PERSONNEL SECURITY 

CLEARANCES

Continuing Leadership and 

Attention Can Enhance 

Momentum Gained from 

Reform Effort

Statement of Gene L. Dodaro

Comptroller General of the United States

Testimony 

Before the Subcommittee on Oversight of Government 

Management, the Federal Workforce, and the District of 

Columbia, Committee on Homeland Security and 

Governmental Affairs, U. S. Senate 

For Release on Delivery 

Expected at 2:30 p.m. EDT

Thursday, June 21, 2012

GAO-12-815T

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-815T, a testimony 

before the Subcommittee on Oversight of 

Government Management, the Federal 

Workforce, and the District of Columbia, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

June 21, 2012 

PERSONNEL SECURITY CLEARANCES 

Continuing Leadership and Attention Can Enhance 

Momentum Gained from Reform Effort

Why GAO Did This Study

As of October 2010, the Office of the 

Director of National Intelligence 

reported that 3.9 million federal 

employees (military and civilians) and 

contractors hold security clearances. 

DOD comprises the vast majority of 

government security clearances. 

Longstanding backlogs and delays in 

the security clearance process led 

GAO to place the DOD’s Personnel 

Security Clearance Program on its 

high-risk list in 2005. Delays in issuing 

clearances can result in millions of 

dollars of additional cost to the federal 

government and could pose a national 

security risk. DOD and others have 

taken steps to address these issues

and additional concerns with clearance 

documentation used to determine 

eligibility for a clearance. As a result, in 

2011, GAO removed the program from 

its high-risk list. 

This testimony addresses (1) the key 

actions that led GAO to remove DOD’s 

security clearance program from its 

high-risk list and (2) the additional 

actions that can enhance the security 

clearance reform efforts. This 

statement is based on prior GAO 

reports and testimonies on DOD’s 

personnel security clearance program 

and governmentwide suitability and 

security clearance reform efforts. 

What GAO Found

Since GAO first identified the Department of Defense’s (DOD) Personnel 

Security Clearance Program as a high-risk area, DOD, in conjunction with 

Congress and executive agency leadership, took actions that resulted in 

significant progress toward improving the processing of security clearances. 

Congress held more than 14 oversight hearings to help oversee key legislation, 

such as the Intelligence Reform and Terrorism Prevention Act of 2004, which 

helped focus attention and sustain momentum of the governmentwide reform 

effort. In addition, the committed and collaborative efforts of DOD, the Office of 

the Director of National Intelligence (ODNI), Office of Management and Budget 

(OMB), and Office of Personnel Management (OPM) as leaders of the Suitability 

and Security Clearance Performance Accountability Council (Performance 

Accountability Council) demonstrated commitment to and created a vision for the 

reform effort, which led to significant improvements in the timeliness of 

processing security clearances. As a result, in 2011, GAO removed DOD’s 

Personnel Security Clearance Program from its high-risk list because of the 

agency’s progress in improving timeliness, development of tools and metrics to 

assess quality, and commitment to sustaining progress. Specifically, GAO found 

that DOD met the 60-day statutory timeliness objective for processing initial 

clearances in fiscal year 2010 by processing 90 percent of its initial clearances in 

an average of 49 days. In addition, DOD developed two quality tools to evaluate 

completeness of investigation documentation and agencies' adjudication process 

regarding the basis for granting security clearances. Moreover, DOD, ODNI, 

OMB, and OPM developed and are in the process of implementing 15 metrics 

that assess the timeliness and quality of investigations, adjudications, reciprocity 

and automation of security clearances.

Even with the significant progress in recent years, sustained leadership attention 

to the following additional actions, on which GAO has previously reported, can

enhance the security clearance reform efforts of executive branch agencies and 

the Performance Accountability Council: 

• Continue to implement, monitor, and update outcome-focused performance 

measures. The development of tools and metrics to monitor and track quality 

are positive steps, but full implementation of these tools and measures will 

enable the executive branch to demonstrate progress in quality 

improvements and contribute to greater visibility over the clearance process.

• Seek opportunities to enhance efficiencies and manage costs related to the 

reform effort. Given the current fiscal constraints, identifying long-term 

funding requirements for the security clearance process is critical for the 

executive branch to sustain the reform effort. Further, the reform efforts are a 

venue to facilitate the identification of efficiencies in areas including 

information technology and investigation and adjudication case management 

processes. 

• Create a sound requirements process for determining which positions require 

clearances and level of clearances. A sound requirements determination 

process may help ensure that workload and costs are not higher than 

necessary by ensuring that clearances are only requested for positions when 

needed and that the appropriate clearance level is requested. 

View GAO-12-815T. For more information, 

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

farrellb@gao.gov. 
 

Page 1 GAO-12-815T 

Chairman Akaka, Ranking Member Johnson, and Members of the 

Subcommittee:

Thank you for the opportunity to discuss the removal of the Department of 

Defense’s (DOD) personnel security clearance program from our high-risk 

list.1

Personnel security clearances allow government and industry personnel 

to gain access to classified information that, through unauthorized 

disclosure can in some cases cause exceptionally grave damage to 

U.S. national security. The 2010 unauthorized leaks of about 500,000 

classified documents posted to the Internet related to the wars in 

Afghanistan and Iraq are examples of the inherent risks involved when 

granting an individual a security clearance. As you know, there continues 

to be a high volume of clearances processed. For example, prior to 

September 11, 2001, we reported that DOD processed about 200,000 

clearances annually. For fiscal year 2008, we reported that DOD 

approved personnel security clearances for approximately 630,000 

military, civilian, and industry personnel. In 2010, the Director of National 

Intelligence reported that there were approximately 3.9 million federal 

government and contractor employees who held a security clearance. 

As you know, we maintain a program to focus attention on 

government operations that we identify as high risk due to their greater 

vulnerabilities to fraud, waste, abuse, and mismanagement or the need 

for transformation to address economy, efficiency, or effectiveness 

challenges. In the past two decades, the attention of Congress, the 

agencies, and others to high-risk areas has brought results. Over 

one-third of the areas previously designated as high-risk have been 

removed from the list because significant progress was made to address 

the problems. When legislative, administrative, and agency actions, 

including those in response to our recommendations, result in significant 

progress toward resolving a high-risk problem, we remove the high risk 

designation. In 2011, DOD’s personnel security clearance program 

became the first designated defense area to be removed from our highrisk list. Seven DOD high-risk areas remain on the list. My testimony 

today will focus on (1) the key actions that led us to remove DOD’s 

personnel security clearance program from our high-risk list, and (2) 

additional actions that can enhance the governmentwide personnel 

security clearance reform efforts.

 

1 GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2007).

 
 

Page 2 GAO-12-815T 

DOD accounts for the vast majority of all initial personnel security 

clearances, making it a formidable challenge to those responsible for 

deciding who should be granted a clearance.

Multiple executive-branch agencies are responsible for different phases in 

the federal government’s personnel security clearance process. With 

respect to DOD’s personnel security clearance program, DOD is 

responsible for determining which military, DOD civilian, and privateindustry personnel working on DOD contracts require access to classified 

information and must apply for a security clearance and undergo an 

investigation. The Office of Personnel Management (OPM), in turn, 

conducts these investigations for DOD. OPM investigators—often 

contractors—use federal investigative standards and OPM internal

guidance as criteria for collecting background information on applicants.

