fax your request to (202) 254-4285, or visit the OIG web site at www.dhs.gov. 

OIG Hotline 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or 

noncriminal misconduct relative to department programs or operations, call the OIG Hotline 

at 1-800-323-8603; write to Department of Homeland, Washington, DC 20528, Attn: Office 

of Inspector General, Investigations Division – Hotline. The OIG seeks to protect the identity 

of each writer and caller.