DEPARTMENT OF DEFENSE

Internal Review of the

Washington Navy Yard Shooting

A Report to the Secretary of Defense

Under Secretary of Defense for Intelligence • November 20, 2013

APPROVED FOR PUBLIC RELEASE

1

Executive Summary

Approximately 5 million people employed by or affiliated with the 

Department of Defense are eligible for access to classified information.

“We like to give people the benefit of the doubt.” Response by a Navy 

official when asked why records of Aaron Alexis’ arrests and non-judicial 

punishment were never reported in the Joint Personnel Adjudication 

System

“Insiders are always the most dangerous.” Gavin de Becker1

1. Introduction

On September 16, 2013, Aaron Alexis, a Navy contractor employee with a 

Secret security clearance, shot and killed 12 U.S. Navy civilian and contractor 

employees and wounded several others at the Washington Navy Yard. Alexis was 

also killed.

Alexis was employed by The Experts, Inc., a private information technology 

firm cleared under the National Industrial Security Program. The Experts 

was a subcontractor to Hewlett-Packard Enterprise Services, which was 

performing work under a contract with the Department of the Navy. Pursuant 

to his employment with The Experts, Alexis was assigned to a project at the 

Washington Navy Yard and began working there on September 9, 2013.

On September 14, 2013, Alexis purchased a Remington 870 12-gauge shotgun 

and ammunition at a gun shop in Northern Virginia. He also purchased a hacksaw 

and other items at a home improvement store in Northern Virginia, using the 

hacksaw to modify the shotgun for concealment.

On the morning of September 16, Alexis arrived at the Washington Navy Yard. 

He had legitimate access to the Navy Yard as a result of his work as a contractor 

employee and used his valid building pass to gain entry to Building 197. Shortly 

after his arrival in the building and over the course of about one hour,

1 Gavin de Becker is president of Gavin de Becker & Associates, Inc., a private security company. Mr. de Becker 

provided a briefing to the Internal Review Team on an automated threat assessment system designed to predict 

and prevent acts of targeted violence.

DEPARTMENT OF DEFENSE

Internal Review of the

Washington Navy Yard Shooting

A Report to the Secretary of Defense
2 3

Alexis used the Remington 870 shotgun and a Beretta handgun he obtained 

during the attack to kill 12 individuals and wound 4 others before he was shot 

and killed by law enforcement officers.

On September 30, 2013, the Secretary of Defense initiated concurrent 

independent and internal reviews to identify and recommend actions that address 

gaps or deficiencies in DoD programs, policies, and procedures regarding 

security at DoD installations and the granting and renewing of security clearances 

for DoD employees and contractor personnel.

2. Conclusions and Significant Findings

Following mass shootings and other incidents of targeted violence, the immediate 

question that springs to mind is “What did we miss?” The Department asked this 

question in 2009 after Major Nidal Hasan shot and killed 13 people and wounded 

43 others in Fort Hood, Texas. We asked this question in 2012 after Specialist 

Ricky Elder fatally shot his battalion commander and then turned the gun on 

himself. We are asking this question again today, in the wake of the tragedy at 

the Washington Navy Yard. Guided by the Terms of Reference (Appendix A), the 

Internal Review Team conducted an exhaustive examination of Alexis’ historical 

record provided by the Department of the Navy (Appendix B) and applicable 

personnel security and installation access policy. The team also analyzed 

previous incidents in which an insider inflicted significant harm, in order to gain 

a better understanding of the causes and common characteristics of these events. 

The results of the team’s examinations provide the basis for the findings and 

recommendations in this report.

At the time of the shooting, Aaron Alexis was a vetted member of the U.S. 

Navy Individual Ready Reserve and a defense contractor employee cleared to 

the Secret level. He was authorized access to the Washington Navy Yard and to 

Building 197 through the use of his DoD Common Access Card (CAC) and valid 

building pass. The Internal Review Team found the Washington Navy Yard was 

in general compliance with DoD installation access policies, although random 

vehicle or bag inspections were not conducted in accordance with DoD policy. 

There is no way to know, however, whether more frequent inspections might 

have given law enforcement personnel the opportunity to discover the weapon 

Alexis carried onto the installation and neutralize or minimize the immediate 

threat.

At various points during Alexis’ military service and subsequent employment as a 

cleared contractor — from the background investigation in 2007 to the disturbing 

behaviors he exhibited in the weeks leading up to the shooting — the review 

revealed missed opportunities for intervention that, had they been pursued, may 

have prevented the tragic result at the Washington Navy Yard. When examining 

events in Aaron Alexis’ history individually, they yield little in the way of 

warning. Combined, however, they demonstrate a pattern of misconduct and 

disturbing behavior that would have prompted investigators, for a position of 

trust in the Federal workforce, if they had been aware of his history in aggregate.

What vulnerabilities in DoD programs, policies, 

or procedures regarding physical security at DoD 

installations and the security clearance and reinvestigation 

process can be strengthened?

The Internal Review Team identified several vulnerabilities that may have alerted 

the Department to the potential threat before the incident occurred. The team’s 

significant findings, summarized below, are detailed in section 7 of this report:

• The Office of Personnel Management (OPM) background investigation 

was missing critical information.

• The Navy granted Alexis a Secret security clearance with specified 

conditions, but there was no oversight mechanism in place to ensure 

compliance.

• Alexis’ Navy command did not report in the security system of record 

multiple incidents of adverse information during Alexis’ active duty 

service.

• Alexis’ employer, The Experts, Inc., had no insight into Alexis’ chronic 

personal conduct issues during his Navy service when they hired 

him and placed him in a position that required access to classified 

information.

• Alexis’ employer did not report behaviors indicating psychological 

instability and did not seek assistance from a mental health professional 

or guidance from the Defense Security Service.

• Although the Review found no direct ties to gaps in physical security 

practice and the actual events of September 16, planned cuts in physical 
4 5

security and vulnerability assessments funding and an overall lack of 

compliance with installation access control policy2

 are likely to leave 

the Department vulnerable to threats to mission assurance.

Although the findings above did ultimately play a role in the events that occurred 

on September 16, it is important to note that the vulnerabilities the team 

identified in personnel security clearance or installation access processes do not 

signify culpability for this mass shooting. Even if those vulnerabilities had not 

been present, neither the personnel security process nor the physical security 

capability is equipped or designed to prevent the kind of violence exhibited by 

Aaron Alexis. A holistic, centralized threat management capability, as directed 

in the Secretary of Defense’s March 26, 2013, memorandum,3

 is essential to 

effectively prevent violent behavior in the workplace.

How should the Department address these vulnerabilities 

to prevent incidents of targeted violence in the future?

The most effective methods to prevent targeted violence in the workplace must 

be employed long before someone enters an installation with a weapon. The 

Internal Review Team developed a series of recommendations, outlined in 

section 7 and summarized below, designed to provide the Department with such a 

threat prevention strategy. Pillars of an effective threat prevention strategy should 

include:

• A centralized insider threat management capability that leverages 

multidisciplinary subject matter experts and links to functional and 

organizational areas of responsibility.

• A continuous evaluation program that provides actionable information 

in real time on the entire cleared DoD population, is serviced by 

the DoD Consolidated Adjudications Facility (CAF), folds in DoD 

Intelligence Community personnel as appropriate, and is scalable to 

include all DoD personnel subject to suitability or fitness adjudications.

• A physical security approach that employs defense in depth using 

technology and manpower to reduce risk and mitigate potential threats.

2 DoD Inspector General Report, “Navy Commercial Access Control System Did Not Effectively Mitigate Access 

Control Risks,” September 16, 2013 

3 Secretary of Defense memorandum, “Final Recommendations of the Defense Science Board on Predicting Violent 

Behavior,” March 26, 2013

Transforming DoD Security and Insider Threat 

Assessment Capabilities

To achieve these objectives, the Internal Review Team recommends the 

Department:

• Establish a DoD Insider Threat Management and Analysis Center 

(DITMAC) to provide a centralized capability that can quickly analyze 

the results of automated records checks and reports of behavior of 

concern and recommend action as appropriate.

• Leverage existing continuous evaluation capability while continuing to 

develop and implement a DoD Continuous Evaluation Program.

• Accelerate the Defense Manpower Data Center’s development of 

the Identity Management Enterprise Services Architecture (IMESA) 

to enable DoD Components to share access control information and 

continuously vet individuals against U.S. Government authoritative 

databases.

Way Ahead

The Deputy Secretary of Defense will synthesize the findings of the Independent 

Review Team with those from the Internal Review and concurrent reviews 

conducted by the Secretary of the Navy. The Deputy Secretary will consolidate 

key recommendations from each of these reviews into a final report to be 

provided to the Secretary of Defense by December 20, 2013.

If approved, the key components of the effective threat management capability 

described above should be placed under the authority, direction and control of a 

single Principal Staff Assistant that would align multiple security disciplines and 

enable cross-functional insider threat assessment and response. The Principal 

Staff Assistant would develop an implementation plan in coordination with the 

DoD Components and the Office of the Director of National Intelligence.
6 7

Internal Review of the 

Washington Navy Yard Shooting

3. Overview and Methodology

On September 30, 2013, the Deputy Secretary of Defense directed the Under 

Secretary of Defense for Intelligence, in coordination with senior representatives 

from each of the Military Departments, the Joint Staff, and the Office of the 

Secretary of Defense, to lead a DoD-wide Internal Review to:

• Examine the security programs, policies, processes, and procedures 

related to the shooting;

• Identify vulnerabilities or weaknesses that may have alerted the 

Department to the threat before the incident occurred; and

• Recommend actions to enable the Department to prevent such incidents 

from occurring in the future.

Concurrently, the Secretary established an Independent Review Team to focus 

on the same objectives as the Internal Review without any potential institutional 

constraints with regard to its findings and recommendations. In parallel with 

these efforts, the Secretary of the Navy commissioned his own series of “rapid 

reviews” focused on Department of the Navy installations, procedures, and 

policy.

The three review teams established a shared foundation of facts to avoid 

duplicative requests to the Department and other organizations for the same 

information. The teams each assessed the data and arrived at conclusions 

independently. Following the submission of this report to the Deputy Secretary 

of Defense, the Internal Review Team’s findings and recommendations will be 

consolidated with those of the Independent Review Team and the Department of 

the Navy reviews.

The Internal Review Team established working groups to review the principal 

areas identified in the Terms of Reference: the personnel security clearance and 

reinvestigation process and physical security at DoD installations. The working 

groups hosted focused interviews and discussions to inform the assessment 

process and provided regular input to the Internal Review Team, which came 

DEPARTMENT OF DEFENSE

Internal Review of the

Washington Navy Yard Shooting

A Report to the Secretary of Defense
8 9

together twice weekly to receive briefings and interview briefers in accordance 

with the task. The Internal Review Team consolidated the input of both working 

groups with data extracted from the research of policy and other documentation 

to develop this report. As directed in the Terms of Reference, the team:

• Considered findings and recommendations from previous relevant 

reports and studies.

• Examined all applicable laws, policies, and regulations, including DoD 

directives, instructions, and manuals.

• Included interviews with appropriate senior officials (health affairs, law 

enforcement and force protection, first responders, intelligence) and 

other pertinent individuals.

• Formulated recommendations for correcting problems and enhancing 

internal controls to prevent similar incidents in the future and mitigate 

associated risk.

4. Personnel Security Clearance Process

4.1 Overview

The personnel security clearance process is governed primarily by Executive 

Order 129684

, Executive Order 134675, and the Federal Investigative Standards. 

DoD governing issuances include the January 1987 DoD Regulation 5200.2.R, 

“DoD Personnel Security Program” (with changes), and the April 1999 DoD 

Directive 5200.2, “DoD Personnel Security Program.” The DoD issuances have 

undergone significant revision over time, and new versions are in various stages 

of the formal coordination process in the Department. 

The DoD directive will be replaced by DoD Instruction 5200.02, which has 

been under review with the Office of Management and Budget (OMB) since 

September 2012. The DoD regulation will be replaced by a comprehensive 

two-volume DoD manual. DoD Manual 5200.02 – Volume 1, “DoD Personnel 

Security Program (PSP): Investigations for National Security Positions and 

Duties,” is en route to the Office of Management and Budget for interagency 

review and posting in the Federal Register for comment. DoD Manual 

4 Executive Order 12968, “Access to Classified Information,” August 2, 1995, as amended

5 Executive Order 13467, “Reforming Processes Related to Suitability for Government Employment, Fitness for 

Contractor Employees, and Eligibility for Access to Classified National Security Information,” June 30, 2008

5200.02 – Volume 2, “DoD Personnel Security Program (PSP): Adjudications, 

Due Process, Continuous Evaluation, and Security Education,” is in formal 

coordination within the Department. The Department has also developed a new 

issuance, DoD Instruction 5200.kk, “Investigative and Adjudicative Guidance 

for Issuing the Common Access Card (CAC).” After formal coordination in the 

Department, this instruction will be forwarded to OMB for interagency review 

and posting in the Federal Register for comment. 

The Department of Defense has about 4.6 million non-intelligence agency 

military, civilian, and contractor personnel who have been deemed eligible for 

access to classified information. Of these, 2.5 million currently have access to 

classified information as follows:

➢ Top Secret or Top Secret/Secret Compartmented Information: 875,785

➢ Secret: 1,670,495

➢ Confidential: 1,824

4.2 Background Investigations and Clearance 

Adjudication

A “personnel security investigation” (PSI) is any investigation required to 

determine the eligibility of military, civilian, or government contractor personnel 

for a national security position, including those with access to classified 

information. All PSIs are conducted by the designated investigative service 

provider. In the case of the Department of Defense, the U.S. Office of Personnel 

Management (OPM) is the designated investigative service provider. 

There are different PSIs required for the levels of security clearance based on 

position sensitivity. For a Secret clearance, applicants must have a National 

Agency Check with Local Agency Checks and Credit Check (NACLC) or an 

Access National Agency Check with Written Inquiries (ANACI). NACLCs 

and ANACIs are valid for continued eligibility for 10 years from the date of 

investigation closure, provided the subject does not have a consecutive break in 

service of more than 2 years. 

For a Top Secret clearance or Top Secret with access to Sensitive Compartmented 

Information (SCI), an applicant must have a Single Scope Background 

Investigation (SSBI) at a minimum. SSBIs are valid for 5 years from the date of 

investigation closure, provided the subject does not have a consecutive break in 

service of more than 2 years. 
10 11

OPM forwards completed investigations to the DoD Consolidated Adjudications 

Facility (CAF) or the intelligence agency CAFs, as appropriate, for adjudication. 

An adjudicator assigned to a case will review the PSI and make a clearance 

determination, identifying potential disqualifying information and applicable 

mitigating factors within the parameters of the 13 National Adjudicative 

Guidelines. 

A “periodic reinvestigation” (PR) is an investigation conducted to update a 

previously completed background investigation. Currently, PRs are required at 

the following intervals:

➢ every 5 years for a Top Secret clearance or access to a highly sensitive 

program

➢ every 10 years for a Secret clearance

➢ every 15 years for a Confidential clearance

4.3 U.S. Office of Personnel Management

In 2005, the Department of Defense transferred most of its personnel security 

investigative workload and investigators to OPM. The Department pays OPM 

approximately $700 million annually to complete investigations.

How much does an initial security clearance cost per person?

SSBI for Top Secret and Top Secret/SCI clearance: $3,959 

ANACI for civilian employee Secret clearance: $272

NACLC for military and contractor Secret clearance: $210* 

*20–25% of investigations for Secret access require subject interviews to 

resolve issues, at an additional cost of $550 per person.

(Cost data effective FY 2014)

4.4 DoD Consolidated Adjudications Facility

In 2011, the Department’s personnel security adjudicative organizations relocated 

to Fort Meade, Maryland, as part of the 2005 Base Realignment and Closure 

Committee recommendations. The Department subsequently established the 

DoD CAF to consolidate resources and standardize adjudicative processes. 