Federal guidelines require that DOD adjudicators use the information 

contained in the resulting investigative reports to determine whether an 

applicant is eligible for a personnel security clearance.

We first placed DOD’s personnel security clearance program on our highrisk list in 2005. Some of the problems included (1) delays in completing 

clearances; (2) incomplete investigative reports from OPM, the agency 

that reportedly supplies about 90 percent of all federal clearance 

investigations, including those for DOD; and (3) the granting of some 

clearances by DOD adjudicators even though required data were missing 

from the investigative reports used to make such determinations. We also 

reported that delays in issuing clearances can result in millions of dollars 

of additional cost to the federal government. Furthermore, during this 

period the executive branch initiated actions to reform the 

governmentwide security clearance process.

My testimony is based on our issued reports and testimonies on DOD’s 

personnel security clearance program and governmentwide suitability and 

security clearance reform efforts.2 Our reports and testimonies were 

conducted in accordance with generally accepted government auditing 

standards.

 

2

See related GAO products at the end of this statement. More information on our scope 

and methodology is included in each issued report. 
 

Page 3 GAO-12-815T 

Since we identified DOD’s Personnel Security Clearance program as a 

high-risk area, DOD, in conjunction with Congress and other executive 

agency leadership, took actions that resulted in significant progress 

toward resolving problems we identified with the security clearance 

program. In 2011, we removed DOD’s personnel security clearance 

program from our high-risk list because of the agency’s progress in

improving timeliness and the development of tools and metrics to assess 

quality, as well as DOD’s commitment to sustaining progress. Importantly, 

congressional oversight and the committed leadership of the Suitability 

and Security Clearance Performance Accountability Council 

(Performance Accountability Council)3

 –which has been responsible for 

overseeing security clearance reform efforts since 2008—greatly 

contributed to the progress of DOD and the governmentwide security 

clearance reform.4

Leadership in Congress and the executive branch demonstrated 

commitment to reforming the security clearance process to address 

longstanding problems associated with the personnel security clearance 

program. As we have previously noted, top leadership must be committed 

to organizational transformation.5 Specifically, leadership must set the 

direction, pace, and tone and provide a clear, consistent rationale that 

brings everyone together behind a single mission. Figure 1 illustrates key 

events related to the Suitability and Personnel Security Clearance Reform 

Effort.

 

3 The Performance Accountability Council is comprised of the Director of National 

Intelligence as the Security Executive Agent, the Director of OPM as the Suitability 

Executive Agent, and the Deputy Director for Management, OMB, as the chair with the 

authority to designate officials from additional agencies to serve as members. The current 

council includes representatives from the Departments of Defense, Energy, Health and 

Human Services, Homeland Security, State, Treasury, and Veterans Affairs, and the 

Federal Bureau of Investigation.

4 Determinations of suitability for government employment in positions in the competitive 

service and for career appointment in the Senior Executive Service include consideration 

of aspects of an individual’s character or conduct that may have an effect on the integrity 

or efficiency of their service.

5 GAO, Personnel Security Clearances: Preliminary Observations on Joint Reform Efforts 

to Improve the Governmentwide Clearance Eligibility Process, GAO-08-1050T

(Washington, D.C.: July 30, 2008).

Leadership 

Commitment, 

Improved Timeliness, 

and Development of 

Metrics Were Key to 

Removal of DOD’s 

Security Clearance 

Program from GAO’s 

High-Risk List

Top Leadership 

Demonstrated 

Commitment and 

Collaboration in 

Reforming Security 

Clearance Process
 

Page 4 GAO-12-815T 

Figure 1: Key Events Related to the Suitability and Personnel Security Clearance Reform Effort

Congressional legislation and oversight has helped focus attention and 

sustain momentum to improve the processing of security clearances not 

only for DOD but governmentwide. The Intelligence Reform and 

Terrorism Prevention Act of 2004 (IRTPA)6

 

6

Pub. L. No. 108-458, 118 Stat. 3638 (2004).

established, among other 

things, milestones for reducing the time to complete initial clearances. We 

previously identified best practices for agencies to successfully transform 

Congressional Leadership
 

Page 5 GAO-12-815T 

their cultures including among other things, setting implementation goals 

and a timeline to build momentum and show progress from day one.7

Congressional oversight through hearings held by this Subcommittee 

helped highlight the need for security clearance reform. From 2005 to 

2010, congressional committees held more than 14 hearings on security 

clearance reform, with 7 held by this Subcommittee.

IRTPA established an interim objective to be met by December 2006

under which DOD and other agencies that adjudicate security clearances 

were to make a decision on at least 80 percent of initial clearance 

applications within 120 days, on average. Further, IRTPA called for the 

executive branch to implement a plan by December 17, 2009, under 

which, to the extent practical, at least 90 percent of decisions are made 

on applications for an initial personnel security clearance within 60 days, 

on average. Additionally, IRTPA required the executive branch to begin 

providing annual reports to Congress in 2006 on the progress made the 

preceding year toward meeting IRTPA’s objectives for security 

clearances, including the length of time agencies took to complete the 

investigations and adjudications—the decision as to whether an individual 

should be granted eligibility for a clearance.

8

 

7 GAO, Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned for 

the Department of Homeland Security and Other Federal Agencies, 

This 

subcommittee’s oversight helped set the direction for the agencies, 

including GAO, to work collaboratively on developing metrics in order to 

address our concerns about the completeness and quality of 

investigations and adjudications. Many federal program efforts, including 

those related to personnel security, generally require the effective 

collaboration of more than one agency. For example, on March 17, 2010, 

the leaders of the reform effort—the Office of Management and Budget 

(OMB), OPM, Office of the Director of National Intelligence (ODNI), and 

DOD—along with GAO, met with this Subcommittee’s Chairman and 

then-Ranking Member to discuss the status of security clearance reform 

efforts and consult on metrics that could be used to measure progress of 

GAO-03-293SP

(Washington, D.C.: Nov. 14, 2002), and Results-Oriented Cultures: Implementation Steps 

to Assist Mergers and Organizational Transformations, GAO-03-669 (Washington, D.C.: 

July 2, 2003). 

8 GAO has testified on security clearance reform before this committee as well as the (1) 

Subcommittee on Intelligence Community Management, House Permanent Select 

Committee on Intelligence, (2) the Subcommittee on Government Management, 

Organization, and Procurement, House Committee on Oversight and Government Reform, 

and (3) Subcommittee on Readiness, House Committee on Armed Services. 
 

Page 6 GAO-12-815T 

security clearance reform efforts. After that meeting, OMB, ODNI, DOD, 

OPM, and GAO provided a memorandum on May 31, 2010 to Chairman 

Akaka containing a matrix with 15 metrics for assessing the timeliness 

and quality of investigations, adjudications, reciprocity (an agency’s 

acceptance of a background investigation or clearance determination 

completed by any authorized investigative or adjudicative agency), and 

automation.9

Furthermore, we have noted for many years the central role that the 

Government Performance and Results Act (GPRA) could play in 

identifying and fostering improved coordination across related federal 

program efforts. The GPRA Modernization Act of 2010 (GPRAMA)

The development of these metrics played a key role in 

GAO’s decision to remove DOD’s Personnel Security Clearance program 

from the high-risk list.

