United States Government Accountability Office

GAO 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

DOD PERSONNEL 

CLEARANCES 

Delays and Inadequate 

Documentation Found for 

Industry Personnel 

Statement of Derek B. Stewart, Director 

Defense Capabilities and Management 

For Release on Delivery

Expected at 9:30 a.m. EDT

Thursday, May 17, 2007

 

GAO-07-842T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 17, 2007

DOD PERSONNEL CLEARANCES

Delays and Inadequate Documentation 

Highlights of GAO-07-842T, a testimony Found for Industry Personnel 

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 

Individuals working for the private 

industry are playing a larger role in 

national security work conducted 

by Department of Defense (DOD)

and other federal agencies. As of

May 2006, industry personnel held

about 34 percent of DODmaintained personnel security

clearances. The damage that the 

unauthorized disclosure of 

classified information can cause to 

national security necessitates the 

prompt and careful consideration

of who is granted a security 

clearance. Long-standing delays in

determining clearance eligibility

and other challenges led GAO to

designate the DOD personnel 

security clearance program as a

high-risk area in January 2005 and 

again in GAO’s January 2007

update of the high-risk areas. In

February 2005, DOD transferred its 

security clearance investigations 

functions to the Office of Personnel 

Management (OPM) and now 

obtains almost all of its clearance 

investigations from OPM. The 

Office of Management and Budget

(OMB) is responsible for effective

implementation of policy relating 

to determinations of eligibility for 

access to classified information.

This testimony addresses the 

timeliness of the process and 

completeness of documentation 

used to determine eligibility of 

industry personnel for top secret 

clearances in January and February 

2006. This statement relies 

primarily on GAO’s September 2006 

report (GAO-06-1070). 

GAO’s analysis of timeliness data showed that industry personnel contracted 

to work for the federal government waited more than 1 year on average to 

receive top secret clearances, longer than OMB- and OPM-produced 

statistics would suggest. GAO’s analysis of 2,259 cases in its population 

showed the process took an average of 446 days for initial clearances and 

545 days for clearance updates. While the government plan has a goal for the

application-submission phase of the process to take 14 days or less, it took 

an average of 111 days. In addition, GAO’s analyses showed that OPM used 

an average of 286 days to complete initial investigations for top secret 

clearances, well in excess of the 180-day goal specified in the plan that OMB 

and others developed for improving the clearance process. Finally, the 

average time for adjudication (determination of clearance eligibility) was 39 

days, compared to the 30-day requirement that began in December 2006. An 

inexperienced investigative workforce, not fully using technology, and other 

causes underlie these delays. Delays may increase costs for contracts and 

risks to national security. In addition, statistics that OMB and OPM report to 

Congress on the timeliness of the clearance process do not portray the full

length of time it takes many applicants to receive a clearance. GAO found 

several issues with the statistics, including limited information on

reinvestigations for clearance updating and failure to measure the total time 

it took to complete the various phases of the clearance process. Not fully 

accounting for all the time used in the process hinders congressional 

oversight of the efforts to address the delays. 

OPM provided incomplete investigative reports to DOD, and DOD personnel 

who review the reports to determine a person’s eligibility to hold a clearance 

(adjudicators) granted eligibility for industry personnel whose investigative 

reports contained unresolved issues, such as unexplained affluence and 

potential foreign influence. In its review of 50 investigative reports for initial 

clearances, GAO found that that almost all (47 of 50) cases were missing

documentation required by federal investigative standards. Moreover, 

federal standards indicate expansion of investigations may be necessary to 

resolve issues, but GAO found at least one unresolved issue in 27 of the 

reports. GAO also found that the DOD adjudicators granted top secret 

clearance eligibility for all 27 industry personnel whose investigative reports 

contained unresolved issues without requesting additional information or 

documenting in the adjudicative report that the information was missing. In 

its November 2005 assessment of the government plan for improving the

clearance process, GAO raised concerns about the limited attention devoted 

to assessing quality in the clearance process, but the plan has not been 

revised to address the shortcomings GAO identified. The use of incomplete 

investigations and adjudications in granting top secret clearance eligibility

increases the risk of unauthorized disclosure of classified information. Also,

it could negatively affect efforts to promote reciprocity (an agency’s 

acceptance of a clearance issued by another agency) being developed by an 

interagency working group headed by OMB’s Deputy Director. 

www.gao.gov/cgi-bin/getrpt?GAO-07-842T.