Beginning in October 2012, the DoD CAF began a phased consolidation of the 

seven non-intelligence agency CAFs: 

• The Joint Staff

• Army

• Navy

• Air Force

• The Adjudicative Division of the Defense Office of Hearings and 

Appeals

• Defense Industrial Security Clearance Office

• Washington Headquarters Services

Today, the DoD CAF comprises more than 700 employees, manages clearances 

for a population of about 4.6 million non-intelligence agency personnel with 

security clearance eligibility, and provides support to about 43,500 DoD 

organizational security managers and contractor facility security officers.

The DoD CAF determines the security clearance eligibility of non-intelligence 

agency DoD personnel occupying sensitive positions and/or requiring access to 

classified material. These determinations involve all military service members, 

civilian employees, contractor personnel working at 26 Federal agencies under 

the National Industrial Security Program, and consultants affiliated with the 

Department of Defense. The DoD CAF also makes favorable adjudicative 

determinations for employment suitability of DoD civilian employees and 

determinations for CAC credentialing of non-cleared DoD contractor personnel.
12 13

A Snapshot of Security Clearance Statistics

Average annual personnel security clearance 

determinations in FY 2013 850,000

Clearances denied or revoked annually in FY 2013 10,500 (1.2%)

Conditional clearances and waivers 

granted annually in FY 2013 4,600

Percentage of OPM investigations 

assessed as inadequate or incomplete 31%

4.5 Intelligence Reform and Terrorism 

Prevention Act

The Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) 

required the Executive branch to establish a plan that, beginning in December 

2009, would require, to the extent practicable, 90 percent of all background 

investigations and adjudications for personnel security to be completed within 

an average of 60 days from date of receipt of investigation requests by the 

designated investigative agency. The 60-day average period allowed: 

• no more than 40 days to complete the investigative phase of the 

clearance review; and

• no more than 20 days to complete the adjudicative phase of the 

clearance review.

IRTPA also required that determinations on clearances not made within 60 days 

would be made without delay.

In 2012, the Director of National Intelligence, pursuant to his authority in 

Executive Order 13467 as Security Executive Agent, further refined the original 

IRTPA standards by establishing timeliness requirements specific to Top Secretlevel clearances. The fastest 90 percent of Top Secret-level investigations and 

adjudications must be completed within 100 days.

4.6 Adverse Information Reporting

DoD policy requires commanders, heads of organizations, and cleared 

contractors in the National Industrial Security Program to develop and maintain 

a program that ensures all pertinent derogatory information regarding cleared 

personnel is forwarded for consideration in the personnel security clearance 

determination process. The DoD CAF is notified of derogatory information 

typically through the Joint Personnel Adjudication System (JPAS), which is 

the DoD system of record for personnel security clearance adjudication and 

management. Derogatory information is reported in the form of “incident 

reports” in JPAS.

The DoD CAF receives about 45,000 incident reports a year on cleared personnel 

who have had security-related issues; examples include bankruptcies, arrests 

for driving under the influence, mental health issues, and security violations. 

Most of these incident reports are based on information that is self-reported 

by the cleared individual. Other reports are based on information reported by 

supervisors, co-workers, or other government agencies. 

4.7 Personnel Security Program Continuous 

Evaluation Initiatives 

The Federal Investigative Standards (FIS), which set the parameters for 

conducting PSIs and PRs in the Federal Government, were revised in December 

2012. Once the FIS are fully implemented in the Department of Defense, all 

personnel in national security positions will be required to have a PR every 5 

years (regardless of the level of clearance), and a portion of personnel with Top 

Secret clearances will be subject to a continuous evaluation process as prescribed 

by the Director of National Intelligence as the Security Executive Agent.

The Department has pursued numerous initiatives to implement some form of 

continuous evaluation as part of the Personnel Security Program. Executive 

Order 12968 was amended in 2008 by Executive Order 13467 to add Subsection 

3.5, “Continuous Evaluation,” which established that all individuals who have 

access to classified information are subject to continuous evaluation. 

In 2005, the Defense Personnel Security Research Center (PERSEREC) 

developed the Automated Continuing Evaluation System (ACES) to 

electronically check records for the continuous evaluation of cleared DoD 

employees. Currently, ACES is capable of checking over 40 government and 

commercial databases in areas relevant to personnel security and even applying 

business rules to identify those individuals who may present a potential security 

risk. ACES complies with legal and regulatory provisions for the protection of 

individual privacy and permissible uses of government and commercial data. 

ACES provides some current capability for the Department to conduct some 
14 15

continuous evaluation of up to 100,000 personnel annually as authorized by 

national policy while the Department develops the “next generation” ACES 

capability.

A recent pilot test with a sample of 3,370 Army service members, civilian 

employees, and contractor personnel demonstrated that ACES was able to 

identify 731 individuals with previously unreported derogatory information (21.7 

percent of the tested population), prompting 176 reinvestigations to resolve or 

adjudicate that derogatory information. Of this group, 99 individuals had serious 

derogatory information (e.g., financial issues, domestic abuse, drug abuse, or 

prostitution). Based on the results of this test, the Army revoked the clearances 

of 55 of these individuals and suspended the access of the remaining 44. 

Implementation of ACES, as approved by the Director of National Intelligence, 

would enable the Department to detect unreported derogatory information and 

greatly improve its ability to mitigate risk. ACES’ functionality also has the 

potential to serve as a continuous evaluation tool for employment suitability 

and CAC credentialing pursuant to Homeland Security Presidential Directive 12 

(HSPD-12), discussed immediately below.

5. Installation Access Control Process

DoD minimum installation access control standards are based on the mandate of 

HSPD-12 to provide a common identification standard for all Federal employees 

and contractors. Federal Information Processing Standard 201-2 prescribes the 

standards for identity verification, issuance, and use of the common identity 

standard. 

All Federal departments and agencies are required to use an eligible personal 

identity verification credential to ensure interoperability for access to facilities, 

installations, and information systems. The DoD personal identity verification 

credential is the CAC. The CAC provides a level of identity assurance and a 

standardized method of authentication for Federal and contractor employees, and 

it is the principal identity credential for supporting interoperable access to DoD 

installations, facilities, buildings, and controlled spaces. Upon presentation of 

a CAC at a perimeter access control point, the individual’s identity is verified 

either electronically or through physical/visual inspection to enable the holder to 

access the installation or facility. 

DoD policy directs non-Federal Government and non-DoD-issued card holders 

who are given unescorted access to DoD installations to be identity proofed and 

vetted to determine fitness and eligibility for access. DoD policy further directs 

that personnel must be vetted against government authoritative data sources, to 

include the National Crime Information Center (NCIC) and Terrorist Screening 

Database (TSDB).

Key policies of the Department’s physical security access control program 

require the Military Departments to implement the following: 

• Biometrically enabled background security screening

• Identification card security features

• Identity-proofing and vetting

• Database interfaces

• Access control point widening and construction (e.g., vehicle and 

pedestrian gates/lanes and entrapment and inspection areas)

• DoD-wide installation of interoperable security hardware (e.g., CAC/

identification card readers, computer systems, closed circuit television 

monitors, barriers)

• Trained security and law enforcement personnel

• CAC/identification card visual inspection requirements and issuance/

revocation procedures

6. The Insider Threat Perspective: 

Comparative Incidents

Fort Hood, Texas, 2009

On November 5, 2009, U.S. Army Major Nidal Malik Hasan shot and killed 13 

people and wounded 43 others in Fort Hood, Texas. It was the single largest 

mass shooting event on a U.S. military installation in the Nation’s history. 

Before his assignment to Fort Hood, Hasan worked as an intern and resident 

at Walter Reed Army Medical Center. His colleagues and superiors there 

expressed concern about his behavior and comments. Hasan was described as 

socially isolated, increasingly and vocally opposed to the wars in Afghanistan 

and Iraq, and troubled by his work with traumatized Soldiers returning from 

combat. In the year leading up to the attack, Hasan was known to have been in 
16 17

communication with Anwar Al-Awlaki expressing interest in jihad and suicide 

attack. Army commanders were notified of his e-mails to Awlaki, but at the time 

their communications were deemed non-threatening.

“Whether internal threats target a computer system, classified information, 

or personnel, research suggests they may often share common indicators. 

The effort to identify threats may be enhanced by exploiting any common 

indicators and integrating the disparate programs designed to defend 

against these threats.”

“Protecting the Force: Lessons from Fort Hood,” Report of the DoD 

Independent Review, January 2010 

WikiLeaks, 2010

In May 2010, U.S. Army Specialist Bradley Manning was arrested for leaking the 

largest number of classified documents to the public in U.S. history through the 

website operated by WikiLeaks, an international organization opposing secrecy. 

In the months leading up to the unauthorized disclosure, Manning displayed 

behaviors indicating instability through multiple emotional and physical 

outbursts, expressed discontent with the Army and the Federal Government, 

and disregarded basic security measures common to all classified working 

environments.

Washington Navy Yard, 2013

On September 16, 2013, then-Navy contractor employee Aaron Alexis concealed 

a sawed-off shotgun in a backpack and used it to kill 12 Navy employees 

and injure 4 others at the Washington Navy Yard before he was killed by law 

enforcement personnel. He was previously an active duty Sailor, had several 

arrests — two of which involved firearms — and, in the weeks leading up to the 

incident, he was observed complaining of being followed, hearing voices, and of 

being under attack by vibrations and microwaves.

Although these incidents differ in both circumstances and outcome, all three 

incidents — each inflicting historic damage to the Department and to DoD 

employees — have several common characteristics:

• The perpetrators had all been granted security clearances. They were 

all trusted insiders.

• Before causing such damage to the Department, all had telegraphed 

their personal dissatisfaction with their employers or were observed 

exhibiting aberrant behavior.

• All had legitimate access to the facilities in which they committed their 

offenses. 

It is through these commonalities that the Internal Review Team sought to 

apply lessons learned from the previous incidents to its examination of the 

Washington Navy Yard shooting. To support this effort, the team reviewed the 

August 2012 Defense Science Board report on predicting violent behavior6

 and 

other authoritative sources, to include briefings from the Federal Bureau of 

Investigation’s Behavioral Analysis Unit and other experts on violent behavior. 

The Defense Science Board report’s final recommendations relating to violent 

behavior, approved by the Secretary of Defense in March 2013, included a 

Department-wide “threat management approach employing multidisciplinary 

professionals” as a holistic method of addressing targeted violence. 

The team’s research revealed that both acts of violence and of deliberate 

unauthorized disclosure have the same root causes, and perpetrators engage in 

planning and preparation steps that are often detectable, providing an opportunity 

to disrupt an intended act. 7

 Threat management principles, therefore, can be 

employed to avert not only incidents of targeted violence but also deliberate acts 

of unauthorized disclosure. 

As a direct result of the WikiLeaks disclosures, the President issued “National 

Insider Threat Policy and Minimum Standards for Executive Branch Insider 

Threat Programs” in November 2012. The cover memorandum signed by the 

President states, “... elements [of an insider threat program] include the capability 

to gather, integrate, and centrally analyze and respond to key threat-related 

information; monitor employee use of classified networks; provide the workforce 

with insider threat awareness training; and protect the civil liberties and privacy 

of all personnel.” 

While some elements of such a departmental program may exist today, they 

are not organized under policy, oversight and funding into compliance with 

national policy. In September 2013, the Deputy Secretary of Defense designated 

 6 Defense Science Board Task Force Report, “Predicting Violent Behavior,” August 2012

 7 Ibid.
18 19

the Under Secretary of Defense for Intelligence (USD(I)) as the senior official 

charged with overseeing insider threat efforts in the Department. 8

7. Findings and Recommendations

7.1 Key Findings

Finding 1. The OPM investigation was missing critical 

information.

Although the 2007 OPM background investigation of Alexis did include a 

follow-up subject personal interview to resolve discrepancies in Alexis’ SF-86 

information, multiple discrepancies remained undetected and unchallenged by 

OPM. During this subject interview, Alexis characterized his 2004 arrest in 

Seattle for “malicious mischief” as nothing more than an altercation with another 

individual that escalated, in which he (Alexis) retaliated by “deflating the tires” 

of the other individual’s car. 

Alexis did not disclose that he accomplished this by shooting out the tires 

with his Glock .45 caliber handgun in a residential area. The Seattle Police 

Department incident report (Appendix B), which OPM did not obtain, reveals an 

account that is markedly different from the one Alexis portrayed in his subject 

interview. He was initially charged in the King County District Court with 

malicious mischief (a felony), although this charge was dismissed. The Seattle 

Police Department then referred the incident to the Seattle Municipal Court 

on the lesser charges of property destruction and discharge of a firearm (these 

charges were likewise dismissed). 

In addition to the 2004 arrest, which may have brought to light early behaviors 

of potential mental instability, there was incomplete or discrepant information in 

Alexis’ reported references, education, delinquent debts, places of address, and 

foreign travel. A more thorough investigation may have given the Department 

of the Navy Central Adjudication Facility (DONCAF) sufficient facts on which 

to simply deny Alexis security clearance eligibility instead of granting eligibility 

with specified conditions.

8 Secretary of Defense Memorandum, “Appointment of the DoD Senior Official Charged With Overseeing Insider 

Threat Efforts,” September 25, 2013

Finding 2. The Navy granted Alexis a Secret security 

clearance with specified conditions, but there 

was no oversight mechanism in place to ensure 

compliance. 

Upon review of the OPM investigation, DONCAF identified potentially 

disqualifying conditions in the areas of personal conduct, financial 

considerations, and criminal conduct. However, DONCAF determined these 

conditions were mitigated under the National Adjudicative Guidelines and 

granted Alexis’ Secret security clearance eligibility in 2008, with a warning 

letter to Alexis via his commanding officer advising that his eligibility was 

granted only under the conditions that he seek financial counseling, resolve 

his outstanding indebtedness, and maintain financial solvency. Although this 

warning was entered in JPAS, there was no process in place for DONCAF to 

monitor compliance, and there is no evidence Alexis’ commanding officer took 

action to ensure Alexis met the conditions, as was required in the warning letter.

Finding 3. Alexis’ Navy command did not report in the 

security system of record multiple incidents 

of adverse information during his active duty 

service.

During his active duty, despite two additional arrests (one of which also involved 

discharge of a firearm) and chronic personal conduct issues resulting in formal 

counseling and imposition of non-judicial punishment, the Navy reported none of 

this adverse information in JPAS. Alexis’ command at the time did not consider 

reporting his misconduct in any security system of record, because Alexis did 

not need to access classified information in the course of his regular duties. 

This perception is common in the Department, as the existing DoD policy is 

not clear. Volume 2 of the new DoD Manual 5200.02, which is in the formal 

coordination process, contains language that clarifies the requirement to report 

adverse information on all individuals who are eligible for access to classified 

information, regardless of whether they actually access classified information. 

DoD Manual 5220.22-M, “National Industrial Security Program Operating 

Manual (NISPOM),” states that “Contractors are required to report certain events 

that impact the status of an employee’s personnel security clearance (PCL).”
20 21

Finding 4. Alexis’ employer, The Experts, Inc., had no 

insight into Alexis’ chronic personal conduct 

issues during his Navy service when they hired 

him and placed him in a position that required 

access to classified information. 

With no adverse information recorded in JPAS and no break in service in 

excess of 2 years, Alexis remained eligible for a Secret security clearance after 

his release from active duty and transition to the Individual Ready Reserve 

in the Navy in January 2011. Subsequently, Alexis was hired in September 

2012 by The Experts, Inc., which served as a subcontractor to Hewlett Packard 

Enterprise Services (HPES), LLC. When The Experts first hired Alexis, there 

was no information available in JPAS that would have alerted the company to 

any misconduct while on active duty in the Navy. The Experts did perform a 

background check as required by the terms of its contract with HPES, but this 

background check revealed no issues of concern. It is not known whether The 

Experts, as part of its hiring process, contacted any references such as Alexis’ 

former Navy supervisor to ascertain his fitness for employment. If The Experts 

had been aware of Alexis’ prior history, this information may have led The 

Experts to assess his erratic, troubling behavior in August 2013 as that indicative 

of an individual who might pose a threat to himself or others.