10 calls 

for a more coordinated and crosscutting approach to achieve meaningful 

results.11 GPRAMA provides an opportunity for agencies to collect and 

report more timely and useful performance information on crosscutting 

programs. This performance information can play an important role in 

congressional decision making. In fact, Mr. Chairman, we conducted work 

for you focusing on how Congress can use such information to address 

challenges facing the government.12

In addition to congressional leadership, multiple administrations, DOD, 

and key executive agencies demonstrated a commitment and vision to 

reform the security clearance process. Specifically, after we initially 

DOD’s personnel security clearance 

program was one of three case studies we used to illustrate how 

Congress has used agency performance information in its decision 

making.

 

9 We participated in legislative and executive branch discussions on development of these 

metrics. However, given the need for GAO to remain independent in carrying out its 

auditing responsibilities of the executive branch, decisions related to performance 

measures and their effective implementation are fundamentally an executive branch 

management responsibility.

10Pub. L. No. 111-352, 124 Stat. 3886 (2011). GPRAMA amended the Government 

Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285 (1993).

11 GAO, Managing for Results: GPRA Modernization Act Implementation Provides 

Important Opportunities to Address Government Challenges, GAO-11-617T (Washington, 

D.C.: May 10, 2011).

12 GAO, Managing for Results: Opportunities for Congress to Address Government 

Performance Issues, GAO-12-215R (Washington, D.C.: Dec. 9, 2011).

Executive Branch Leadership 
 

Page 7 GAO-12-815T 

placed the program on our high-risk list, top executive branch leadership 

put in place an effort to reform the security clearance process. For 

example, in 2007, DOD and ODNI formed the Joint Security Clearance 

Process Reform Team, known as the Joint Reform Team, to improve the 

security clearance process governmentwide.

13 Specifically, they tasked 

the Joint Reform Team to execute joint reform efforts so that they achieve 

IRTPA timeliness goals and improve the processes related to granting 

security clearances.14 In 2008, the President in a memorandum called for 

a reform of the security clearance program and subsequently issued an 

executive order establishing the Performance Accountability Council.15

DOD worked with the Joint Reform Team and the Performance 

Accountability Council to develop a corrective action plan to improve 

timeliness and demonstrate progress toward reforming the security 

clearance process. For example,

Under the executive order, this council is accountable to the President for 

leading the implementation of reform, including aligning security and 

suitability processes, holding agencies accountable for implementation, 

and establishing goals and metrics for progress.

• DOD’s leadership, in conjunction with the Joint Reform Team, 

developed a plan for reform that continuously evolved to incorporate 

 

13 In June 2007, the Director of National Intelligence and Under Secretary of Defense for 

Intelligence through a memorandum of agreement established The Joint Security Process 

Reform Team.

14 The Joint Reform Team continues to work on the reform effort under the Performance 

Accountability Council by providing progress reports, recommending research priorities, 

and overseeing the development and implementation of an information technology 

strategy, among other things. Since its formation, the Joint Reform Team under the 

Performance Accountability Council: (1) Submitted an initial reform plan to the President 

on April 30, 2008. The plan proposed a new process for determining clearance eligibility 

that departs from the current system in a number of ways, including the use of a more 

sophisticated electronic application, a more flexible investigation process, and the 

establishment of ongoing evaluation procedures between formal clearance investigations. 

The report was updated in December 2008 to include an outline of reform progress and 

further plans. (2) Issued an Enterprise Information Technology Strategy to support the 

reformed security and suitability process in March 2009. According to the report, the Joint 

Reform Team is pursuing an approach that leverages existing systems and capabilities, 

where applicable, and developing new tools where necessary.

15 Exec. Order No. 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).
 

Page 8 GAO-12-815T 

new goals and address identified issues. To communicate these 

plans, the Joint Reform Team issued an initial reform plan in April 

2008 that presented a new seven-step design intended to streamline 

the security clearance process, including the use of a more 

sophisticated electronic application, a more flexible investigation 

process, and the establishment of ongoing evaluation procedures 

between formal clearance investigations. The report was updated in 

December 2008 to include an outline of reform progress and further 

plans, and in March 2009 the Joint Reform Team issued its Enterprise 

Information Technology Strategy for the security clearance and 

suitability reform program. Then, in line with GAO recommendations, 

DOD worked with the Performance Accountability Council to issue a 

strategic framework that the council included in its 2010 report to the 

President. The strategic framework identified key governmentwide 

reform goals and identified the root causes for timeliness delays and 

delays to agencies honoring reciprocity. It also set forth a 

governmentwide mission, performance measures, a communications 

strategy, roles and responsibilities, and metrics to measure the quality 

of security clearance investigations and adjudications. DOD continues 

to work with the Performance Accountability Council to sustain 

clearance reform efforts and enhance transparency and accountability 

through annual reporting to Congress.

16

• DOD issued guidance on adjudication standards. In May 2009, we 

found that although DOD asserted that adjudicators follow a riskmanagement approach for granting security clearances, DOD had not 

issued formal guidance clarifying if and under what circumstances 

adjudicators can adjudicate incomplete investigative reports—such as 

missing information relevant to residences, employment, or education. 

As a result, we recommended that DOD issue guidance that clarifies 

when adjudicators may use incomplete investigative reports as the 

basis for granting clearances. Subsequently, on November 8, 2009, 

the Under Secretary of Defense for Intelligence issued guidance on 

adjudication standards that outline the minimum documentation 

requirements adjudicators must adhere to when documenting 

personnel security clearance determinations for cases with potentially 

damaging information. On March 10, 2010, the Under Secretary of 

 

16 Annual reports were required under IRTPA through 2011. Section 367 of the 

Intelligence Authorization Act for Fiscal Year 2010, Pub. L. No. 111-259 (2010), 

established new annual reporting requirements in section 506H of the National Security 

Act of 1947 (50 U.S.C. § 415a-10). 
 

Page 9 GAO-12-815T 

Defense for Intelligence issued additional guidance that clarifies when 

adjudicators may use incomplete investigative reports as the basis for 

granting clearances. This guidance provides standards that can be 

used for the sufficient explanation of incomplete investigative reports. 

Further, according to DOD officials, in 2010, DOD created a 

Performance Accountability Directorate within the Directorate of 

Security to provide oversight and accountability for the DOD Central 

Adjudication Facilities that process DOD adjudicative decisions.

One of DOD’s key actions that led to the removal of its personnel security 

clearance program from our high-risk list was that DOD was able to 

demonstrate its progress in having implemented corrective measures. 