To view the full product, click on the link 

above. For more information, contact Derek 

B. Stewart on (202)512-5559 or

stewartd@gao.gov. 
Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss the Department of Defense’s 

(DOD) personnel security clearance program and problems that continue 

to negatively affect that program. We have testified on clearance-related 

issues in three prior hearings that this Subcommittee has held since 

January 2005 when we first placed DOD’s security clearance program on 

our list of high-risk government programs and operations.1 To facilitate an 

understanding of our recent findings on private industry personnel who 

applied for top secret clearances,2

 I would like to first provide some 

information about the clearance process and events that have occurred 

since we placed DOD’s program on our high-risk list. 

DOD is responsible for about 2.5 million security clearances issued to 

servicemembers, DOD civilians, and industry personnel who work on 

contracts for DOD and 23 other federal agencies. Individuals working for 

the private industry are playing an increasingly larger role in national 

security work conducted by DOD and other federal agencies as a result of

an increased awareness of threats to our national security stemming from

the September 11, 2001, terrorist attacks and increased efforts over the 

past decade to privatize federal jobs. As of May 2006, industry personnel 

held about 34 percent of DOD-maintained personnel security clearances. 

As with servicemembers and federal workers, industry personnel must 

obtain security clearances to gain access to classified information, which

is categorized into three levels: top secret, secret, and confidential. The 

level of classification denotes the degree of protection required for 

 1

 GAO, DOD Personnel Clearances: New Concerns Slow Processing of Clearances for

Industry Personnel, GAO-06-748T (Washington, D.C.: May 17, 2006); DOD Personnel 

Clearances: Government Plan Addresses Some Long-standing Problems with DOD’s 

Program, But Concerns Remain, GAO-06-233T (Washington, D.C.: Nov. 9, 2005); and 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). Since January 2005, we have provided the Subcommittee with 

additional information in our answers to sets of questions for the records: GAO, DOD 

Personnel Clearances: Questions and Answers for the Record Following the Second in a

Series of Hearings on Fixing the Security Clearance Process, GAO-06-693R (Washington,

D.C.: June 14, 2006), and Questions for the Record Related to DOD’s Personnel Security 

Clearance Program and the Government Plan for Improving the Clearance Process, 

GAO-06-323R (Washington, D.C.: Jan. 17, 2006). 

2

 GAO, DOD Personnel Clearances: Additional OMB Actions Are Needed to Improve the 

Security Clearance Process, GAO-06-1070 (Washington, D.C.: Sept. 28, 2006). 

Page 1 GAO-07-842T 
information and the amount of damage that unauthorized disclosure could 

reasonably be expected to cause to national defense or foreign relations.

For top secret information, the expected damage that unauthorized 

disclosure could reasonably be expected to cause is “exceptionally grave 

damage;” for secret information, it is “serious damage;” and for 

confidential information, it is “damage.”3

 

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

has overall responsibility for DOD clearances. Two offices are responsible 

for adjudication (eligibility determination to hold a clearance) for industry 

personnel. The Defense Industrial Security Clearance Office (DISCO) 

within OUSD(I) is responsible for adjudicating cases that contain only 

favorable information or minor issues regarding security concerns (e.g., 

some overseas travel by the individual). The Defense Office of Hearings 

and Appeals (DOHA) within the Defense Legal Agency is responsible for 

adjudicating cases that contain major security issues (e.g., an individual’s 

unexplained affluence or criminal history), which could result in the denial 

of clearance eligibility. 