Finding 5. Alexis’ employer did not report behavior 

indicating psychological instability and did 

not seek assistance from a mental health 

professional or guidance from the Defense 

Security Service. 

The Experts became aware of Alexis’ erratic behavior during August 2013 and 

was sufficiently concerned to remove Alexis’ access in JPAS temporarily but 

did not report the incident in JPAS or seek guidance from the Defense Security 

Service about whether it should be reported. The employer’s decision not to 

report Alexis’ behavior appears to be influenced by a lack of awareness about 

what types of behaviors are considered “adverse” information that must be 

reported (particularly those related to mental health issues). Anecdotal evidence 

suggests a reluctance to report adverse information for a variety of reasons (for 

example, reluctance to “ruin a career” over something that may be deemed minor 

or isolated, or because of a personal relationship). This lack of awareness and 

reluctance to report is not limited to the cleared contractor community, but is also 

prevalent government-wide. 

This illustrates a gap in existing processes and training of security personnel 

regarding psychological conditions associated with significant security or safety 

risks. While reporting of criminal behavior is a relatively straightforward area, 

reporting of behaviors that indicate psychological impairment is not well defined 

in policy. Compounding this problem is the lack of a centralized structure that 

can receive and assess such reports and recommend interventions or caretaking 

actions that may disrupt an individual’s potential path to committing violence. 

There may be reluctance to report mental health-related behaviors in particular 

and confusion on when to report such behaviors, because an adverse information 

report is often viewed as potentially punitive rather than a caretaking or 

intervening measure. Additionally, JPAS is the DoD system of record for 

personnel security clearance adjudication and management, not a mechanism 

designed to seek help from mental health professionals. Consequently, even if 

The Experts had reported the August incidents in JPAS, it is unknown whether 

such reporting might have provided an opportunity for intervention measures to 

prevent the shooting in September. However, The Experts did not seek assistance 

from a mental health professional to assess the potential for violence based on 

Alexis’ behavior.

Finding 6. Although the Review found no direct ties to 

poor physical security practice and the actual 

events of September 16, planned cuts in 

physical security and vulnerability assessment 

funding and an overall lack of compliance with 

installation access control policy introduce risk 

and could be a factor in the future.

The Fiscal Year 2008 National Defense Authorization Act directs the Secretary 

of Defense to develop access standards applicable to all military installations in 

the United States, to include the ability to determine the fitness and verify the 

identity of all visitors. Not all visitors are being vetted before gaining unescorted 

access to DoD installations. The Defense Installation Access Control (DIAC) 

Working Group, under the auspices of the DoD Physical Security Equipment 

Action Group, is developing a Joint Concept Technology Demonstration effort 
22 23

called the Identity Management Enterprise Services Architecture (IMESA) to 

serve as the overarching architecture. This architecture will allow all Military 

Departments’ physical access control systems to share information and provide 

a continuous information management capability that continuously updates 

information in the authoritative databases. 

Vulnerability assessments are a critical tool to enable commanders to identify 

vulnerabilities and mitigate risk. A Joint Staff Integrated Vulnerability 

Assessment (JSIVA) evaluates an installation’s ability to deter and/or respond to 

a terrorist incident. Due to fiscal constraints, beginning in FY 2015, the Defense 

Threat Reduction Agency will reduce the number of JSIVAs from 80-100 each 

year to 30 (up to a 70 percent reduction). Fiscal constraints also impact the 

Military Departments’ ability to initiate their own assessment programs. As a 

result, some installations will go without a higher headquarters vulnerability 

assessment.

7.2 Key Recommendations

Transforming DoD Security and 

Insider Threat Assessment Capabilities

Effective insider threat mitigation requires a more coordinated and consolidated 

approach to security policies and reporting capabilities. These roles provide 

distinct challenges for mitigation of associated threats and are not always 

integrated or synchronized. Information that could identify DoD personnel 

who are insider threats is available from numerous sources (e.g., personnel 

security, physical security, information assurance, counterintelligence, human 

resources, and law enforcement), to include mental health evaluations, but is not 

centralized or integrated. This inability to integrate and evaluate information 

in a “whole person” context is, in large part, because of the lack of a single 

centralized function or authority with the responsibility to aggregate, evaluate, 

and appropriately disseminate insider threat information. 9

“Continuous evaluation” is traditionally viewed as an information system; 

rather, it is a process and capability to generate informed decisions regarding 

the trustworthiness of DoD personnel based on the composite of organizational 

information and the linkage of that information through technology 

9 The September 25, 2013 Deputy Secretary of Defense memorandum appointed the USD(I) as the senior official 

charged with overseeing DoD insider threat efforts. The Department is drafting its Insider Threat Policy and 

Implementation Plan, in accordance with the National Insider Threat Policy and Minimum Standards and E.O 

13587.

infrastructure. To get to that capability, the Department should create a DoD 

Insider Threat Management and Analysis Center (DITMAC). The DITMAC 

would serve as the “one stop shop” to consolidate and analyze all DoD reporting 

of potentially adverse information, to include potential insider threat information. 

The DITMAC would also be responsible for:

• Tasking the automated records checks system

• Analyzing the results for continuous evaluation

• Sending identified issues to the appropriate responding organization for 

further evaluation and action

The DITMAC should be a multifunctional team composed of law enforcement, 

mental health, counterintelligence, security, human resources, information 

assurance, cybersecurity, and legal personnel. The DITMAC should include 

a 24-hour watch center to respond to emergent issues, which would satisfy 

a Department of Justice requirement for 24-hour command center capability 

to access the TSDB. It should also be responsible for developing training 

requirements for identification and mitigation of insider threats. 

The DITMAC must be closely aligned and should perhaps be co-located with 

the DoD CAF. In implementing a continuous evaluation program, the number of 

new investigations and additional adjudicative responsibility can be expected to 

increase, at least initially. The DoD CAF would need to be augmented to handle 

the additional workload imposed by continuous evaluation.

Both the DITMAC and the DoD CAF would depend on two critical information 

technology platforms: the Defense Information System for Security (DISS) 

and the Automated Continuous Evaluation System (ACES). DISS has more 

capability and flexibility than JPAS, was developed in 2005 and has not yet been 

fully resourced as a DoD system of record. For the DITMAC to be effective and 

for the DoD CAF to reach its full potential, DISS should be funded, built, and 

maintained appropriately. 

As described in section 4.7, ACES is the first-generation automated continuous 

evaluation system. This system operates on an “on demand” basis and can 

evaluate up to 100,000 personnel annually. In its present state, ACES has limited 

operational utility for continuous evaluation of the entire cleared population. 

Further, it does not have the ability to gather and present new information 

continuously and in real time. However, with sufficient funding, the Department 

can begin immediately to evaluate potentially high-risk populations (e.g., 

personnel with overdue PRs, those with access to Special Access Program 
24 25

information, and those cleared for access to Top Secret information and above) 

while the next-generation system is completed.

Development of the next-generation system is already under way; however, additional 

research is required before its concepts are fully realized and its compliance with 

Director of National Intelligence continuous evaluation requirements established. The 

next-generation system leverages IMESA, a continuous evaluation platform to be 

used at the local command level for installation access. Because IMESA is still in the 

concept demonstration phase, it is not yet a DoD system of record. 

ACES, IMESA, and the DITMAC would constitute the critical elements of a 

Departmental continuous evaluation program and provide the foundation for an 

effective insider threat program. To avoid stovepipes in policy and procedures that 

inhibit effective threat management, the resourcing, policy requirements, and oversight 

responsibility should fall under a single Principal Staff Assistant in the Office of the 

Secretary of Defense. Currently, ACES is led by the Under Secretary of Defense for 

Personnel and Readiness, and IMESA is led by the Under Secretary of Defense for 

Acquisition, Technology and Logistics.

Implementation of all of these elements, in aggregate, would address most of the 

findings in this review. In addition, it will facilitate DoD compliance with the National 

Insider Threat Policy issued by the President in 2012.10 

The concept of bringing critical security components under a single governance 

structure is not new: in 2010, the Under Secretary of Defense for Intelligence 

conducted a study on improving DoD security through the establishment of a DoD 

security field activity. 11 On a smaller scale, the Defense Intelligence Agency has 

already established such a structure, which serves as a model for a successful crossfunctional effort for mitigating insider threat through continuous evaluation of 

personnel. 

10 Presidential Memorandum, “National Insider Threat Policy and Minimum Standards for Executive Branch Insider 

Threat Programs,” November 21, 2012

11 Office of the Under Secretary of Defense for Intelligence, “Feasibility Study for the Establishment of a DoD 

Security Field Activity, December 15, 2010

Primary Recommendations: 

Mitigating Insider Threat Through Continuous Evaluation

Recommendation 1. 

Establish an organizational framework under the 

authority, direction and control of a single Principal Staff 

Assistant that would align multiple security disciplines 

and enable cross-functional insider threat assessment and 

response.

Recommendation 2. 

Within such an organizational framework, establish a 

DoD Insider Threat Management and Analysis Center 

to provide a centralized capability that can quickly 

assess reports of behavior that may be of concern and 

recommend action as appropriate. Establishment of the 

DITMAC :

• Leverages the 2012 Defense Science Board recommendation for a 

Threat Management Unit concept to prevent and mitigate various types 

of insider threat.

• Aligns with DoD efforts to implement a DoD insider threat program. 

• Integrates and aligns existing information reporting to 

counterintelligence, information assurance, law enforcement, human 

resource, and security entities. 

• Serves as a “one stop shop” leveraging the capabilities of subject matter 

experts.

• Synchronizes efforts with those of the DoD CAF and the DoD 

Intelligence Community CAFs.
26 27

Recommendation 3. 

Leverage existing ACES capability while continuing to 

develop and implement a DoD Continuous Evaluation 

Program. The first-generation ACES could enable the 

Department to assess high-risk populations within the 

pool of cleared personnel and identify potential issues that 

may not have been reported. The next-generation ACES 

capability would:

• Support the CAFs and proposed DITMAC.

• Assist with local level vetting/installation access control through 

IMESA.

• Be executed in compliance with the Director of National Intelligence 

requirements under his role as Security Executive Agent.

Recommendation 4. Accelerate the Defense Manpower 

Data Center’s development of IMESA to enable DoD 

Components to share access control information and 

continuously vet individuals against U.S. Government 

authoritative databases. Procure electronic physical 

access control systems that provide capability to rapidly 

and electronically authenticate credentials and individuals 

authorized to enter an installation.

Supporting Recommendations: Enabling the DITMAC

• Provide additional human resources to the DoD CAF to enable more 

thorough evaluation of investigative products.

• Accelerate implementation of the Defense Information System for 

Security.

• Based on insider threat training requirements and standards established 

by the DITMAC, develop an education and awareness program to train 

the trusted population and continuously reinforce:

o The importance of reporting any concerning behaviors via a 

centralized, objective, automated mechanism that is not designed to 

be negative or punitive.

o The importance of supervisors’ roles in “managing the 90 percent and 

referring the 10 percent” who cause concern.

o The message that early intervention on behalf of people struggling 

with real or perceived issues is a win-win for everyone, including the 

organization. 

Interim Recommendations: 

Closing Gaps in Existing Policies and Procedures

Background Investigations

• Establish standards for completeness of background investigation forms 

and facilitate their electronic management and storage.

• Accelerate and expand efforts to reformat SF-86 data and reports of 

investigation to support more automated, efficient, consistent, and 

reliable detection of potential security concerns. 

• Revise the Federal Investigative Standards to require OPM to provide 

copies of all records reviewed in the course of investigations to the 

DoD CAF, including arrest records or other documentation associated 

with criminal conduct. This will ensure investigators and adjudicators 

have the information they need to detect and resolve discrepancies 

adequately, enabling a more informed adjudicative process.

• Require OPM to obtain signed statements from the subjects of 

significant issue cases. 

• Director of National Intelligence reconsider adopting the Question 21 

language recommended in a PERSEREC technical report,12 which 

proposes a two-part relevant risk approach to Question 21 focusing on 

standardized clinical conditions that could pose a security risk as well 

as mental health-related hospitalizations. 

Adjudication and Security Clearance Oversight

• Update the National Adjudicative Guidelines for Determining 

Eligibility for Access to Classified Information, Guideline I, 

12 Jonathan Shedler and Eric Lang, Executive Summary of PERSEREC Technical Report, “A Relevant Risk 

Approach to ‘Question 21’: Security Clearance Inquiries Regarding Mental Health,” May 4, 2012 (revised 

September 3, 2013
28 29

“Emotional, mental, and personality disorders,” to specify standardized 

clinical conditions associated with heightened security, safety and 

reliability risk.

• Consider expanding the mission of the DoD CAF to include 

adjudications, both favorable and unfavorable, of background 

investigations to support HSPD-12 suitability determination.

• Ensure adjudicators have the means by which to request additional 

information or investigative activity when they believe the information 

they have is insufficient or leaves discrepancies unresolved.

• Develop a mechanism by which the DoD CAF can track waivers 

and conditional clearances granted and take action to revoke or deny 

continued clearance eligibility for non-compliance.

• Task the DoD Components to review their JPAS records to ensure data 

accuracy.

• Require DoD Component and agency heads to validate annually the 

need for security clearances for individuals who are eligible but have 

not required access in the past 12 months.

• Hold security personnel accountable for incident reporting.

• Working with the Office of the Director of National Intelligence, 

identify appropriate protocols for the inactivation of eligibility at a time 

less than 24 months after a break in service occurs.

Security Education and Training

• Develop more rigorous training requirements for component security 

managers and industry facility security officers.

• Evaluate, update, and standardize security education and training 

on identifying reportable behaviors and events, how they should be 

reported, and to whom. Establish recurring training requirements to 

ensure that all personnel — including supervisors, commanders, and 

security managers — are continuously reminded and demonstrate 

knowledge of their responsibility to report incidents of security 

concern.

• Include security training at all commanders’ courses and in professional 

military education.

Installation Vulnerability Assessments

• Fund the JSIVA program in FY 2015 and beyond until the Department 

transitions to a broader Mission Assurance Assessment Capability 

in order to retain the Chairman’s critical independent vulnerability 

assessment capability.

8. Detailed Assessment of DoD Programs, 

Policies, and Procedures

The Internal Review Team examined a variety of DoD programs, policies, and 

procedures in the context of the Washington Navy Yard shooting to identify 

issues that may present Department-wide vulnerabilities. Using the Terms of 

Reference in Appendix A as the overarching guideline, the team assessed the 

adequacy and effectiveness of DoD policy and procedures related to:

• Personnel security background investigations, clearance adjudications 

and reinvestigations

• Suitability and fitness determinations for personnel in positions that 

don’t require access to classified information

• Continuous evaluation of DoD personnel and contractors between 

investigation periods

• Information-sharing and the accuracy and completeness of investigation 

and adjudication verification databases

• Self-reporting, suspicious activity reporting, and incident reporting

• Access to DoD facilities

• Privately-owned weapons on DoD installations

• Vulnerability assessment capabilities to address gaps in physical 

security procedures

The team also examined:

• Leadership roles and responsibilities for suspension or revocation 

of facility access credentials, or for initiating a security clearance 

reinvestigation

• Impact of changes to “insider threats” on security requirements, 

programs and policies
30 31

• Programming, budgeting and resourcing for physical security 

infrastructure

The team established two working groups to assess each of the areas defined 

in the Terms of Reference. The results of their assessments are detailed below 

and include supporting recommendations to address gaps or inconsistencies 

in existing DoD policy, procedures, and processes. These recommendations 

augment the key recommendations of the Internal Review Team in section 7 and 

will serve to strengthen the Department’s overall security posture.