Longstanding backlogs and delays in the clearance process led to our 

initial designation of this area as high risk. For example, in 2004, we 

testified that from fiscal year 2001 through fiscal year 2003, the average 

time for DOD to determine clearance eligibility for industry personnel 

increased by 56 days to over 1 year.17 In 2005, we reported that DOD 

could not estimate the full size of its backlog, but we identified over 

350,000 cases exceeding established timeframes for determining 

eligibility.18 Moreover, in 2007 and 2009, we reported that clearances 

continued to take longer than the timeliness goals prescribed in IRTPA.19

 

17 GAO, DOD Personnel Clearances: Preliminary Observations Related to Backlogs and 

Delays in Determining Security Clearance Eligibility for Industry Personnel, 

In 2011, we reported that DOD processed 90 percent of initial clearances 

in an average of 49 days for federal civilians, military, and industry 

GAO-04-202T

(Washington, D.C.: May 6, 2004).

18 High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January 2005.

19 IRTPA required agencies to make a determination of eligibility for a clearance on at 

least 80 percent of all applications within an average of 120 days after the date of receipt 

of the application, with a maximum of 90 days allotted for the investigation and a 

maximum of 30 days allotted for the adjudication by no later than December 17, 2006. We 

found that clearances in 2007 for DOD industry personnel took an average of 325 days to 

complete. We also found that the application-submission phase averaged 111 days for 

industry personnel seeking initial top secret clearances, but the government goal is 14 

days. In the investigation phase, we found that it took an average of 286 days for initial 

clearances—compared with the goal of 180 days—and 419 days for clearances updates 

for the 2,259 industry personnel who were granted clearance eligibility in January and 

February 2006. GAO, High-Risk Series: An Update, GAO-07-310 (Washington, D.C.: 

January 2007). In our 2009 high-risk update, GAO-09-271, we noted that DOD made 

significant progress toward meeting statutory timeliness goals for initial clearances. In 

December 2008, we reported that a sample of initial DOD clearances completed in fiscal 

year 2008 took an average of 87 days.

DOD Developed 

Assessment Tools and 

Performance Metrics and 

Improved Timeliness to 

Demonstrate Progress
 

Page 10 GAO-12-815T 

personnel and met the 60-day statutory timeliness objective for 

processing all initial clearances in fiscal year 2010. Also we found that 

DOD completed 90 percent of initial clearances for industry personnel in 

an average of 63 days for all the data we reviewed in fiscal year 2010,20

Our high-risk designation was based not only on problems with timeliness 

but also incomplete documentation of investigations and adjudications. 

We reported on missing documentation in investigative reports prepared 

by OPM that DOD adjudicators had used to make clearance eligibility 

decisions. In 2009, we estimated that 87 percent of about 3,500 OPM 

investigative reports provided to DOD in July 2008 were missing required 

documentation, which in most cases pertained to residences, 

employment, and education. DOD adjudicators granted clearance 

eligibility without requesting missing investigative information or fully 

documenting unresolved issues in 22 percent of DOD’s adjudicative files. 

These findings led us to recommend that OPM and DOD, among other 

things, develop and report metrics on completeness and other measures 

of quality for investigations and adjudications that address the 

effectiveness of the new procedures. DOD agreed and implemented our 

recommendations regarding adjudication. OPM neither concurred nor 

nonconcurred with our recommendation; however, as noted earlier, OPM 

has taken steps to develop metrics.

demonstrating an improvement from what we found in 2004, when the 

average processing time for industry personnel was over a year.

Subsequently, DOD developed two quality tools to evaluate 

completeness of documentation used to determine clearance eligibility.

First, the Rapid Assessment of Incomplete Security Evaluations (RAISE) 

tracks the quality of investigations conducted by OPM. Results of RAISE 

will be reported to the Director of National Intelligence, which, as the 

Security Executive Agent of the Performance Accountability Council, will 

arbitrate any potential disagreements between OPM and DOD and clarify 

policy questions. DOD deployed RAISE to four Central Adjudication 

Facilities from July to October 2010 and planned to complete deployment 

to the remaining Central Adjudication Facilities by calendar year 2011. 

According to DOD officials, as of June 2012 this tool has been deployed 

to all of DOD’s non-intelligence agencies adjudication facilities. Although 

the Joint Reform Team is considering using it in the future, it is not being 

 

20 GAO-11-278. 
 

Page 11 GAO-12-815T 

used by other executive agencies. Second, in 2008 DOD developed the 

Review of Adjudication Documentation Accuracy and Rationales 

(RADAR), which tracks the quality of clearance adjudications. In 2009, 

the Under Secretary of Defense for Intelligence directed DOD Central 

Adjudication Facilities to provide adjudication case records to the Defense 

Personnel Research Center for analysis. According to DOD officials, the 

department plans to use results of the RADAR assessments to monitor 

Central Adjudication Facilities’ compliance with documentation policies, 

communicate performance to the Central Adjudication Facilities, identify 

potential weaknesses and training needs, increase compliance, and 

establish trend data. DOD has completed a pilot program for the use of 

RADAR and began its implementation for the Army, Defense Industrial 

Security Clearance Office, and Navy Central Adjudication Facilities in 

September 2010. In addition to these assessment tools, in 2010 DOD, 

OMB, ODNI, and OPM developed 15 metrics that assess the timeliness 

and quality of investigations, adjudications, reciprocity, and automation. 

The quality metrics, in turn, can be used to gauge progress and assess 

the quality of the personnel security clearance process. These metrics 

represented positive developments that could contribute to greater 

visibility over the clearance process.

Having assessment tools and performance metrics in place is a critical 

initial step toward instituting a program to monitor and independently 

validate the effectiveness and sustainability of corrective measures. The 

combination of congressional reporting requirements, the strategic 

framework, and the development of quality metrics, will help ensure 

transparency throughout the reform effort. It is important not only to have 

metrics but to use them to guide implementation. By using metrics for 

timeliness, DOD was able to show progress over time that helped build 

momentum to reach the final goal.
 

Page 12 GAO-12-815T 

DOD’s security clearance reform effort aligned with our criteria for 

removal from the high-risk list in fiscal year 2011. However, security 

clearance reform extends beyond DOD throughout the executive branch. 

This is evidenced by the oversight structure, through the Performance 

Accountability Council, and broad executive branch participation in the 

reform effort. Building on the factors for reforming the security process 

that we have reported in the past, continued leadership and attention, 

such as continuing to monitor and update outcome-focused performance 

measures, seeking opportunities to enhance efficiency and managing 

costs, and ensuring a strong requirements determination process, may 

enhance the security clearance reform effort.21

DOD has developed tools to monitor quality as well as participated in the 

development and tracking of quality metrics for OPM’s investigations and 

DOD’s adjudications through the Performance Accountability Council. We 

view the development of quality metrics as a positive step towards 

creating greater visibility over the quality of the clearance process and 

identifying specific quantifiable targets linked to goals that can be 

measured objectively. Moreover, leaders and others need to use these 

metrics to gauge progress toward improvements. Further, the 

development of performance measures related to the security clearance 

process by the Performance Accountability Council aligns with our 

previous recommendation to develop outcome-focused performance 

measures to continually evaluate the progress of the reform effort.22 We 

have also previously reported on the importance of continually assessing 

and evaluating programs as a good business practice, including 

evaluating metrics to help ensure that they are effective and updated 

when necessary.23

 

21 GAO, Personnel Clearances: Key Factors for Reforming the Security Clearance 

Process, 

As a result, it is important to sustain the momentum of 

the reform and that DOD and OPM complete implementation of the 

GAO-08-776T (Washington, D.C.: May 22, 2008).

22 GAO, Personnel Security Clearances: An Outcome-Focused Strategy Is Needed to 

Guide Implementation of the Reformed Clearance Process, GAO-09-488 (Washington, 

D.C.: May 19, 2009).

23 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

Continuing Executive 

Branch Leadership 

and Management

Attention May 

Enhance the Security 

Clearance Reform 

Efforts

Implementing, Monitoring, 

and Updating OutcomeFocused Performance 

Measures
 

Page 13 GAO-12-815T 

quality tools and metrics so that the executive branch can demonstrate 

progress in improving the quality of investigations and adjudications.

Leaders of the reform effort have consistently stated that implementation 

of reform will be incremental, and therefore, it is important that the 

information necessary to capture performance is up-to-date. The 

Performance Accountability Council quality metrics were developed 

subsequent to the issuance of the 2010 Strategic Framework, which 

articulates the goals of the security and suitability process reform. As a 

result, the 2010 Strategic Framework did not include a detailed plan or 

guidance for the implementation of the quality metrics. Further, the 

May 31, 2010 memorandum in which the Performance Accountability 

Council detailed its metrics did not discuss how often the metrics will be 

reexamined for continuous improvement. Moreover, according to DOD, 

the tools and metrics to assess quality have not been fully implemented. 

For example, while DOD has implemented its RAISE tool for investigation 

quality, it is not being used by other executive branch agencies—

including OPM, which conducts the investigations and would be the 

appropriate agency to take actions to improve investigation quality—

although the Joint Reform Team is considering using it in the future. 

Without these tools and metrics the executive branch will be unable to 

demonstrate progress in improving quality.

Emphasis on quality in clearance processes should promote positive 

outcomes, including more reciprocity among agencies in accepting each 

others’ clearances. Building quality throughout clearance processes is 

important, but government agencies have not paid the same attention to 

quality as they have to timeliness. The emphasis on timeliness is due in 

part to the requirements and objectives established in IRTPA regarding 

the speed with which clearances should be completed. Our work has 

repeatedly called for more emphasis on quality.

As previously noted, IRTPA required an annual report of progress and 

key measurements as to the timeliness of initial security clearances in 

February of each year from 2006 through 2011. It specifically required 

those reports to include the periods of time required for conducting 

investigations, adjudicating cases, and granting clearances. IRTPA 

required the executive branch to implement a plan by December 2009 in 

which, to the extent practical, 90 percent of initial clearances were 

completed within 60 days, on average. In its initial reports, the executive 

branch reported only on the average of the fastest 90 percent of 

clearances and excluded the slowest 10 percent. We previously reported 

that full visibility was limited by the absence of comprehensive reporting 
 

Page 14 GAO-12-815T 

of initial clearance decisions timeliness. 24 Consistent with our 

recommendation, the executive branch began reporting on the remaining 

10 percent in its 2010 and 2011 reports. However, the IRTPA requirement 

for the executive branch to annually report on its timeliness expired last 

year. More recently, in 2010, the Intelligence Authorization Act of 2010 

established a new requirement25 that the President annually report the 

total amount of time it takes to process certain security clearance 

determinations for the previous fiscal year for each element of the 

Intelligence Community. 26

The Intelligence Authorization Act of 2010 requires, among other things, 

annual reports from the President to Congress that include the total 

number of active security clearances throughout the United States 

government, to include both government employees and contractors. Its 

timeliness reporting requirement, however, applies only to the elements of 

the Intelligence Community. Unlike the IRTPA reporting requirement, the 

requirement to submit these annual reports does not expire. Further, the 

Intelligence Authorization Act requires two additional one-time reports: 

first, a report to Congress by the President including metrics for 

adjudication quality, and second, a report to the congressional 

intelligence committees by the Inspector General of the Intelligence 

Community on reciprocity. The report containing metrics for adjudication 

quality summarizes prior information on developed tools and performance 

measures; however, it does not provide additional information on the 

implementation or update of the performance measures that were 

 

24 GAO, Personnel Clearances: Key Factors to Consider in Efforts to Reform Security 

Clearance Processes. GAO-08-352T. Washington, D.C.: February 27, 2008. 

25 Section 367 of the Intelligence Authorization Act for Fiscal Year 2010, Pub. L. No. 111-

259 (2010), established new annual reporting requirements in section 506H of the 

National Security Act of 1947 (50 U.S.C. § 415a-10). 

26 The Intelligence Community comprises 17 components: the National Security Agency, 

National Geospatial-Intelligence Agency, National Reconnaissance Office, Defense 

Intelligence Agency, Army Intelligence, Navy Intelligence, Marine Corps Intelligence, Air 

Force Intelligence (Air Force Intelligence, Surveillance, and Reconnaissance), Office of 

the Director of National Intelligence, Central Intelligence Agency, Department of 

Homeland Security (Office of Intelligence and Analysis), Department of State (Bureau of 

Intelligence and Research), Department of the Treasury (Office of Intelligence and 

Analysis), Federal Bureau of Investigation (National Security Branch), Drug Enforcement 

Agency (Office of National Security Intelligence), U.S. Coast Guard (Intelligence and 

Criminal Investigations), and Department of Energy (Office of Intelligence and 

Counterintelligence). 
 

Page 15 GAO-12-815T 

identified in the May 2010 memorandum on quality metrics. Additionally, 

according to an ODNI official, the report on reciprocity has not been 

provided, although these reports were required 180 days after the law 

was enacted on Oct 7, 2010.

The Intelligence Authorization Act of 2010 reporting requirement on 

reciprocity—an agency’s acceptance of a background investigation or 

clearance determination completed by any authorized investigative or 

adjudicative agency—is the first time the executive branch has been 

required to report on this information since the reform effort began. 

Further, in 2010 we reported that although there are no governmentwide 

metrics to comprehensively track when and why reciprocity is granted or 

denied, agency officials stated that they routinely take steps to honor 

previously granted security clearances.27

In addition, agencies do not consistently and comprehensively track the 

extent to which reciprocity is granted. OPM has a metric to track 

reciprocity, but this metric captures limited information, such as numbers 

of requested and rejected investigations, but not the number of cases in 

which a previously granted security clearance was or was not honored. 

Similarly, the metrics proposed by the Performance Accountability 

Council do not track the extent to which reciprocity is or is not ultimately 

honored. For example, metrics proposed by the Performance 

Accountability Council, such as the number of duplicate requests for 

investigations, percentage of applications submitted electronically, 

number of electronic applications submitted by applicants but rejected by 

OPM as unacceptable because of missing information or forms, and

percentage of fingerprint submissions determined to be “unclassifiable” by 

the Federal Bureau of Investigation, provide useful information but do not 

We found that agencies do not 

consistently document the additional steps they have taken prior to 

granting a reciprocal clearance. For example, the Navy keeps electronic 

documentation, the Department of Energy and the Department of the 

Treasury keep paper documentation, and the Army and the Air Force do 

not maintain any documentation on the additional steps taken to accept a 

previously granted security clearance. Consequently, there is no 

consistent tracking of the amount of staff time spent on the additional 

actions that are taken to honor a previously granted security clearance.