Personnel Security Clearance Process

Initiating the Investigation: Standard Form 86, 

Questionnaire for National Security Positions

Alexis provided incomplete and inaccurate information on the Standard Form 86, 

“Questionnaire for National Security Positions,” which was required to initiate 

his background investigation. In addition to failing to disclose arrests, criminal 

conduct, delinquent debts, and foreign travel, Alexis provided invalid information 

regarding employment, education, and personal references that should have 

been detected when his application was reviewed and approved. As an example, 

Alexis claimed he lived in Washington State from March 2001 – February 2007, 

yet he also claimed he was employed in the State of New York from January 

2001 – March 2003.

OPM’s published guidance to those initiating investigations advises only that the 

submitting offices are responsible for ensuring the completeness of forms and 

does not explain how to review the SF-86 information.13 

Current DoD policy contains little guidance on the roles and responsibilities for 

officials initiating personnel security investigations. Policies state that those 

initiating officials should provide instructions and applicants should follow 

instructions, but do not articulate standards for either. 

The Department lacks policy and specific standards to ensure the quality and 

completeness of the SF-86 and other standard forms. Consequently, DoD 

Components do not use consistent instructions for completing the SF-86 forms 

and give inconsistent guidance to personnel completing the forms regarding what 

to include and the level of detail they should provide.

13 OPM’s INV 15 Handbook, “Requesting OPM Personnel Investigations,” states at page 14: “The Submitting 

Office is responsible for ensuring completeness of the SF-85, SF-85P, SF-85PS, and SF-86. The agency must 

have an individual complete all information required, as OPM will not accept incomplete investigation requests.”

Most personnel complete the SF-86 electronically using OPM’s Electronic 

Questionnaires for Investigations Processing (e-QIP) system. Electronic forms 

offer an excellent opportunity to leverage technology to detect anomalies or 

inconsistencies in reported information. OPM’s electronic application validation 

rules are not currently configured to evaluate the validity and logical consistency 

of information applicants provide; rather, they only reject entries based on the 

format of the data entered.

Recommendations:

• Improve assessments and accountability for the quality and completeness 

of information submitted on background investigation application forms. 

• Strengthen requirements, clarify roles and responsibilities, and enhance 

the capability to detect falsification, invalid information, and other 

inaccuracies on the SF-86 and other standard forms.

• Develop and require the use of minimum standards for completeness of 

information in applications for national security positions, including those 

that do not require access to classified information. 14

• Enforce penalties that can be imposed on subjects who falsify information 

on the SF-86 such as fines, imprisonment, or denial of security clearance 

eligibility.

• Establish a database of DoD personnel’s SF-86 application data for 

electronic analysis to detect anomalies and to inform decisions about risk 

thresholds more effectively. 

Availability of Records in the Report of Investigation

The OPM Report of Investigation (ROI) did not contain a copy of the incident 

report associated with the 2004 arrest in Seattle. Electronic queries of Federal 

and state-wide criminal and court record databases typically do not return 

arrest reports or court transcripts and thus cannot provide critical details about 

circumstances surrounding charges and arrests.

14 The Defense Security Service Center for Development of Security Excellence has two training products that 

provide guidance on completing the SF-86, but they do not specifically advise reviewers to look for discrepancies 

or gauge investigative usefulness. Guidance for industry facility security officers (FSOs) in NISPOM Section 

2-202, “Procedures for Completing the Electronic Version of the SF 86” addresses the requirement to review the 

SF-86 for adequacy and completeness, but does not provide guidance on determining adequacy.
32 33

While the FBI and the Washington statewide checks disclosed the fact of Alexis’ 

arrest and other charges, the specific details were missing. For many subjects, 

FBI and state-wide databases are missing criminal record information altogether 

that would be accessible through local agency checks. Most records of charges, 

arrests, dispositions, detention, and court proceedings can only be obtained 

through queries or site visits to individual local agencies.

Federal statute requires cooperation in background investigations for certain 

records providers.15 

16 However, investigative service providers may not have 

adequate access to local criminal arrest records due to lack of cooperation by 

local authorities, or they may be overly relying on centralized electronic checks 

without conducting in-person leads to view or obtain actual arrest reports. These 

may preclude investigators and adjudicators from accurately documenting and 

evaluating circumstances surrounding criminal conduct, as is required by the 

National Adjudicative Guidelines. As a result, investigators and adjudicators are 

sometimes forced to rely on the subject’s account of the “facts” during his or her 

interview to evaluate the circumstances and the extent to which issues have been 

mitigated.

Overall, OPM does not provide to adjudicators copies of many of the records 

they review in the course of investigations. For example, OPM is not 

required by Federal investigative standards to collect and provide copies of 

personnel, enlistment, and other records that are generated or obtained as part 

of applications for employment or military enlistment. If these documents are 

provided with the ROI, however, adjudicators can easily cross-reference them 

with SF-86 information to help identify discrepancies. Too often, investigators 

conducting subject interviews and adjudicators evaluating results must rely on 

subject self-reporting and second-hand summaries of information. An added 

benefit of providing adjudicators with all information used in employment 

applicant and military enlistment processing is they can notify human resource 

or military personnel when they become aware that applicants provided false or 

fraudulent information to gain entry.

15 Title 5, United States Code Section 9101, “Access to criminal history records for national security and other 

purposes,” effective October 30, 2000

16 The 1985 Security Clearance Information Act requires Federal, State, and local criminal justice agencies to 

release criminal history record information to Federal agencies for purposes of national security clearance 

investigations. (Public Law 99-169, Title VIII, codified in part at 5 U.S.C. §9101).

Recommendations:

• OPM should provide copies of all records reviewed in the course 

of investigations to the DoD CAF, including arrest records or other 

documentation associated with criminal conduct. This will ensure 

investigators and adjudicators have the information they need to 

adequately detect and resolve discrepancies, enabling a more informed 

adjudicative process.

• OPM should report to the Department of Defense and Office of the 

Director of National Intelligence those agencies that do not comply with 

the Security Clearance Information Act by failing to provide relevant 

records and the reasons why. This data would inform proposed legislation 

to strengthen criminal history record information sharing. 

Undetected Discrepancies in Self-reported Information 

Upon enlisting in the Navy, Alexis received the minimum level of investigation 

required for military service, the National Agency Check with Local Agency 

Checks and Credit Check (NACLC). OPM identified Alexis’ unreported 

delinquent debts and the 2004 arrest in Seattle but failed to detect other invalid 

and inconsistent information Alexis provided. Alexis’ credit report provided 

further evidence of unlisted education, residences, and possible employment that 

was not identified or addressed in the investigation.

Investigators (and later adjudicators) may have missed the discrepancies 

in Alexis’ SF-86 because NACLC investigative standards do not include 

employment, education, residence, and reference checks. In most instances, 

investigators and adjudicators are not currently required to assess whether 

education information provided by applicants is accurate and complete.

This should be partially mitigated once the December 2012 Federal Investigative 

Standards are implemented. The new standards require verifying employment 

and education for military enlistment and Secret-level investigations. They 

also articulate thresholds that require expanded investigation, including 

“discrepancies” in personal history information. However, the thresholds could 

be strengthened with additional language to specifically draw attention to logical 

inconsistencies between one or more pieces of information provided on standard 

forms and identified in the course of investigations (e.g., evidence of student 

loans on credit reports but no college education listed on the standard form).
34 35

Inconsistent and invalid applicant data often remain undetected partly because 

standard form data and reports of investigation are not provided in organized, 

sortable formats that allow adjudicators to detect anomalies quickly. The 

Department adjudicates more than half a million Secret-level clearance and 

military enlistment investigations and a quarter-million Top Secret-level 

investigations each year. This volume, coupled with an emphasis on meeting 

IRTPA timelines, does not allow adjudicators time to restructure the data 

manually and conduct a detailed review of every application and investigation.17 

Some discrepancies won’t be detected because many investigations are 

incomplete. Overall, at least 31 percent of the investigations forwarded to 

the DoD CAF are incomplete, although incomplete cases are not necessarily 

deficient. For example, OPM may forward an incomplete investigation 

where the investigator has exhausted all reasonable avenues to satisfy a lead 

requirement. In such cases, adjudicators have the latitude to accept some 

incomplete investigations. In some cases, adjudicative facilities have found ways 

to work with or supplement incomplete investigative products. In response to 

the April 2009 Government Accountability Office audit of the DoD personnel 

security clearance process, the Under Secretary of Defense for Intelligence 

published guidance in March 2010 clarifying how adjudicators should handle 

such incomplete investigations.

Recommendations:

• OPM should establish and enforce higher standards for the completeness 

of subject interviews, in part by ensuring that investigators have all 

documentation to formulate relevant and effective questions, and address 

all occurrences of omission, falsification, inconsistencies, or any other 

concealment of information or issues.

• OPM and DoD should accelerate and expand efforts to reformat SF-86 

data and reports of investigation to support more automated, efficient, 

consistent, and reliable detection of potential security concerns. 

• Adjudicator training should reinforce their ability and responsibility to 

request additional information to resolve issues as needed so they can 

make an informed adjudicative determination. Accelerate efforts to 

17 The Review Team spent about 2 hours manually reorganizing and analyzing Alexis’ case file. The team identified 

numerous inconsistencies missed by both investigators and adjudicators. However, given the size of the Secretlevel population alone and the current number of adjudicators (460 at the DoD CAF), detailed analysis of every 

case is impossible. Each adjudicator has about 20 minutes to process a case.

use publicly-available electronic information as an investigative source 

for initial eligibility determinations, reinvestigations, and continuous 

evaluation.18

• Expand and fund the use of polygraphs for issue resolution to obtain 

information from subjects that would otherwise not be known through 

other sources.

Security Clearance Adjudication

DONCAF adjudicators identified potentially disqualifying conditions for Alexis’ 

security clearance eligibility but found them to be mitigated in accordance with 

existing adjudicative guidelines. DONCAF did find the issues to be of enough 

concern to issue a warning letter to Alexis via his commanding officer specifying 

certain conditions Alexis was required to meet to retain his clearance eligibility. 

There is no evidence to suggest the commanding officer followed up on this 

requirement or ensured Alexis took the appropriate steps to meet the conditions.19

The current 13 National Adjudicative Guidelines contain a general guideline 

called “Personal Conduct.” This guideline is a “catch-all” of sorts and contains a 

wide range of issues and behaviors that are not specifically covered elsewhere in 

the Guidelines. It is rarely used by itself to initiate an unfavorable adjudication, 

but rather is used in conjunction with issues covered under other guidelines. 

Consequently, the Guidelines may not sufficiently articulate the importance of 

subjects’ honesty in applications and interviews.

Recommendations:

• Require DoD CAF oversight of conditional clearance eligibility 

determinations. DoD CAF should create a mechanism to track and 

monitor all conditional clearances and waivers to adjudicative standards, 

18 Preliminary results from the Army G2/ODNI’s Assessment of Emerging Technologies for use in Continuous 

Evaluation Phase 2 show that social media checks identify evidence about illegal drug and alcohol use, arrests, 

images and text that may suggest an underlying psychological condition to include thoughts of despair or 

hopelessness, a desire to die by suicide, and more. In Alexis’ case, a check of publicly available information on 

the internet may have surfaced mug shots from his Texas 2010 firearm-related arrest. 

19 The warning letter required that Alexis maintain financial solvency and ensure any future personnel security 

questionnaires are complete and accurate prior to submission.
36 37

and take action to revoke or deny eligibility for non-compliance after a 

specified period (no more than 12 months). 

• Clearances granted with warnings should be monitored through 

continuous evaluation to ensure the issues do not recur.20

• Consider revising the National Adjudicative Guidelines to list an 

applicant’s deliberate omission or falsification of reportable information 

on the SF-86 as a behavior that will normally result in an unfavorable 

clearance action or administrative termination of further processing for 

clearance eligibility. 

• Revise adjudicator training to support decisions of denial/revocation in 

instances of intentional misrepresentation or omission of facts on forms or 

during interviews.

Incident Reporting and Continuous Evaluation

After DONCAF’s favorable Secret eligibility determination in 2008, neither 

the Navy nor Alexis’ cleared employer reported any adverse information about 

Alexis’ conduct in JPAS. During Alexis’ Navy career, there were two arrests and 

one instance of non-judicial punishment that should have been reported. Alexis’ 

command at the time did not consider reporting his misconduct in any security 

system of record, because Alexis did not need to access classified information in 

the course of his regular duties. 

During the final weeks of his employment with The Experts, Alexis displayed 

behavior and made statements that indicated psychological problems of security 

concern. Following an August 4 incident at the Norfolk airport and subsequent 

incidents August 6-7 in Newport, Rhode Island, The Experts was sufficiently 

concerned to remove Alexis from access in JPAS and send him home to rest. 

Based on the information available to The Experts at the time (which included 

none of Alexis’ misconduct prior to and during his employment in the Navy), 

The Experts determined he was fit to return to work, restoring his access in JPAS 

on August 9. At the time, The Experts also considered whether reporting this 

incident in JPAS was appropriate and believed it was not reportable because 

the incident did not involve criminal activity, nor had Alexis been referred to a 

medical facility for psychiatric evaluation. 

20 A condition denotes action on the part of the subject. A warning usually directs the subject not to do something. 

At a minimum, clearances with conditions should receive oversight to ensure that the conditions are met. Subjects 

of warnings could be monitored through continuous evaluation record checks, once available.

The above indicates that DoD and industry personnel do not have a consistent 

understanding of incident reporting and security oversight requirements and 

procedures, particularly for individuals who are eligible but not actually granted 

access. To illustrate the scope of this issue, there are more than 2.5 million 

personnel with current access to classified information, and another 2.1 million 

personnel who are eligible but not currently in access. Many security personnel 

believe that continuous evaluation and periodic reinvestigation requirements 

don’t apply to personnel who are simply “eligible” for access. Consequently, 

they may not report issues potentially affecting an individual’s eligibility. 

In hindsight, members of the review team and those contacted in the course 

of the review agreed that Alexis displayed behavior and made statements that 

indicated psychological problems of security concern. However, neither training 

that pertains to National Adjudicative Guideline I (Emotional, mental, and 

personality disorders) nor Question 21 on the SF-86 provides any specificity or 

guidance regarding those psychological conditions that are associated with the 

greatest risk that an individual may pose a security or safety concern. Greater 

specificity about clinical conditions of greatest security concern might:

• reduce ambiguity on what individuals must self-report; 

• appropriately reduce the number of individuals required to report 

mental health counseling, by eliminating low-risk psychological 

conditions (thereby reducing stigma and investigation costs);

• clarify this area of reporting requirements for co-workers, supervisors, 

human resources and security personnel, and; 

• clarify when psychological assessments should be ordered and how the 

results should be used. 

The value of greater specificity, however, must be weighed against the potential 

vulnerability created by focusing too much on a narrow set of risks. Additionally, 

many people with psychological conditions lack the insight into the fact that they 

are ill; and very often, clinicians disagree about diagnoses.

The Department does not have a single, consolidated repository of security 

incident information. JPAS is the official system of record for reporting issues 

of personnel security concern; however, the DOD CAF receives incident reports 

using methods other than just JPAS. The Intelligence Community relies on 

its own system for issue reporting. It is also likely that there are componentspecific records containing adverse information that could bear on an individual’s 

continuing eligibility for access to classified information. 
38 39

The process for identifying and acting on security incidents and behaviors of a 

national security concern relies heavily on individuals, co-workers, managers, 

supervisors, and commanders to report information to their security managers or 

FSOs. An enterprise-wide continuous evaluation capability would help mitigate 

gaps in information obtained through self-reporting and would complement a 

threat management capability. The Department has existing capability to conduct 

continuous evaluation checks between regularly scheduled investigations and is 

developing a robust continuous evaluation system that would enable real-time 

automatic notifications of issues of security concern.

Recommendations:

• Implement and invest in an enterprise-level continuous evaluation system 

to augment and enable audits of reporting by individuals, co-workers, 

supervisors, and security professionals. An effective continuous evaluation 

program may increase the number of self-reports, as personnel may decide 

to report rather than have their behavior discovered. It may also serve as a 

deterrent to unacceptable behavior if there is a greater risk of being caught.