 

27 GAO, Personnel Security Clearances: Overall Progress Has Been Made to Reform the 

Governmentwide Security Clearance Process, GAO-11-232T (Washington, D.C.: Dec. 1, 

2010).
 

Page 16 GAO-12-815T 

track the extent to which reciprocity is or is not ultimately honored. 

Without comprehensive, standardized metrics to track reciprocity, and 

documentation of the process, decision makers lack a complete picture of 

the extent to which reciprocity is granted and the challenges to honoring 

previously granted security clearances.

To further improve governmentwide reciprocity, in 2010 we recommended 

that the Deputy Director of Management, OMB, in the capacity as Chair of 

the Performance Accountability Council, develop comprehensive metrics 

to track reciprocity and then report the findings from the expanded 

tracking to Congress.28 OMB generally concurred with our 

recommendation, stating that the Performance Accountability Council is 

working to develop these additional metrics. According to a 2011 report 

on security clearance performance metrics, the executive branch is 

making progress toward developing metrics to track reciprocity 

specifically with the intelligence community agencies.29 We are 

encouraged by the Performance Accountability Council’s development of 

quality metrics, which include some metrics for tracking reciprocity. These 

are positive steps that can contribute to greater visibility of the clearance 

process, but these measures have not yet been fully implemented or their 

effectiveness assessed.

Our previous work has highlighted the importance of the executive branch 

enhancing efficiency and managing costs related to the reform effort. For 

example, in 2008, we noted that one of the key factors to consider in 

current and future reform efforts was the long-term funding 

requirements.30 Further, in 2009, we found that reform-related reports did 

not detail what reform objectives require funding, how much they will cost, 

or where funding will come from.31

 

28 GAO, Personnel Security Clearances: Progress Has Been Made to Improve Timeliness 

but Continued Oversight Is Needed to Sustain Momentum, 

Furthermore, the reports did not 

GAO-11-65 (Washington, 

D.C.: November 19, 2010).

29 Office of the Director of National Intelligence, 2011 Report on Metrics for Security 

Clearance Adjudication Quality (January 17, 2012) 

30 GAO. DOD Personnel Clearance: Improved Annual Reporting Would Enable More 

Informed Congressional Oversight. GAO-08-350 (Washington, D.C.: February 13, 2008). 

31 GAO. Personnel Security Clearances: An Outcome-Focused Strategy Is Needed to 

Guide Implementation of the Reformed Clearance Process. GAO-09-488 (Washington, 

D.C.: May 19, 2009).

Enhancing Efficiencies 

and Managing Costs
 

Page 17 GAO-12-815T 

estimate potential cost savings resulting from the streamlined process. At 

that time, senior reform leaders stated that cost estimates had not been 

completed by the Joint Reform Team or the agencies affected by reform 

as it was too early. Accordingly, we recommended that reform leaders 

issue a strategic framework that contained the long-term funding 

requirements of reform, among other things. Consequently, in February 

2010, the Performance Accountability Council issued a strategic 

framework that responded to our recommendation; however, that 

framework did not detail funding requirements. Instead, it noted that DOD 

and OPM would cover costs for major information technology 

acquisitions.

As reform leaders, through the Performance Accountability Council, 

consider changes to the current clearance processes, they should ensure 

that Congress is provided with the long-term funding requirements 

necessary to implement any such reforms. Those funding requirements to 

implement changes to security clearance processes are necessary to 

enable the executive branch to compare and prioritize alternative 

proposals for reforming the clearance processes. For example, DOD 

officials told us that it was unable to conduct quality assessment of 

adjudications during fiscal year 2011 due to lack of funding. In addition, 

DOD officials noted that the department is using its tool to assess the 

quality of investigations. However, there is no evidence that this tool is 

being used by other agencies to assess the quality of investigations. 

Given current fiscal constraints, identifying the long-term costs is critical 

for decision-makers to compare and prioritize alternative proposals for 

completing the transformation of the security clearance process. Without 

information on longer-term funding requirements necessary to implement 

the reform effort, Congress lacks the visibility it needs to fully assess 

appropriations requirements. We most recently reported on two areas of 

opportunity for which the executive branch may be able to identify 

efficiencies: information technology and investigation and adjudication 

case management and processes.32

 

32 GAO, Background Investigations: The Office of Personnel Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Savings, GAO-12-197 (Washington, 

D.C.: Feb. 2012).
 

Page 18 GAO-12-815T 

In February 2012, we reported that information technology investments 

were one of OPM’s background investigations programs’ three main cost 

drivers.33 While these investments represent less than 10 percent of 

OPM’s fiscal year 2011 reported costs, they have increased more than 

682 percent over 6 years (in fiscal year 2011 dollars), from about $12 

million in fiscal year 2005 to over $91 million in fiscal year 2011.34

 

33

Moreover, we reported that OPM’s investigation process reverts its 

electronically-based investigation back into paper-based files. In 

November 2010, the Deputy Director for Management of the Office of 

Management and Budget testified that OPM now receives over 98 

percent of investigation applications electronically, yet we observed that it 

is continuing to use a paper-based investigation processing system and 

converts electronically submitted applications to paper. OPM officials 

stated that the paper-based process is required because a small portion 

of their customer agencies do not have electronic capabilities. 

Furthermore, OPM’s process has not been studied to identify efficiencies. 

As a result, OPM may be simultaneously investing in process 

streamlining technology while maintaining a less-efficient and duplicative 

paper-based process. We recommended that OPM take actions to 

identify process efficiencies, including its use of information technology to 

complete investigations, which could lead to cost savings within its 

background investigation processes. OPM concurred with our 

recommendation and commented that these actions also reinforce a 

Federal Investigative Services priority and that the agency will continue to 

map its process to achieve maximum process efficiencies and identify 

potential cost savings. In commenting on our final report, OPM stated in a 

May 25, 2012 letter to us that it is taking a number of actions that could 

lead to cost savings within its background investigation process. For 

example, OPM noted it is conducting a study of business processes 

identifying time savings and efficiencies for future Federal Investigative 

Services’ business processes which will conclude by December 2013.

GAO-12-197. 

34 For fiscal years 2005 to 2007, information technology costs were primarily for the 

operation and maintenance of OPM’s information technology for processing background 

investigations; after fiscal year 2008 and beyond, according to officials information 

technology costs increased as a result of Federal Investigative Services’ modernization 

effort, known as EPIC modernization. 

Information Technology Is a 

Primary Cost Driver in the 

Security Clearance Process 
 

Page 19 GAO-12-815T 

In February 2012, as part of our annual report on opportunities to reduce 

duplication, overlap and fragmentation, we reported that multiple 

agencies have invested in or are beginning to invest in potentially 

duplicative, electronic case management and adjudication systems 

despite governmentwide reform effort goals that agencies leverage 

existing technologies to reduce duplication and enhance reciprocity.35

Five other agencies are also developing or seeking funds to develop 

systems with similar capabilities.

According to DOD officials, DOD began the development of its Case 

Adjudication Tracking System in 2006 and, as of 2011, invested a total of 

$32 million to deploy the system. The system helped DOD achieve 

efficiencies with case management and an electronic adjudication module 

for secret level cases that did not contain issues, given the volume and 

types of adjudications performed. According to DOD officials, after it 

observed that the Case Adjudication Tracking System could easily be 

deployed to other agencies at a low cost, the department intended to 

share the technology with interested entities across the federal 

government. For example, the Department of Energy is piloting the 

electronic adjudication module of DOD’s system, and, according to DOD 

officials, the Social Security Administration is also considering adopting 

the system. In addition to DOD, Department of Justice officials said they 

began developing a similar system in 2007 at a cost of approximately $15 

million. In an effort to better manage the adjudication portion of the 

suitability and security clearance process, agencies have transitioned or 

plan to transition from a paper-based to an electronic adjudication casemanagement system. Although the investment in electronic casemanagement systems will likely lead to process efficiencies, agencies 

may not be leveraging adjudication technologies in place at other 

executive branch agencies to minimize duplication.

36

 

35 GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue, 

With multiple agencies developing 

individual case-management systems, these agencies may be at risk of 

duplicating efforts and may fail to realize cost savings. DOD officials 

suggested that opportunities may exist to leverage their casemanagement technology. However, DOD officials explained that agencies 

GAO-12-342SP (Washington, 

D.C.: Feb. 28, 2012).

36 One of these other agencies, the National Reconnaissance Office, is itself a component 

of DOD. 

Case Management and 

Adjudication Process 

Efficiencies Could 

Reduce Duplication
 

Page 20 GAO-12-815T 

would have to initially invest approximately $300,000 for implementation, 

plus any needed expenditures related to customizations, and long-term 

support and maintenance, which could require approximately $100,000 

per year.

Officials from OPM, one of the five other agencies developing or seeking 

funds to develop similar systems, explained that they plan to develop an 

electronic case-management system that is synchronized with its 

governmentwide background investigations system that would be 

available for their customer agencies to purchase. OPM released a 

request for information to evaluate the options for this system. DOD 

responded to OPM’s request for information by performing a comparative 

analysis of its own case-management system and said that it believes its 

system meets the needs set out in OPM’s request for information. 

However, OPM officials said that DOD’s system would cost too much 

money for smaller agencies to adopt, so OPM plans to continue exploring 

other options that would allow customer agencies access to their 

electronic case-management system without the need to make an 

expensive initial investment. Additionally, OPM officials said that their 

effort is intended to promote process efficiency by further integrating OPM 

with its more than 100 customer agencies. However, some OPM 

customer agencies, including DOD, which makes up approximately 75 

percent of OPM’s investigation workload, expressed concern that such a 

system would likely be redundant to currently available casemanagement technology. Further, any overhead costs related to the 

development of an OPM system would be incorporated into OPM’s 

operating costs, which could affect investigation prices.

The investment in electronic case-management systems aligns with the 

reform effort’s goal to automate information technology capabilities to 

improve the timeliness, efficiency, and quality of existing security 

clearance and suitability determinations systems. It also will likely lead to 

process efficiencies; however, agencies may be unclear how they might 

achieve cost savings through leveraging adjudication technologies in 

place at other executive branch agencies. In its March 2009 Enterprise 

Information Technology Strategy, the Joint Reform Team stated that 

agencies will leverage existing systems to reduce duplication and 

enhance reciprocity. Moreover, the Performance Accountability Council is 

positioned to promote coordination and standardization related to the 

suitability and security clearance process through issuing guidance to the 

agencies. The reform effort’s strategic framework includes cost savings in 

its mission statement, but this framework lacks specificity regarding how 

agencies might achieve costs savings. Without specific guidance, the 
 

Page 21 GAO-12-815T 

opportunities to minimize duplication and achieve cost savings may be 

lost. Therefore, in 2012 we recommended that OMB as the Chair of the 

Performance Accountability Council expand and specify reform-related 

guidance to help ensure that reform stakeholders identify opportunities for 

cost savings, such as preventing duplication in the development of 

electronic case management.OMB concurred with our recommendation.37

In February 2008 and in subsequent reports, we have noted the 

importance of having a sound requirements determination process for 

security clearances. Specifically, a sound requirements determination 

process may help ensure that workload and costs are not higher than 

necessary. Further, the Performance Accountability Council’s reformed 

security clearance process identified determining if a position requires a 

security clearance as the first step of the process. Specifically, the 

clearance process begins with establishing whether a position requires a 

clearance, and if so, at what level. The numbers of requests for initial and 

renewal clearances and the levels of such clearance requests are two 

ways to look at outcomes of requirements setting in the clearance 

process. As of October 2010, the Director of National Intelligence 

reported that 3.9 million38

In our prior work, DOD personnel, investigations contractors, and industry 

officials told us that the large number of requests for investigations could 

be attributed to many factors. For example, they ascribed the large 

number of requests to the heightened security concerns that resulted 

from the September 11, 2001, terrorist attacks. They also attributed the 

large number of investigations to an increase in the operations and 

deployments of military personnel and to the increasingly sensitive 

technology that military personnel, government employees, and 

contractors come in contact with as part of their jobs. Having a large 

number of cleared personnel can give the military services, agencies, and 

federal employees (military and civilian) and 

contractors hold security clearances. Moreover, OPM reported that its 

cost to conduct background investigations for much of the executive 

branch outside the intelligence agencies increased about 79 percent from 

about $602 million in fiscal year 2005 to over $1.1 billion in fiscal year 

2011.

 

37 GAO-12-197. 

38 These are the latest available data.

A Sound Requirements 

Process for Determining 

Required Clearances and 

Level of Clearances May 

Reduce Costs
 

Page 22 GAO-12-815T 

industry a great deal of flexibility when assigning personnel, but the 

investigative and adjudicative workloads that are required to provide 

clearances and that flexibility further tax the clearance process. 

A change in the higher level of clearances being requested also increases 

the investigative and adjudicative workloads. For example, top secret 

clearances must be renewed twice as often as secret clearances (i.e., 

every 5 years versus every 10 years). More specifically, the average 

investigative report for a top secret clearance takes about 10 times as 

many investigative staff hours as the average investigative report for a 

secret clearance. As a result, the investigative workload increases about 

20-fold. Additionally, the adjudicative workload increases about 4-fold, 

because in our previous work, DOD officials estimated that investigative 

reports for a top secret clearance took about twice as long to review as an 

investigative report for a secret clearance. Further, a top secret clearance 

needs to be renewed twice as often as the secret clearance. In August 

2006, OPM estimated that approximately 60 total staff hours are needed 

for each investigation for an initial top secret clearance and 6 total staff 

hours are needed for the investigation to support a secret or confidential 

clearance. The doubling of the frequency along with the increased effort 

to investigate and adjudicate each top secret reinvestigation adds costs 

and workload for the government.