• Update policy and issue specific DoD-wide procedures for reporting security 

incidents and behaviors of security concern so that all personnel, regardless 

of their roles and responsibilities and location in the organization, know what 

to report, how to report, and to whom.21 Clarify that reporting requirements 

apply to all clearance-eligible individuals as well as non-cleared individuals 

with unsupervised access to DoD installations and facilities. 

• Implement and enforce policy that holds security managers and supervisors 

accountable for failures to file incident reports on events that meet clearly 

defined reporting thresholds.

• Require annual certification by supervisors, commanders, security 

managers, and other personnel that they understand, have complied with, 

and will continue to comply with incident reporting policy.22

21 Policy on security incident and reportable behavior reporting are dispersed across security disciplines. For 

example, policy is contained in personnel security issuances like DoD 5200.2-R, industrial security issuances like 

DoD 5220.22-M, National Industrial Security Program Manual (NISPOM), Defense Security Service Industrial 

Security Letters, and information security issuances like DoDI 5200.01.

22 For example, a recent PERSEREC report (TR 13-02) provides background information and a concept of 

operations for a simple procedure called the Personal Acknowledgment of Staff Security (PASS). The purpose of the 

proposed procedure is to increase supervisor awareness, felt responsibility, accountability, and reporting of behaviors 

related to foreign intelligence entity threats in accordance with DoD Directive 5240.06, Counterintelligence 

Awareness and Reporting (CIAR), May 17, 2011. The defining feature of PASS is the requirement of a signed 

certification by supervisors that they understand and intend to comply with reporting policy.

• Evaluate, update, and standardize security education and training on 

identifying reportable behaviors and events, how they should be reported, 

and to whom. Establish recurring training requirements to ensure that all 

personnel — including supervisors, commanders, and security managers 

— are continuously reminded and demonstrate knowledge of their 

responsibility to report incidents of security concern.

• Update Question 21 on the SF-86 to specify standardized clinical 

conditions associated with heightened security, safety, and reliability risk. 

Suitability and Fitness Determinations for Personnel who do 

not Require Access to Classified Information 

Investigations for suitability evaluations (and contractor fitness) are comparable 

to investigations for security clearances and will be further aligned with 

implementation of the Revised Federal Investigative Standards. Under the 

current investigative standards, all suitability investigations require employment, 

education, residence, and reference checks or inquiries, whereas security 

investigations for military and contractor Secret-level clearances do not.

Historically, adjudications for investigations of personnel in positions that do not 

require access to classified information have been decentralized and of unknown 

consistency. Effective October 1, 2013, the DoD CAF became responsible for 

favorable suitability adjudications of DoD and contractor personnel in positions 

that do not require access to classified information. Under current policy, adverse 

suitability23 adjudications are retained by the individual DoD Components. The 

community is divided on whether the DoD CAF should also adjudicate applicants 

under HSPD-12 for Common Access Cards (CACs). Some in the community 

feel that risk management for installation and information access can only be 

done effectively at the Component level. Others believe that the decentralization 

of potentially adverse suitability determinations reduces oversight and consistent 

standards for adjudicating what is likely the highest risk group of personnel based 

on issues identified in their background investigations. 

Overall, the Review Team found insufficient oversight of suitability 

determinations. DoD Components either do not consistently report all 

adjudication actions for suitability determinations into OPM’s Clearance 

23 The term “suitability” is used to refer to HSPD-12 eligibility, suitability for employment in the competitive and 

senior executive service, fitness for employment in the excepted service, and fitness for employment as a contract 

employee.
40 41

Verification System (CVS), or OPM does not enter all adjudication actions 

received into CVS. Additionally, as of October 2013, the Department had nearly 

185,000 active personnel in JPAS with eligibility reported as “No Determination 

Made.”24 For these latter cases, it is not known whether anyone ever reviewed 

the results of the investigations or whether the adjudicators simply did not have 

a JPAS code available to indicate a favorable suitability determination (separate 

from eligibility for access to classified information). Regardless, incomplete 

adjudications and missing adjudicative data undermine effective oversight, 

reciprocity, and accountability.

Recommendations:

• Expand consolidation of adjudications for DoD background investigations 

to include all HSPD-12 determinations in addition to security clearance 

determinations, and direct the required resources to the DoD CAF.25 

• Improve accountability for, and remove barriers to, reporting of suitability 

adjudications and HSPD-12 determinations.

Investigation and Adjudication Verification Databases............

Data pertaining to Alexis’ initial investigation and adjudication status were 

recorded in JPAS. As discussed, however, JPAS did not contain incident reports 

pertaining to criminal arrests, military non-judicial punishments, and aberrant 

behavior that would have warranted incident reports. 

Additionally, although Alexis’ enlistment, separation, and employment data were 

entered correctly in JPAS, the Internal Review Team learned that DoD security 

managers do not reliably update data with respect to the status of their current 

24 Alexis’ initial adjudication of his background investigation was reported as “No Determination Made.” In 

his case, however, the Navy requested his investigation be adjudicated for eligibility for access to classified 

information.

25 As of October 1, 2013, the DoD CAF assumed responsibility for favorable adjudications for suitability, public 

trust, and HSPD-12 determinations. In FY 2014, these are projected to total approximately 160,000 cases. DoD 

CAF leadership estimates that favorable adjudications can be made for approximately 90% of cases, which would 

mean that about 16,000 adjudications on the highest risk cases will be made by security personnel in the field. 

Effectively, this means that the DoD is assigning the adjudications of its highest risk subjects to the personnel 

who have the least amount of experience and training to adjudicate background investigations. Additionally, 

most of these field personnel will be doing adjudications in very small quantities, which contributes to lack of 

consistency in rendering credentialing determinations.

or departing personnel. One reason is that the Department does not have policy 

addressing roles, responsibilities, and standards for security managers to ensure 

the upkeep of data in JPAS. However, the Defense Manpower Data Center 

has developed numerous data quality initiatives to identify incomplete and 

inconsistent information in JPAS and either administratively remove associated 

personnel from access to classified information or administratively separate them 

from the Department.26 Additionally, in August 2013, the Office of the Under 

Secretary of Defense for Intelligence directed DoD Components to validate that 

personnel identified as having overdue reinvestigations in JPAS still require 

them. The Department is issuing a memorandum reminding security managers, 

supervisors, and commanders of their responsibilities to ensure that JPAS 

accurately reflects the status of their personnel and whether they have engaged in 

behaviors of security concern.

Recommendations:

• Establish, reinforce, and enforce roles and responsibilities for updates to 

JPAS/Joint Verification System by security managers within specific time 

frames to ensure completeness, accuracy, and accessibility of information 

about current employment status and access to classified information.

• Revise DoD policy to define procedures for adverse information reporting 

and clarify the kinds of behaviors that indicate issues of security concern 

and must be reported. 

Process for Determining 

Whether Security Clearances are Required 

The number of clearances issued and deficiencies in the process for identifying 

positions and responsibilities that require security clearances were not direct 

factors in the Navy Yard incident. Alexis was subject to the minimum 

background investigation for military service, which is also the minimum 

background investigation for access to classified information. A few months 

after enlisting, he was assigned to Navy training that required eligibility for 

access to classified information, which led to a request for a re-adjudication of his 

investigation based on national security standards (i.e., the National Adjudicative 

Guidelines). He was not indoctrinated for access, however, until he was hired by 

26 For more information on DMDC’s Data Quality Initiative to administratively debrief persons with active access 

who do not meet business rules and policy requirements for that level of access, see: https://www.dmdc.osd.

mil/psawebdocs/docRequest//filePathNm=PSA/appId=560/app_key_id=1559jsow24d/siteId=7/ediPnId=0/

userId=public/fileNm=DQI+597+Slides.pdf
42 43

a cleared industry employer. In his industry position, he was assigned to support 

a classified contract and required a Secret security clearance in the performance 

of his duties. 

Indirectly, one could argue that the sheer volume of security clearance eligibility 

and access determinations processed by the Department has the consequence 

of reducing the amount of time that investigators and adjudicators can spend 

on cases to ensure that reports of investigation are complete and all issues are 

adequately identified and resolved. Regardless of whether this was pertinent or 

indirectly affected Alexis’ investigation and adjudication, the workload challenge 

will not be eliminated by reducing the number of security clearances because of 

the pending impacts of the alignment of suitability and security investigations and 

reinvestigations required by Executive Order 13467 and the 2012 Revised Federal 

Investigative Standards. The net effect of the new standards will be to increase the 

Department’s investigative and adjudicative workload, regardless of the number 

of security clearances. For example, all military and contractor personnel who 

currently require NACLC investigations will instead require an investigation that 

is more similar to the ANACI required for civilian employees, which includes 

employment and education checks not required for NACLC investigations. 

Recommendation:

• At least annually, require DoD Component and agency heads to validate 

and certify the need for all personnel security clearances under their 

cognizance. 

Adequacy and Effectiveness of DoD Personnel Security 

Clearance and Background Reinvestigation Policies 

When the 2012 Revised Federal Investigative Standards are implemented in 

the Department, reinvestigations for personnel will be required for all national 

security positions (regardless of classification level) every 5 years. Security 

managers may continue to apply differing reinvestigation requirements for 

individuals with eligibility for access but who are not indoctrinated for access 

unless the Department makes a concerted effort to clarify expectations. If 

reinvestigation requirements remain subject to interpretation, the Department 

will remain vulnerable to a policy gap that contributed to Alexis gaining access 

to classified information without having been subjected to security requirements 

and oversight for several years.

When Alexis was honorably released from active duty in the Navy and transitioned 

to the Individual Ready Reserve, he retained his active eligibility for access to 

classified information as recorded in JPAS. When he found employment as a DoD 

contractor 20 months later, his employer complied with current DoD policy that 

allowed him to be indoctrinated for access to classified information based on the 

Navy’s eligibility determination and without any reinvestigation. In practical 

terms, Alexis was indoctrinated for access to classified information by The Experts 

after nearly 5 years without being subjected to security oversight. This gap in 

existing policy, moreover, could allow someone like him to be indoctrinated 

without any reinvestigation based on an existing Secret-level eligibility after 10 

years without security oversight.

Numerous policy-related findings and recommendations have been presented in 

the previous sections of this review. The policy-making process itself, however, 

presents very difficult challenges to the DoD’s ability to keep policies up-to-date 

and responsive to emerging needs. DoD Personnel Security Program policies 

generally take years to go through both DoD and OMB coordination processes. 

The current formal policy issuance process for DoD Personnel Security Program 

instruction and procedures as well as Common Access Credential investigation and 

adjudication instructions and procedures is too long and undermines the ability of 

the Department to provide timely direction and guidance to components.

Recommendations:

• Establish requirements for eligible personnel and transitioning personnel 

to more frequently update standard forms that are required for their type 

of eligibility. For example, the Department could revise policy to require 

individuals who have a break in access of 12 consecutive months or more 

to complete the SF-86C, Standard Form 86 Certification, to ensure SF-86 

information is current and correct. 

• Convene a follow-up working group to determine how to mitigate risk 

regarding individuals who have a break in access and extended periods 

with no security oversight and recommend the appropriate duration for 

restoration of access.

• Develop strategies for streamlining the DoD issuance process where 

possible to ensure policies keep pace with changes in national policies and 

the Department’s needs (e.g., restoring USD(I)’s ability to issue interim 

direction and policy to DoD Components via a policy memorandum).
44 45

Installation Access Control Process

Access to DoD Facilities and Identity Vetting

The Naval Criminal Investigative Service (NCIS) and FBI published in their 

findings that Alexis arrived at the Washington Navy Yard on the morning of 

September 16 having legitimate access as a DoD contractor employee and that he 

used his valid building pass to gain entry to Building 197. However, the Review 

Team found some DoD components are not compliant with implementing 

policy requirements for identity proofing, vetting, and authentication of visitors 

seeking unescorted access to DoD installations. Implementation, execution, 

and oversight of DoD policies and procedures related to physical security and 

antiterrorism is inconsistent. Leadership awareness of policy requirements and 

implementation challenges is critically important in setting the tone for a strong 

overall security posture.

Although DoD processes and procedures related to access to facilities by 

cleared personnel appear to be adequate, the review revealed that some DoD 

Components are not in compliance with DoD policy on visitor access control. 

DoD Instruction 2000.16, “DoD Antiterrorism (AT) Standards,” requires DoD 

Components in Force Protection Condition Bravo to verify the identity of visitors 

seeking access to DoD installations and randomly inspect their suitcases, parcels, 

and other containers. Likewise, Directive-type Memorandum (DTM) 09-012, 

“Interim Policy Guidance for DoD Physical Access Control,” directs non-federal 

government and non-DoD-issued card holders who are provided unescorted 

access to DoD installations to be identity proofed and vetted to determine fitness 

and eligibility for access. DTM 09-012 also requires personnel to be vetted 

against government authoritative data sources, including the National Crime 

Information Center (NCIC) and Terrorist Screening Database (TSDB). 

Not all visitors are being vetted before gaining unescorted access to DoD 

installations. In some cases, visitors can show a driver’s license to gain access 

to DoD installations without being vetted. In other cases, local vendors may be 

given a base pass without being vetted against the NCIC or TSDB. As resources 

allow, the Military Departments actively pursue compliance with installation 

access control, but fiscal pressures prevent installations from having NCIC 

capability at their visitor centers. Some DoD installations have purchased 

commercial access control vetting systems (such as MOBILISA) that do not 

check against U.S. Government authoritative data sources (NCIC and TSDB). 

These systems do not meet the intent of DTM 09-012, as they use only a public 

records check and are not interoperable, nor do they support a DoD-wide access 

control capability. A recently issued DoD Inspector General report27 noted a 

key finding that numerous contractor employees were enrolled in a commercial 

access control system and received interim installation access and a local access 

credential without having their claimed identities vetted through mandatory 

databases such as NCIC and TSDB. This occurred in attempts to reduce access 

costs. OMB memorandum 05-24 directs that government employees and 

contractor personnel requiring routine physical access to an installation for more 

than 6 months must receive a personal identity verification credential, such as 

a DoD CAC, and successfully complete a National Agency Check with Written 

Inquiries (or higher) investigation.

Although it appears physical security policies at the Washington Navy Yard 

were aligned and nested with Department of the Navy and DoD policies, there 

were some shortcomings in the implementation and execution of these policies. 

The review revealed that random antiterrorism measures (RAM) and vehicle 

inspections were not being conducted regularly as required under DoDI 2000.16, 

“DoD Antiterrorism (AT) Standards.” Installation antiterrorism plans and 

local vulnerability assessments were not completed in accordance with DoD 

antiterrorism policy. Further, visitors were not properly vetted in accordance 

with DoD physical security policy. We do not believe these concerns are 

isolated to the Navy Yard. Common observations from Joint Staff Integrated 

Vulnerability Assessments (JSIVAs) identified:

• Deficiencies in commercial delivery inspection processes, employment 

of RAM and final denial barriers; and

• Insufficient explosive detection equipment, working dogs, and 

communications equipment.

Implementation and enforcement of physical security and antiterrorism 

procedures and policies require senior leadership emphasis and oversight.

Recommendations:

• Ensure all visitors entering DoD installations are properly vetted against 

U.S. Government authoritative data sources (NCIC and TSDB).

• Maintain current physical security standards of physical and visual 

inspection of identification credentials for access control.

27 DoD Inspector General Report #DODIG-2013-134, “Navy Commercial Access Control System Did Not 

Effectively Mitigate Access Control Risks,” September 16, 2013
46 47

• Issue policy prohibiting use of commercial access control vetting systems 

that do not check against U.S. Government authoritative data sources and 

support a DoD-wide and federally interoperable access control capability.

• Ensure Military Department and installation compliance with DoD AT and 

physical security policies, and examine Military Department oversight of 

these policies.

Not all DoD installations are using authoritative databases to vet visitors to 

determine fitness to enter DoD installations as specified in DTM 09-012. While 

most DoD installations have access to law enforcement databases like the NCIC 

for law enforcement and investigative purposes, not all installations have access 

to NCIC for the purpose of vetting for access control. DTM 09-012 mandates 

that unescorted visitors entering DoD installations be queried against government 

authoritative data sources to vet the claimed identity to determine fitness: 

“Installation government representatives shall query the following government 

authoritative data sources to vet the claimed identity and to determine fitness, 

using biographical information including, but not limited to, the person’s name, 

date of birth, and social security number: NCIC, TSDB, other sources as 

determined by DoD component, local commander or director.”

Not all installations are compliant; this is primarily a funding and personnel 

staffing issue. Vetting visitors against NCIC requires a trained security clerk to 

send individual queries to NCIC, which is a manual and labor intensive process; 

it also requires investment in equipment, infrastructure, and licenses to access 

the databases. Although workarounds exist, such as conducting NCIC checks 

by phone, they are not practical for installations with large visitor populations. 

As a result, some installations are not vetting visitors against required law 

enforcement databases. 

Currently, Military Department-level law enforcement databases are not 

interoperable. Because of this, an individual barred from an Army installation 

can gain access to an Air Force or Navy installation. The Fort Hood Follow-on 

Review recommended establishing a consolidated law enforcement database to 

enable organizations across the Department to query, retrieve, and post criminal 

investigation and law enforcement data into a single repository. The report 

recommended acceleration of efforts to automate access control that would 

authenticate various identification media (e.g., passports, CAC, drivers’ licenses, 

license plates) against authoritative databases. DoD has implemented the Law 

Enforcement Defense Data Exchange (LE D-DEx), an automated information 

management system designed to share criminal justice information between DoD 

LE agencies for LE and investigative purposes. However, LE D-DEx is not 

currently integrated with physical access control systems.

The DIAC Working Group, under the auspices of the DoD Physical Security 

Equipment Action Group, is establishing IMESA to provide the capability to 

vet individuals seeking access to a DoD installation against DoD, Federal, 

state, and local authoritative data sources. This architecture will provide the 

capability for fitness determination of non-Federal Government and non-DoD 

issued card holders and visitors requesting unescorted access to DoD installations 

using biographical name checks. Secure information will enable installations’ 

physical access control systems (PACS) to authenticate individuals’ credentials, 

authorization, and fitness to enter, vastly enhancing the security of DoD 

personnel and resources worldwide.

Recommendations:

• Establish an efficient process or system for DoD Components to gain 

access to law enforcement and other authoritative databases to vet 

personnel for access control.

• Accelerate implementation of IMESA. Explore integrating LE D-DEx 

with physical access control systems via IMESA.

Suspicious Activity Reporting

DoD Instruction 2000.26, “Suspicious Activity Reporting,” is the capstone DoD 

policy governing how the Department reports suspicious activities. Although the 

Department is not mandated by Federal law or other statutes to use eGuardian, 

DoDI 2000.26 requires DoD components with law enforcement agencies or 

activities to use eGuardian exclusively for reporting, storing, and sharing 

unclassified suspicious activity reports dealing with information regarding a 

potential threat or suspicious activity related to DoD personnel, facilities, or 

forces in transit.

Although the DoD Components and the Washington Navy Yard are compliant 

with suspicious activity reporting policy and have established procedures for 

eGuardian, they need to ensure the law enforcement community is aware of the 

means and methods for reporting suspicious activities through eGuardian.
48 49

In addition, law enforcement and eGuardian users must report suspicious 

behaviors, activities, and other reportable information and ensure this information 

populates within eGuardian so it can be seen and accessed.

Recommendations:

• Develop and implement suspicious activity reporting awareness 

campaigns for all DoD Components. Ensure all personnel (military, 

civilian, contractor, vendor, and visitors) on DoD installations know how 

to report suspicious activities.

• Ensure suspicious activities as reported through other “tip” systems, such 

as Eagle Eyes, are recorded in eGuardian.

• Monitor and track eGuardian reporting through the DoD eGuardian 

Working Group.

• Emphasize the sharing of all suspicious activities and other LE reporting 

through the local threat working group and other LE channels.

Privately-owned Weapons on DoD Installations

Although DoD policy regarding privately owned weapons is adequate, 

enforcement and verification is difficult. It is impractical to search every vehicle 

entering an installation for illegal weapons. Additionally, without conducting 

exhaustive searches of facilities and residences, it is impossible to verify illegal 

weapons have not been smuggled onto DoD installations. Commanders must 

balance security with access and privacy concerns.

Title 18 U.S.C., Section 930, prohibits any individual from knowingly possessing 

or presenting a firearm or dangerous weapon in a Federal facility. The December 

3, 2010, Secretary of Defense message on privately owned firearms (POF) 

directed all DoD components to require mandatory registration of POF for all 

personnel who store POF on an installation (whether or not they live on the 

installation). U.S. Navy policy for POF aligns with this DoD policy, requiring 

any weapon brought onto a Navy installation to be registered with base security 

forces.

Recommendations:

• Installation commanders develop strategies to check vehicles and 

personnel entering DoD installations and facilities for POF.

• Conduct a follow-on review to examine installation security and law 

enforcement resource requirements to implement an adequate personnel, 

property, and vehicle inspection program.

• Ensure notices of provisions are posted conspicuously at each DoD 

installation in public entrance in accordance with subsections (a) and (b) 

of Title 18, United States Code, Section 930 (Possession of firearms and 

dangerous weapons in Federal facilities).

DoD Vulnerability Assessment Capabilities to Identify and 

Mitigate Physical Security Gaps

Vulnerability assessments are critical to commanders’ ability to identify 

vulnerabilities and mitigate risk. DoDI 2000.16, Standard 6, directs heads of 

DoD components to conduct and update terrorism vulnerability assessments at 

least annually or more frequently if the terrorist threat assessment or mission 

requirements dictate. Vulnerability assessments are conducted, at a minimum, 

for any facility populated daily by 300 or more DoD personnel, any DoD facility 

bearing responsibility for emergency response or physical security plans and 

programs, or determined to host critical infrastructure.

JSIVAs evaluate an installation’s ability to deter and/or respond to a terrorist 

incident. The Defense Threat Reduction Agency (DTRA) conducts between 

80-100 JSIVAs per year. Due to fiscal concerns, the Military Departments have 

reduced their vulnerability assessment teams and have become more reliant 

upon JSIVAs. However, beginning in FY 2015, DTRA will reduce the number 

of JSIVAs it conducts by approximately 70 percent to about 30 per year, placing 

greater pressure on the Military Departments to conduct higher headquarters 

vulnerability assessments. Given the constrained fiscal environment, it is 

unlikely the Military Departments will be able to make up the difference 

and some installations may go without a higher headquarters vulnerability 

assessment. Although the vulnerabilities identified in the JSIVA and CNO 

integrated vulnerability assessment of the Washington Navy Yard had no direct 

bearing on the specific events of September 16, 2013, the identified shortcomings 

in the implementation and execution of DoD physical security policies introduces 

risk and could be a factor in the future.
50 51

Recommendation:

• Fund the JSIVA program in FY 2015 and beyond until the Department 

transitions to a broader Mission Assurance Assessment Capability in order 

to in order to retain the Chairman’s critical independent vulnerability 

assessment capability.

Programming, Budgeting and Resourcing for 

Physical Security Infrastructure

Due to current budget constraints, DoD Components are encountering significant 

challenges with procuring technological capabilities that support physical 

security infrastructure. DoD programming, budgeting, and resourcing for 

physical security encounters significant challenges with competing requirements.

Although programming, budgeting, and resourcing of physical security 

infrastructure had no direct impact on the WNY shooting incident, further 

reductions in physical security funding could put installations at risk for 

preventing and responding to future active shooter incidents. Not all installations 

are compliant with physical security requirements due to budget constraints that 

impact the Military Departments’ ability to procure equipment, integrate law 

enforcement and physical security databases, and manpower.

Equipment. DTM 09-12 directs “When funding becomes available, 

installations will procure an electronic Physical Access Control System (PACS) 

that provides capability to rapidly and electronically authenticate credentials 

and individuals authorized to enter an installation.” Not all of the Military 

Departments have physical access control systems and the current capability 

is not interoperable for access control. Not all installations have NCIC at their 

visitor centers. Some installations have purchased commercial access control 

vetting systems that do not check against U.S. Government authoritative data 

sources (NCIC and TSDB); thus, they fail to meet the intent of DTM 09-12. 

Although the Military Departments implement “work-arounds” with telephonic 

NCIC background checks to offset a lack of technological equipment, this 

process is not operationally conducive for rapid identity vetting to determine 

fitness of personnel entering installations at the access control point. 

Integration of Law Enforcement and Physical Security 

Databases. The Department implemented the Law Enforcement Defense 

Data Exchange (LE D-DEx), an automated information management system 

designed to share criminal justice information between DoD law enforcement 

agencies. LE D-DEx is not currently integrated with existing law enforcement 

databases and physical access control systems.

Manpower. Beginning in FY15, the Defense Threat Reduction Agency and 

the Military Departments will reduce the number of JSIVAs from 80 or more per 

year to about 30. Reduction of JSIVAs will limit commanders’ ability to identify 

vulnerabilities and mitigate risk.

Assessments. Observations from JSIVAs identified deficiencies in 

commercial delivery inspection process; RAM; final denial barriers; explosive 

detection equipment and dogs; and communication deficiencies. These are 

reoccurring deficiencies that can be rectified with additional manpower and 

funding. DoD Components need to procure PACS that are HSPD-12 compliant 

and possess capabilities now that share law enforcement information from 

integrated databases to rapidly vet and screen personnel entering our installations. 

Physical security programming, budgeting, and resourcing varies within the 

Military Departments. Each Service prioritizes and budgets for physical security 

and AT programs differently. In this austere budget environment, competing 

requirements are difficult for physical security and antiterrorism programs to 

overcome. 

Governance. Also, at the Department level, there is no single Principal 

Staff Assistant in OSD with oversight of law enforcement, physical security, and 

antiterrorism, inhibiting the Department from directing and integrating policy, 

assessing compliance and recommending resource priorities. Governance of 

these programs and their execution is diffused within the Department, and 

security programs sometimes do not receive appropriate priority at the strategic 

level. 

Recommendations:

• DoD Components must continue to conduct risk-based programming 

to support physical security and antiterrorism capabilities and JSIVA 

programs during austere budget environments.
52 53

• Conduct a follow-on review to examine physical security programming, 

budgeting, and resourcing. DoD should review how physical security, 

antiterrorism, and law enforcement activities are governed within 

the Department to improve synergy. Currently, these functions are 

decentralized in the Department.

• Highlight security programs in the Defense Planning Guidance and other 

strategic prioritization documents.

Impact of Changes in Information Technology 

on Security Programs

The Department has limited capability to electronically vet and identify 

personnel entering its installations.

Section 1069 of the Fiscal Year 2008 National Defense Authorization Act for 

Fiscal Year 2008 states: “(1) Access Standards for Visitors: Secretary of Defense 

shall develop access standards applicable to all military installations in the 

United States ... to include to determine the fitness and verifying the identity. 

Secretary of Defense is encouraged to procure and field existing identification 

screening technology and to develop additional technology only to the extent 

necessary to assist commanders of military installations in implementing the 

standards developed under this section at points of entry for such installations.”

DTM 09-12 directs, “When funding becomes available, installations will procure 

an electronic physical access control systems that provides the capability to 

rapidly and electronically authenticate credentials and individuals authorized 

to enter an installation. The PACS must support a DoD-wide and federally 

interoperable access control capability.”

Current DoD physical access control systems are governed and implemented 

under Military Department-unique guidance and are not interoperable 

among military installations. No enterprise capability exists for linking DoD 

installations using electronic authentication of credentials. Funding of physical 

access control systems is inconsistent across the Military Departments.

The DIAC Working Group is developing IMESA to serve as the overarching 

architecture. This architecture consists of: 1) Interoperability Layer Service 

(IoLS) that will allow DoD Components’ physical access control systems to 

share information with one another; and 2) Continuous Information Management 

Engine capability, which continuously updates information in the authoritative 

databases. IMESA will not only tie the DoD Components together, but benefit 

them by:

• Providing real-time continuous identity vetting with periodic updates/

alerts;

• Enabling installations to identify “bad actors;”

• Providing minimal impact on how Military Department physical access 

control systems are further developed and maintained;

• Providing Military Departments’ physical access control systems near 

real-time access to authoritative source data; and

• Including additional capabilities, as the architecture evolves, leveraged 

from linkages to a biometric component.

The DIAC Joint Capability Technology Demonstration is currently on hold 

pending approval of an exception to DoDD 5200.27, which prohibits storing 

of information on non-DoD affiliated personnel. DoDD 5200.27 specifies all 

information on non-DoD affiliated personnel that the Department is not otherwise 

authorized by law or by direction of the Secretary of Defense to retain must be 

destroyed within 90 days.

Recommendations:

• Continue Defense Manpower Data Center’s development of IMESA and 

IoLS to enable DoD components to share access control information 

and vet individuals continuously against U.S. Government authoritative 

databases before allowing access to DoD installations.

• Approve exemption to DoDD 5200.27 to collect and store NCIC and 

TSDB information on non-DoD personnel.

• Fund procurement of electronic physical access control systems that 

provide the capability to rapidly and electronically authenticate credentials 

and individuals authorized to enter an installation.
54 55

Appendices

Appendix A. Internal Review Team Composition, Contributing 

Organizations, and Terms of Reference

A-1. Internal Review Team Composition

The Internal Review Team membership was derived primarily from an existing 

DoD team of subject matter experts focused on threats from trusted insiders: the 

DoD Insider Threat Working Group, which was established under the auspices 

of the Under Secretary of Defense for Intelligence in August 2013. The team 

organized into two primary areas of focus: personnel security clearance and 

installation access control processes. Using those principal areas as points of 

departure for the review, the team received briefings and conducted interviews 

with subject matter experts and senior officials across the Department. The 

team included representatives from the following original and augmenting 

organizations: 

The Joint Staff

Department of the Army

Department of the Navy

Department of the Air Force

U.S. Cyber Command

U.S. Northern Command

Office of the Under Secretary of Defense (Acquisition, Technology and 

Logistics)

Office of the Under Secretary of Defense for Intelligence

Office of the Under Secretary of Defense for Personnel and Readiness

Office of the Under Secretary of Defense for Policy

Office of the Assistant Secretary of Defense for Health Affairs

Office of the General Counsel of the Department of Defense

DoD Chief Information Officer

Director, Administration and Management

Defense Intelligence Agency

Defense Security Service

Defense Privacy and Civil Liberties Office

DEPARTMENT OF DEFENSE

Internal Review of the

Washington Navy Yard Shooting

A Report to the Secretary of Defense
56 57

A-2. Briefings and Supporting Organizations

The Internal Review Team received briefings from stakeholder organizations 

across the Department and conducted extensive interviews with subject matter 

experts. The following organizations contributed to the review:

Subject Organization

Continuous Evaluation Concept 

Demonstration

Department of the Army

Fort Hood Update Office of the Under Secretary of 

Defense for Policy

Overview of Security Executive Agent 

Roles and Responsibilities; Status of 

Continuous Evaluation Initiative

Office of the Director of National 

Intelligence

DoD Adjudications DoD Consolidated Adjudications 

Facility

National Industrial Security Program Defense Security Service

Security Vulnerability Assessment 

Overview

Defense Security Service

Insider Threat Prediction and 

Prevention; MOSAIC Threat 

Assessment Systems

Gavin de Becker & Associates

DoD Privacy and Civil Liberties 

Programs

Defense Privacy and Civil Liberties 

Office

Navy Threat Management Unit Naval Criminal Investigative Service

HSPD-12: DoD Common Access 

Card (CAC) and Other Emerging 

Physical Security Activities

Defense Manpower Data Center

Overview of the Washington Navy 

Yard Criminal Investigation

Federal Bureau of Investigation

Naval Criminal Investigative Service

Overview of Secretary of the Navy 

Rapid Reviews

Department of the Navy

Overview of the Health Insurance 

Portability and Accountability Act 

(HIPAA)

Office of the Assistant Secretary of 

Defense for Health Affairs

Joint Lessons Learned Program Joint Staff

Office of the Assistant Secretary of 

Defense for Homeland Defense & 

Americas’ Security Affairs

A-3. Terms of Reference

Department of Defense Review of the Washington Navy Yard 

Shooting

These Terms of Reference (TOR) set forth the objectives for the Secretary of 

Defense-directed internal and independent reviews (hereafter referred to as “the 

Reviews”) to examine the security programs, policies, processes, and procedures 

related to the shooting at the Washington Navy Yard on September 16,2013. The 

purpose of the Reviews is to identify and address vulnerabilities or weaknesses 

that may have alerted the Department of Defense (DoD) to the potential threat 

before the incident occurred. The Reviews will be conducted on a separate but 

paraJlel track, with a consolidated list of recommendations provided to the 

Secretary of Defense.