For fiscal year 2012, OPM’s standard base prices are $4,005 for an 

investigation for an initial top secret clearance; $2,711 for an investigation 

to renew a top secret clearance, and either $228 or $260 for an 

investigation for a secret clearance.39

 

39 These billing rates are published in OPM’s annual Federal Investigative Notices. 

As we reported in February 2012, 

these base prices can increase if triggered by the circumstances of a 

case, such as issues related to credit or criminal history checks. For 

example, in 2011, DOD officials stated that the prices contained in OPM’s 

Federal Investigative Notices are not always reflective of the amount 

DOD actually pays for an investigation, as a result of these 

circumstances. Further, the cost of getting and maintaining a top secret 

clearance for 10 years is almost 30 times greater than the cost of getting 

and maintaining a secret clearance for the same period. For example, an 

individual getting a top secret clearance for the first time and keeping the 

clearance for 10 years would cost the government a total of $6,716 in 

current year dollars ($4,005 for the initial investigation and $2,711 for the 
 

Page 23 GAO-12-815T 

reinvestigation after the first 5 years). In contrast, an individual receiving a 

secret clearance and maintaining it for 10 years would result in a total 

cost to the government of $228 ($228 for the initial clearance that is good 

for 10 years). Requesting a clearance for a position in which it will not be 

needed, or in which a lower level clearance would be sufficient, will 

increase investigative workload and thereby costs unnecessarily. We are 

currently reviewing the process that the executive branch uses to 

determine whether a position requires a security clearance for the 

Ranking Member of the House Committee on Homeland Security, and the 

expected issuance date for this report is this summer.

In conclusion, Mr. Chairman, Mr. Johnson, and Members of the 

Subcommittee, as evidenced by our removal of the DOD’s security 

clearance program from our high-risk list, we are strongly encouraged by 

the progress that the Performance Accountability Council, and in 

particular, DOD, has made over the last few years. DOD has shown 

progress by implementing recommendations, improving overall 

timeliness, and taking steps to integrate quality into its processes. The 

progress that has been made with respect to the overall governmentwide 

reform efforts would not be possible without committed and sustained 

leadership of Congress and by the senior leaders involved in the 

Performance Accountability Council as well as their dedicated staff. 

Continued oversight and stewardship of the reform efforts is the 

cornerstone to sustaining momentum and making future progress. As the 

executive branch continues to move forward to enhance the suitability 

and security clearance reform, the actions to monitor quality and enhance 

efficiency will be key to enhance the progress made on timeliness to date.

Chairman Akaka, Ranking Member Johnson, and Members of the 

Subcommittee, this concludes my prepared statement, and I would be 

pleased to answer any questions that you may have. Thank you.

For further information on this testimony, please contact Brenda S. 

Farrell, Director, Defense Capabilities and Management, who may be 

reached at (202) 512-3604. Contact points for our Congressional 

Relations and Public Affairs offices may be found on the last page of this 

statement. GAO staff who made key contributions to this testimony 

include Lori Atkinson (Assistant Director), Grace Coleman, Sara Cradic, 

James Krustapentus, Gregory Marchand, Jillena Roberts, and Amie 

Steele.
Related GAO Products

Page 24 GAO-12-815T 

Background Investigations: Office of Personnel Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Savings. 

GAO-12-197. Washington, D.C.: February 28, 2012.

GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington, 

D.C.: February 17, 2011.

High-Risk Series: An Update. GAO-11-278. Washington, D.C.: February 

16, 2011.

Personnel Security Clearances: Overall Progress Has Been Made to 

Reform the Governmentwide Security Clearance Process. GAO-11-232T. 

Washington, D.C.: December 1, 2010.

Personnel Security Clearances: Progress Has Been Made to Improve 

Timeliness but Continued Oversight Is Needed to Sustain Momentum. 

GAO-11-65. Washington, D.C.: November 19, 2010.

DOD Personnel Clearances: Preliminary Observations on DOD’s 

Progress on Addressing Timeliness and Quality Issues. GAO-11-185T. 

Washington, D.C.: November 16, 2010.

Personnel Security Clearances: An Outcome-Focused Strategy and 

Comprehensive Reporting of Timeliness and Quality Would Provide 

Greater Visibility over the Clearance Process. GAO-10-117T. 

Washington, D.C.: October 1, 2009.

Personnel Security Clearances: Progress Has Been Made to Reduce 

Delays but Further Actions Are Needed to Enhance Quality and Sustain 

Reform Efforts. GAO-09-684T. Washington, D.C.: September 15, 2009.

Personnel Security Clearances: An Outcome-Focused Strategy Is 

Needed to Guide Implementation of the Reformed Clearance Process. 

GAO-09-488. Washington, D.C.: May 19, 2009.

DOD Personnel Clearances: Comprehensive Timeliness Reporting, 

Complete Clearance Documentation, and Quality Measures Are Needed 

to Further Improve the Clearance Process. GAO-09-400. Washington, 

D.C.: May 19, 2009.

High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January 

2009.

Related GAO Products
Related GAO Products

Page 25 GAO-12-815T 

Personnel Security Clearances: Preliminary Observations on Joint 

Reform Efforts to Improve the Governmentwide Clearance Eligibility 

Process. GAO-08-1050T. Washington, D.C.: July 30, 2008.

Personnel Clearances: Key Factors for Reforming the Security Clearance 

Process. GAO-08-776T. Washington, D.C.: May 22, 2008.

Employee Security: Implementation of Identification Cards and DOD’s 

Personnel Security Clearance Program Need Improvement. 

GAO-08-551T. Washington, D.C.: April 9, 2008.

Personnel Clearances: Key Factors to Consider in Efforts to Reform 

Security Clearance Processes. GAO-08-352T. Washington, D.C.: 

February 27, 2008.

DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts 

to Improve Clearance Processes for Industry Personnel. GAO-08-470T. 

Washington, D.C.: February 13, 2008.

DOD Personnel Clearances: Improved Annual Reporting Would Enable 

More Informed Congressional Oversight. GAO-08-350. Washington, D.C.: 

February 13, 2008.

DOD Personnel Clearances: Delays and Inadequate Documentation 

Found for Industry Personnel. GAO-07-842T. Washington, D.C.: May 17, 

2007.

High-Risk Series: An Update. GAO-07-310. Washington, D.C.: January 

2007.

DOD Personnel Clearances: Additional OMB Actions Are Needed to 

Improve the Security Clearance Process. GAO-06-1070. Washington, 

D.C.: September 28, 2006.

DOD Personnel Clearances: New Concerns Slow Processing of 

Clearances for Industry Personnel. GAO-06-748T. Washington, D.C.: 

May 17, 2006.

DOD Personnel Clearances: Funding Challenges and Other Impediments 

Slow Clearances for Industry Personnel. GAO-06-747T. Washington, 

D.C.: May 17, 2006.
Related GAO Products

Page 26 GAO-12-815T 

DOD Personnel Clearances: Government Plan Addresses Some Longstanding Problems with DOD’s Program, But Concerns Remain. 

GAO-06-233T. Washington, D.C.: November 9, 2005.

DOD Personnel Clearances: Some Progress Has Been Made but Hurdles 

Remain to Overcome the Challenges That Led to GAO’s High-Risk 

Designation. GAO-05-842T. Washington, D.C.: June 28, 2005.

High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January 

2005.

DOD Personnel Clearances: Preliminary Observations Related to 

Backlogs and Delays in Determining Security Clearance Eligibility for 

Industry Personnel. GAO-04-202T. Washington, D.C.: May 6, 2004.

(351749)
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