Finally, the Department of Navy (DoN) is conducting its own review of security 

at Navy and Marine Corps installations, as well as other security, contractor, 

and personnel issues stemming from this tragedy. The DeN’s findings will be 

incorporated into the final report to the Secretary of Defense.

Background

On September 16, 2013, Aaron Alexis, a Navy contractor, shot and killed 12 

U.S. Navy civilian and contractor employees and wounded several others at 

the Washington Navy Yard. The shooter was also killed. The Federal Bureau of 

Investigation is leading a criminal investigation into the incident. The Reviews 

should in no way interfere with that investigation or suggest culpability for the 

events of September 16, 2013.

Objectives and Scope

The Reviews are to determine whether there are DoD program, policy, or 

procedural weaknesses in the security procedures for access to DoD installations 

worldwide (outside areas ofhostilities) or related to the security clearance and 

reinvestigation process for DoD personnel and contractors. The Reviews will 

examine the Washington Navy Yard shooting to identify issues that may present 

Department-wide vulnerabilities.

The Reviews will:

• Assess the adequacy and effectiveness of DoD policies related to 

personnel security clearances and background reinvestigations;
58 59

• Assess the adequacy and effectiveness of DoD processes and 

procedures related to access to DoD facilities by cleared personnel;

• Evaluate information-sharing processes and procedures among federal, 

state, and local law enforcement agencies regarding security clearance 

and background reinvestigations;

• Assess the accuracy and completeness of DoD investigation and 

adjudication verification databases;

• Evaluate DoD procedures for initiating and using background 

investigations for personnel security clearances, suitability 

determinations, and Homeland Security Presidential Directive-12 

compliance, including:

o Depth, quality, and thoroughness of investigations conducted by the 

Office of Personnel Management for DoD;

o Access to relevant information, including law enforcement databases, 

financial data, and health and personnel records; and

o Continuous evaluation ofDoD personnel and contractors between 

investigation periods;

• Assess DoD implementation and effectiveness of suitability evaluations 

and determinations · for those DoD and contractor personnel in 

positions that do not require access to classified information;

• Assess the process by which DoD determines whether security 

clearances are required for military, civilian, and contractor personnel;

• Review DoD self-reporting, suspicious activity reporting, and security 

incident reporting programs and procedures;

• Review DoD policy and procedures regarding privately-owned 

weapons on DoD installations;

• Review current and planned DoD vulnerability assessment capabilities 

used to identify and mitigate gaps in physical security procedures and 

resources;

• Assess the adequacy and effectiveness of programming, budgeting, and 

resourcing for physical security infrastructure;

• Analyze changes in information technology that may facilitate 

improved security programs or pose emerging challenges;

• Evaluate the roles and responsibilities of military and civilian 

leadership for suspension or revocation of facility access credentials, or 

for initiating a security clearance reinvestigation; and

• Examine whether and how changes in “insider threats” to DoD 

installations may alter security requirements or necessitate changes in 

security programs, policies, processes and procedures.

Methodology

• The Reviews should consider find ings and recommendations from 

previous relevant reports and studies.

• The Reviews will examine all applicable laws, policies, and regulations, 

including DoD directives, instructions, and manuals.

• The Reviews may include interviews with appropriate senior officials 

(health affairs, law enforcement and force protection, first responders, 

intelligence), and other pe11inent individuals.

• The Reviews will formulate recommendations for correcting problems 

and enhancing internal controls to prevent similar incidents in the future 

and mitigate associated risk.

Process

• The Under Secretary of Defense for Intelligence (USD(I)) will lead the 

internal review, in coordination with senior representatives from each 

of the Military Departments, the Joint Staff, and the Office of the 

Secretary of Defense.

• Dr. Paul Stockton (former Assistant Secretary of Defense for Homeland 

Defense and Americas’ Security Affairs) and Admiral Eric Olson, USN 

(Ret), will lead the Independent Review.

• The Deputy Secretary of Defense will oversee the internal review as well 

as the consolidation and drafting of the final report.

• The Secretary of Defense has given the Independent Review the authority 

to submit their findings directly to him, should it deem such a step 

necessary.
60 61

Timeline and Deliverables:

The Reviews will begin on September 30, 2013. A final report with key 

findings and recommendations from the internal and independent reviews will 

be provided separately to the Secretary and Deputy Secretary ofDefense by 

November 15,201 3. Under supervision ofthe Deputy Secretary of Defense, 

a consolidated report synthesizing the findings and recommendations of both 

reviews will be provided to the Secretary of Defense by December 20, 2013, 

unless the Independent Review exercises the aforementioned authority to submit 

their findings directly to the Secretary of Defense. Implementation plans will be 

developed at the direction of the Secretary of Defense.

Support:

• The Under Secretary of Defense (Comptroller)/Chief Financial Officer 

will ensure adequate funding is provided for the Reviews.

• The Director of Administration & Management, through Washington 

Headquarters Services, will coordinate with other DoD Components on 

behalf of the Reviews and provide human resources, office facilities, 

and other support, as required, to ensure the success of theseefforts.

• The Reviews will be able to draw upon the full support of the Military 

Departments and other DoD Components for support, personnel, 

information (including, but not limited to, documents and personnel to 

be interviewed), and analytical and investigative capacity as determined 

necessary by the USD(I) and the Co-chairs of the independent review.

Appendix B. Seattle Police Department Incident Report
62 63
64 65
66 67

Appendix C. References

Personnel Security

U.S. Law, National Policy and Federal Regulations

Part 732 of title 5, Code of Federal Regulations 

Public Law 108-458, “Intelligence Reform and Terrorism Prevention Act of 

2004,” December 17, 2004 

Executive Order 10450, “Security Requirements for Government Employment,” 

April 27, 1953, as amended

Executive Order 10865, “Safeguarding Classified Information within Industry,” 

February 20, 1960, as amended

Executive Order 12829, “National Industrial Security Program,” January 6, 1993, 

as amended

Executive Order 12968, “Access to Classified Information,” August 2, 1995, as 

amended

Executive Order 13467, “Reforming Processes Related to Suitability for 

Government Employment, Fitness for Contractor Employees, and Eligibility for 

Access to Classified National Security Information,” June 30, 2008

Executive Order 13488, “Granting Reciprocity on Excepted Service and Federal 

Contractor Employee Fitness and Reinvestigating Individuals in Positions of 

Public Trust,” January 16, 2009

White House Memorandum, “Adjudicative Guidelines,” December 29, 2005

White House Memorandum, “Implementation of Executive Order 12968,” March 

24, 1997

Executive Order 13526, “Classified National Security Information,” December 

29, 2009

U.S. Office of Personnel Management Booklet, “Requesting OPM Personnel 

Investigations,” December, 2010 (also known as “INV 15”)
68 69

U.S. Office of Personnel Management Federal Investigations Notice 97-

02, “Executive Order 12968 and Investigative Standards for Background 

Investigations for Access to Classified Information,” July 29, 1997

Office of Management and Budget Memorandum, “Reciprocal Recognition of 

Existing Personnel Security Clearances,” December 12, 2005

Office of Management and Budget Memorandum M-06-21, “Reciprocal 

Recognition of Existing Personnel Security Clearances,” July 17, 2006

Office of Management and Budget Memorandum, “Reciprocal Recognition of 

Existing Personnel Security Clearances,” November 14, 2007

Director of National Intelligence and U.S. Office of Personnel Management 

Memorandum, “Approval of the Federal Investigative Standards,” December 13, 

2009

Intelligence Community Policy

Office of the Director of National Intelligence and the U.S. Office of Personnel 

Management, “Approval of the Federal Investigative Standards,” December 13, 

2008

Intelligence Community Directive 704, “Personnel Security Standards and 

Procedures Governing Eligibility for Access to Sensitive Compartmented 

Information and Other Controlled Access Program Information,” October 2, 2008

Intelligence Community Policy Guidance 704.2, “Personnel Security 

Adjudicative Guidelines for Determining Eligibility for Access to Sensitive 

Compartmented Information and Other Controlled Access Program Information,” 

October 2, 2008 

Intelligence Community Policy Guidance 704.3, “Denial or Revocation of 

Access to Sensitive Compartmented Information, Other Controlled Access 

Program Information, and Appeals Processes,” October 2, 2008

Director of National Intelligence Memorandum, “Delegation of Authority 

for the Director of Administration and Management to Determine Sensitive 

Compartmented Information Eligibility at the Department of Defense 

Consolidated Central Adjudication Facility,” October 22, 2012

Director of National Intelligence Memorandum, “Clarification of Conflicting 

Personnel Security Investigative Standards,” E/S 00388, July 29, 2011

Department of Defense Policy

DoD Directive O-5240.02, “Counterintelligence,” December 20, 2007, as 

amended

DoD Directive 5143.01, “Under Secretary of Defense for Intelligence (USD(I)),” 

November 23, 2005

DoD Directive 5200.02, “DoD Personnel Security Program,” April 9, 1999 

DoD Directive 5220.6, “Defense Industrial Personnel Security Clearance Review 

Program,” January 2, 1992

DoD Instruction 3305.13, “DoD Security Training,” December 18, 2007

DoD Directive 5145.01, “General Counsel of the Department of Defense,” May 

2, 2001

DoD 5200.2-R, “Personnel Security Program,” January 1987

DoD 5220.22-R, “Industrial Security Regulation,” December 4, 1985

DoD 5220.22-M, National Industrial Security Program Operating Manual, 

February 28, 2006

DoD 5400.11-R, “DoD Privacy Program,” May 14, 2007

DoD Instruction 5210.91, “Polygraph and Credibility Assessment (PCA) 

Procedures,” August 12, 2010

DoD Directive 5210.48, “Polygraph and Credibility Assessment Program,” 

January 25, 2007

DoD Directive 5105.42, “Defense Security Service (DSS),” August 3, 2010

DoD Instruction 5145.03, “Oversight of the DoD Personnel Security Programs,” 

January 10, 2013

DoD Directive 5240.06, “Counterintelligence Awareness and Reporting (CIAR),” 

May 17, 2011, as amended

DoD Instruction 5220.22, “National Industrial Security Program (NISP),” March 

13, 2011
70 71

DoD 5400.7-R, “DoD Freedom of Information Act Program,” September 4, 1998

DoD 5400.11-R, “Department of Defense Privacy Program,” May 14, 2007

DoD Manual 5200.01, Volume 1, “DoD Information Security Program: Overview, 

Classification, and Declassification,” February 24, 2012

DoD Manual 5200.01, Volume 3, “DoD Information Security Program: Protection of 

Classified Information,” February 24, 2012, as amended

DoD Manual 3305.13, “DoD Security Accreditation and Certification,” March 14, 

2011

Secretary of Defense Memorandum, “Final Recommendations of the Defense 

Science Board Report on Predicting Violent Behavior,” March 26, 2013

Office of the Assistant Secretary of Defense, C3I Memorandum, “Clearance and 

Access Reciprocity in the Department of Defense,” July 16, 1998

Office of the Assistant Secretary of Defense, C3I Memorandum, “Personnel Security 

Investigations and Adjudications,” November 10, 1998

Assistant Secretary of Defense, C3I Memorandum, “Personnel Security Clearance 

Investigations,” August 22, 2000

Assistant Secretary of Defense, C3I Memorandum, “Transfer of Additional Personnel 

Security Investigation Workload to the Office of Personnel Management (OPM),” 

April 30, 2001

Deputy Under Secretary of Defense (Counterintelligence and Security) 

Memorandum, “Personnel Security Issues,” January 8, 2004

Office of the Under Secretary of Defense for Intelligence letter to U.S. Office of 

Personnel Management, re: Presidential approval of Single-Scope Background 

Investigation – Periodic Reinvestigation, known as the Phased PR, February 22, 2005

Office of the Under Secretary of Defense for Intelligence Memorandum, 

“Facilitating Classified Visits within the Department of Defense,” April 01, 2005

Under Secretary of Defense for Intelligence Memorandum, “Implementation of 

Adjudicative Guidelines for Determining Eligibility For Access to Classified 

Information (December 29, 2005)”, August 30, 2006

Deputy Secretary of Defense Memorandum, “Defense Security Service (DSS) 

Future Options Study Recommendations,” January 15, 2009

Under Secretary of Defense for Intelligence Memorandum, “Designation of the 

DoD Case Management and Adjudication Systems,” April 10, 2009

Office of the Secretary of Defense Memorandum, “Department of Defense (DoD) 

Implementation and Transition to the Office of Personnel Management (OPM) 

Electronic Questionnaires for Investigations Processing (e-QIP),” May 18, 2009

Under Secretary of Defense for Intelligence Memorandum, “Personnel Security 

Clearance Adjudication Documentation,” November 8, 2009

Under Secretary of Defense for Intelligence Memorandum, “DoD Personnel 

Security Adjudicator Certification Program,” July 1, 2010

Under Secretary of Defense for Intelligence Memorandum, “Implementation of the 

Rapid Assessment of Incomplete Security Evaluations (RAISE),” July 13, 2010

Under Secretary of Defense for Intelligence Memorandum, “DoD Transition 

to Electronic Fingerprint Capture and Submission in Support of Background 

Investigations,” July 29, 2010

Under Secretary of Defense for Intelligence Memorandum, “Review of the 

Adjudication Documentation, Accuracy and Rationales (RADAR) Assessments,” 

August 31, 2010

Deputy Secretary of Defense Memorandum, “DoD Central Adjudications Facilities 

(CAF) Consolidation,” October 20, 2010

Office of the Under Secretary of Defense for Intelligence Memorandum, “Approval 

of the Defense Security Service Industry Implementation Plan in Support of the 

DoD Transition to Electronic Fingerprint Capture,” April 12, 2011

Deputy Secretary of Defense Memorandum, “DoD Central Adjudications 

Facilities (CAF) Consolidation, May 3, 2012

Office of the Under Secretary of Defense for Intelligence Memorandum, 

“Transition to Electronic Fingerprint Capture and Submission in Support of 

Background Investigations,” June 7, 2012

Secretary of Defense Memorandum, “Department of Defense Guidance on 

Question 21, Standard Form 86, Questionnaire for National Security Positions,” 

September 4, 2012

Deputy Secretary of Defense Memorandum, “Appointment of the DoD Senior 

Official Charged with Overseeing Insider Threat Efforts,” September 25, 2013
72 73

Note: Memoranda without a corresponding hyperlink are available from the 

Security Policy and Oversight Directorate, Office of the Deputy Under Secretary 

of Defense (Intelligence & Security)

Other

Memorandum of Agreement among Defense Security Service, Defense Human 

Resources Activity’s Defense Manpower Data Center, Deputy Under Secretary 

of Defense (HUMINT, Counterintelligence and Security) and Deputy Under 

Secretary of Defense (Program Integration), February 2, 2010

Memorandum of Understanding between U.S. Office of Personnel Management, 

Federal Investigative Services and DoD Office of the Under Secretary of Defense for 

Intelligence for the Expansion of Electronic Delivery (eDelivery), June 21, 2010

Physical Security and Installation Access

U.S. Law, National Policy and Federal Regulations

10 U.S.C. Subtitle C, “Authority, Law Enforcement, Security of Naval 

Installations, Security of DoD Installations.”

Title 18, U.S.C. Section 930, “Possession of firearms and dangerous weapons in 

Federal facilities”

Presidential Documents

Presidential Memorandum, “National Insider Threat Policy and Minimum 

Standards for Executive Branch Insider Threat Programs. (limited public link)

Homeland Security Presidential Directive 12, “Policies for a Common 

Identification Standard for Federal Employees and Contractors”

Department of Defense Policy

DTM 09-012, “Interim Policy Guidance for DoD Physical Access Control,” with 

chg 3, March 19, 2013

DTM 13-005, “Deviations from the DoD Physical Security Program,” April 25, 

2013

Deputy Secretary of Defense Memorandum, “Antiterrorism Building Standards 

for Leased Space,” December 7, 2012

DoDI 2000.12, “DoD Antiterrorism Program,” September 9, 2013

DoDI 2000.16, “DOD Antiterrorism Standards,” December 8, 2006

DoDI 2000.26, “Suspicious Activity Reporting,” November 1, 2011

DoD 5200.08-R, “ Physical Security Program,” April 2007

DoDI 5200.08, “Security of DoD Installations and Resources and the DoD 

Physical Security Review Board (PSRB),” December I 0, 2005

DoDD 3000.3, “Policy for Non-Lethal Weapons,” July 9, 1996

FIPS 201, “Federal Information Processing Standards Publication Personal 

Identity Verification of Federal Employees and Contractors,” June 23, 2006

Unified Facilities Criteria 4-010-01, “DoD Minimum Antiterrorism Standards for 

Buildings,” February 9, 2012

Department of Homeland Security Policy

DHS Interagency Security Committee (ISC) Standard, “Facility Security Level 

Determinations for Federal Facilities,” 2008 (FOUO – requires an HSIN account 

for access)

DHS ISC Standard, “Items Prohibited from Federal Facilities,” February 2013

DHS ISC, “Use of Physical Security Performance Measures,” 2009

DHS ISC Standard, “Physical Security Criteria for Federal Facilities,” April 7, 

2010 (FOUO – requires an HSIN account for access)

Department of the Navy Policy

SECNAV M-5510.30, “DoN Personnel Security Program,” June 2006

SECNAV M-5510.36, “DoN Information Security Program,” June 2006
74 75

SECNAVINST 5510.37, “DoN Insider Threat Program,” August 8, 2013

SECNAV Directed Installation Security Posture Assessment, September 17, 20 

13

CNO Antiterrorism Strategic Guidance, September 2010

OPNAVINST 3400.12, “Navy Required Operational Capability Levels for Navy 

Installations and Activities,” October 6, 2008

OPNAVINST 3300.53C, “Navy Antiterrorism Program,” May 26, 2009 (FOUO 

– on SIPRNET)

OPNAVINST 5530.14E, “Navy Physical Security and Law Enforcement 

Program,” January 28,2009

OPNAVINST 3591.1F, “Small Arms Training and Qualification,” August 12, 

2009

Navy-wide OPTASK Antiterrorism, March 18, 2013

U.S. Fleet Forces, Antiterrorism Operations Order 3300-13, January 2013

U.S. Pacific Fleet Operations Order 201, September 2007

U.S Naval Forces Southern Command, Operations Order 4000-07, October 2007

U.S. Naval Forces Europe, Operations Order 4000-05, April 2006

U.S. Naval Forces Central Command, Operations Order 09-1, December 2009

Department of the Army Policy

Army pamphlet, “Tips for Commanders on Suspicious Activity Reporting”

Army Regulation 600-20, “Army Command Policy,” September 20, 2012

Army Regulation 525-13, “Antiterrorism,” September 11, 2008 (FOUO – 

requires AKO account for access)

All Army Activities (ALARACT) message 145/11, EXORD 171-11, “Law 

Enforcement Suspicious Activity Reporting (eGuardian),” 131536Z April, 2011

All CID message, 015-10, “Implementation of the eGuardian Reporting System,” 

October 26, 2010

HQ, US Army Installation Management Command, OPORD 12-116, 

“Requirement to Establish and Report eGuardian Accounts,” (DTG not available)

Chairman of the Joint Chiefs of Staff Policy

CJCS EXORD for Standup of USNORTHCOM AT-FP Responsibility, 011710Z 

May 2004

Geographic Combatant Command Policy

USNORTHCOM Antiterrorism Instruction 10-222

USNORTHCOM Force Protection Directive (Information Reporting 

Requirements) 11-100, 102100Z April, 2011

USNORTHCOM Force Protection Level messages, 242245Z May 2012

USNORTHCOM Force Protection Directive 11-356 (NCI 10-222 interim 

revision 3), 221745Z December 2011

USNORTHCOM Force Protection Directive 12-241 (NCI 10-222 interim 

revision 4), 292215Z August 2012

USNORTHCOM FP Advisory 13-231, 291935 August 2013

USEUCOM Antiterrorism Operations Order 11-05

USCENTCOM Antiterrorism Operations Order 05-02

USPACOM Antiterrorism/CIP Operations Order 5050-08

USSOUTHCOM SC Regulation 380.16

USAFRICOM AT-CIP Operations Order 10-06

Other

Memorandum of Understanding between The Federal Bureau of Investigation, 

Criminal Justice Information Services Division and the United States Department 

of Defense, December 5, 2012
76 77

Appendix D. Bibliography

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Defense/Director of National Intelligence automated continuing evaluation 

system (ACES)—pilot evaluation. 

Working paper 12-02. Monterey, CA: Defense Personnel Security Research 

Center. FOUO.

Ainslie, F.M., Neal, M.M., & Buck, K.R. Comparison of government and 

commercial criminal history record sources. Unpublished manuscript. Monterey, 

CA: Defense Personnel Security Research Center

Buck, K.R. & Neal, M.M. (2008). Military accession and security clearance 

screening impact on early and adverse separation. Tech. rep. 08-09. Monterey, 

CA: Defense Personnel Security Research Center

Buck, K.R. & Rose, A.E. (2005). Crime self-reporting study: Phase I. Tech. rep. 

05-1. Monterey, CA: Defense Personnel Security Research Center

Buck, K.R. (2005). Comparative productivity of criminal record checks by 

federal investigations and contractors. Tech rep. 05-3. Monterey, CA: Defense 

Personnel Security Research Center

Buck, K.R., Rose, A.E., Wiskoff, M.F., & Liverpool, K.M. (2005). Screening for 

potential terrorists in the enlisted military accessions process. Tech. rep. 05-07. 

Monterey, CA: Defense Personnel Security Research Center. FOUO.

Chandler, C.J. (2013, July 24). Automated record check pilot status update: 

Briefing to DADSIWG. Unpublished manuscript. Monterey, CA: Defense 

Personnel Security Research Center

Chandler, C.J. (2013, October). ACES checks on Aaron Alexis. Unpublished 

manuscript. Monterey, CA: Defense Personnel Security Research Center. FOUO

Defense Personnel Security Research Center & Office of the Director of National 

Intelligence—Special Security Directorate (ODNI-SSD). (2012: August 15). 

Security clearance reciprocity within the Department of Defense: Evaluation of 

reciprocity practices. Unpublished manuscript. Monterey, CA: Author. FOUO

Defense Personnel Security Research Center. (2010). PERSEREC crosswalk of 

adjudicative guidelines, HSPD-12 credentialing, and suitability. Monterey, CA: 

Author

Executive Order 13488, Granting reciprocity on excepted service and federal 

contractor employee fitness and reinvestigating individuals in positions of public 

trust, January 16, 2009

Godes, O. & Lang, E.L. (2009). Identifying personality disorders that are 

security risks: Phase I results. Tech rep. 09-01. Monterey, CA: Defense Personnel 

Security Research Center. FOUO

Helton-Fauth, W.B. (2013). Evaluating health information technology for use in 

accession screening. DRAFT. Unpublished manuscript. Monterey, CA: Defense 

Personnel Security Research Center

Helton-Fauth, W.B. Analysis of decision thresholds articulated in Defense Office 

of Hearings and appeals (DOHA) Statements of Fact: 2002 – 2007 DRAFT. 

Unpublished manuscript. Monterey, CA: Defense Personnel Security Research 

Center

Helton-Fauth, W.B., Ainslie, F.M., Chandler, C.J. (2013). Department of 

Defense/automated continuing evaluation system continuing evaluation: Pilot 

study results. Tech rep. 13-03. Monterey, CA: Defense Personnel Security 

Research Center. FOUO

Helton-Fauth, W.B., Ainslie, F.M., Chandler, C.J., Harris, D.B. (2012). 

Department of Defense and Office of Personnel Management (OPM) Automated 

Continuing Evaluation System (ACES) 

Automated Record Check (ARC) Pilot: Final Report. DRAFT. Unpublished 

manuscript: raw data. Monterey, CA: Defense Personnel Security Research 

Center

Herbig, K.L. & Nelson, P. R. (2004). Reciprocity: A progress report. Tech rep. 

04-2. Monterey, CA: Defense Personnel Security Research Center

Lang, E.L. & Shedler, J. (2013). Relevant risk approach to Q21. DRAFT. 

Unpublished manuscript. Monterey, CA: Defense Personnel Security Research 

Center
78 79

Leggitt, J.S., Leather, J.E., & Lang, E.L. (2010). Using hand-held computers 

when conducting national security background interviews: Utility test results. 

Tech. rep. 10-01. Monterey, CA: Defense Personnel Security Research Center

Neal, M.M., Buck, K.R., & Chandler, C.J. (2006). Comparison of criminal 

history record detection methods to meet NACLC requirements: LAC, NCIC/

III, and NLETS. Unpublished manuscript. Monterey, CA: Defense Personnel 

Security Research Center

Neal, M.M., Leather, J.E., Buck, K.R. OPM, ANACI, NACI, and NACLC 

investigations: Developing baseline information. Unpublished manuscript. 

Monterey, CA: Defense Personnel Security Research Center

Neal, M.M. & Buck, K.R. (2008). Greater information sharing needed between 

screening systems for military accessions and national security clearances. Tech. 

rep. 08-08. Monterey, CA: Defense Personnel Security Research Center

Nelson, L.C. & Smith-Pritchard, S.A. (2013). Baseline suitability analysis. Tech 

rep. 13-05. (Monterey, CA: Defense Personnel Security Research Center

Nelson, L.C. & Tadle, D.L. (2013). 2012 RADAR adjudication quality 

evaluation. DRAFT. Unpublished manuscript. Monterey, CA: Defense Personnel 

Security Research Center

Nelson, L.C., Crawford, K.S., Richmond, D.A., Lang, E.L., Leather, J.E., 

Nicewander, P.P., & Godes, O. (2009). DoD personnel security program 

performance measures. Management rep. 09-01. Monterey, CA: Defense 

Personnel Security Research Center

Office of Personnel Management. (2009, September 24). Guidance on 

implementing executive order 13488, “Granting Reciprocity on Excepted Service 

and Federal Contractor Employee Fitness and 

Reinvestigating Individuals in Positions of Public Trust.” Washington, DC: 

Author. Retrieved October 14, 2013 at http://www.chcoc.gov/Transmittals/

TransmittalDetails.aspx?TransmittalId=2518

Rose, A.E. & Buck, K.R. (2004). Crime self-reporting: Phase II. Management 

rep. 05-3. Monterey, CA: Defense Personnel Security Research Center. FOUO

Rose, A.E. (2005). Compact Council user fee survey. Unpublished manuscript. 

Monterey, CA: Defense Personnel Security Research Center

Rose, A.E. (2007). Options for using military waiver information in personnel 

security clearance investigations. Tech. rep. 07-03. Monterey, CA: Defense 

Personnel Security Research Center

Rose, A.E., Timm, H.W., Pogson, C.E., Gonzalez, J.L., Appel, E.J., Kolb, N. 

(2011). Guidance for developing a cybervetting strategy for national security 

positions. Management rep. 11-02. Monterey, CA: Defense Personnel Security 

Research Center. FOUO

Shechter, O.G. & Lang, E.L. (2011). Identifying personality disorders that 

are security risks: Field test results. Tech. rep. 11-05. Monterey, CA: Defense 

Personnel Security Research Center.

United States Army G2 & Office of Director of National Intelligence (ODNI). 

Assessment of emerging technologies for use in continuous evaluation phase 2. 

DRAFT. Unpublished manuscript. Washington, DC: Author

Youpa, D.G. & Smith-Pritchard, S.A. (2013). Development of a procedure to 

increase awareness and reporting of counterintelligence and terrorism indicators: 

Personal acknowledgment of staff security (PASS). Tech. rep. 13-02. Monterey, 

CA: Defense Personnel Security Research Center.
80 81

Appendix E. Glossary of Terms

Personnel security clearance. An administrative determination by competent 

authority that an individual is eligible for access to classified information.

Access to classified information. The ability and opportunity to obtain 

knowledge of classified information by persons with the proper security 

clearance and a need to know of specified classified information.

Insider. Any person with authorized access to any United States Government 

resource, to include personnel, facilities, information, equipment, networks or 

systems.28

Insider threat. The threat that an insider will use her/his authorized access, 

wittingly or unwittingly, to do harm to the security of the United States. This 

threat can include damage to the United States through espionage, terrorism, 

unauthorized disclosure of national security information, or through the loss or 

degradation of departmental resources or capabilities.29 

Physical security. That part of security concerned with physical measures 

designed to safeguard personnel; to prevent unauthorized access to equipment, 

installations, material, and documents; and to safeguard them against espionage, 

sabotage, damage, and theft.

Targeted violence. Pre-conceived violence focused on individuals, groups, 

or locations where perpetrators are engaged in behaviors that precede and are 

related to their attacks. These perpetrators consider, plan and prepare before 

engaging in acts of violence and are often detectable, providing an opportunity 

for disruption of the intended violence.30

28 National Insider Threat Policy, November 21, 2012

29 Ibid.

30 Defense Science Board Task Force Report: Predicting Violent Behavior, August 2012

Appendix F. Abbreviations and Acronyms

ACES Automated Continuous Evaluation System

ANACI Access National Agency Check plus Written 

Inquiries 

CAC Common Access Card

DIAC Defense Installation Access Control

DITMAC DoD Insider Threat Management and Analysis 

Center

DONCAF Department of the Navy Central Adjudication 

Facility

DISS Defense Information System for Security

e-QIP Electronic Questionnaires for Investigations 

Processing system

FIS Federal Investigative Standards

FSO facility security officer

HSPD-12 Homeland Security Presidential Directive 12

IMESA Identity Management Enterprise Services 

Architecture

IRTPA Intelligence Reform and Terrorism Prevention Act

JPAS Joint Personnel Adjudication System

JSIVA Joint Staff Integrated Vulnerability Assessment

NACLC National Agency Check with Local Agency Checks 

and Credit Check/

National Agency Check with Law Check and 

Credit Search/ 

NCIC National Crime Information Center

NCIS Naval Criminal Investigative Service

NJP non-judicial punishment

NISP National Industrial Security Program

NISPOM National Industrial Security Program Operating 

Manual

OPM Office of Personnel Management

PERSEREC Defense Personnel Security Research Center

PCL personnel security clearance
82

PR periodic reinvestigation

PSI personnel security investigation

PSP Personnel Security Program

RAM random antiterrorism measures

SCI sensitive compartmented information

SF-86 Standard Form 86, Questionnaire for National 

Security Positions

SPIN subject personal interview

TSDB Terrorist Screening Database

USD(I) Under Secretary of Defense for Intelligence

USD(P) Under Secretary of Defense for Policy

WNY Washington Navy Yard