Long-standing delays in determining clearance eligibility and other 

clearance challenges led us to designate DOD’s personnel security 

clearance program as a high-risk area in January 2005 and continue that 

designation in the updated list of high-risk areas that we published in 

2007.

4

 In February 2005, DOD transferred its security clearance 

investigations functions to the Office of Personnel Management (OPM) 

and now obtains almost all of its clearance investigations from OPM, 

which conducts about 90 percent of all federal clearance investigations. 

Other recent significant events affecting DOD’s clearance program have 

been the passage of the Intelligence Reform and Terrorism Prevention Act 

of 2004 (IRTPA)5

 and the June 2005 issuance of Executive Order No. 

13381,6

 Strengthening Processes Relating to Determining Eligibility for 

Access to Classified National Security Information. IRTPA included 

 3

 5 C.F.R. § 1312.4, Classification of National Security Information (2006). 

4

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

High-Risk Series: An Update, GAO-07-310 (Washington, D.C.: January 2007). 

5

 Pub. L. No. 108-458. 

6

 The White House, Exec. Order No. 13381, (June 27, 2005). On June 29, 2006, the executive 

order was extended until July 1, 2007. 

Page 2 GAO-07-842T 
milestones for reducing the time to complete clearances, general 

specifications for a database on security clearances, and requirements for 

reciprocity of clearances (the acceptance of a clearance and access 

granted by another department, agency, or military service). Executive 

Order No. 13381 assigned the Office of Management and Budget (OMB) 

responsibility for the effective implementation of a uniform, efficient, 

effective, timely, and reciprocal policy related to determinations of 

personnel eligibility for access to classified information. 

In June 2005, OMB’s Deputy Director of Management was designated as 

the OMB official responsible for improving the process by which the 

government determines eligibility for access to classified national security

information. One of OMB’s efforts to improve the security clearance

process involved taking a lead in preparing a November 2005 strategic plan 

to improve personnel security clearance processes governmentwide. In its 

February 2007 annual IRTPA-mandated report to Congress,7

 OMB noted 

additional improvements that had been made to the clearance process 

governmentwide. For example, OMB indicated that it had issued 

reciprocity standards, OPM had increased its investigative workforce to an 

estimated 9,367 total staff in efforts to reach an earlier goal of having 8,000

full-time staff, and agencies had dramatically increased the use of OPM’s 

Electronic Questionnaires for Investigations Processing (eQIP) system to 

reduce the time required to get a clearance by 2 to 3 weeks. The report 

also identified several challenges associated with accessing records 

repositories. 

In requesting our past work, you have expressed concern about the 

negative consequences of untimely, inadequate, or inconsistent 

investigations and adjudications. This testimony summarizes our earlier 

work that examined those issues and supplements other clearance-related 

reports that we have issued since originally placing DOD’s personnel 

security clearance program on our high-risk list (see the list of Related 

GAO Products at the end of this statement). It addresses two questions: 

(1) How timely are the processes used to determine whether industry 

personnel are eligible for top secret clearances? and (2) How complete is 

the documentation of the processes used to determine whether industry 

personnel are eligible for top secret clearances? 

 7

 Office of Management and Budget, Report of the Security Clearance Oversight Group

Consistent with Title III of the Intelligence Reform and Terrorism Prevention Act of 2004

(February 2007). 

Page 3 GAO-07-842T 
This statement relies primarily on GAO’s September 2006 report.8

 In 

conducting our prior work on these two key questions, we reviewed laws, 

executive orders, policies, and reports related to the timeliness and 

completeness of security clearance investigations and adjudications for 

industry personnel as well as servicemembers and civilian government 

employees. Those sources provided the criteria used for assessing 

timeliness and documentation completeness, and identified causes for and 

effects from delayed clearances and incomplete investigative and 

adjudicative reports. Additional insights about causes of and effects from 

delayed clearances and incomplete investigative and adjudicative reports

were obtained from interviews with and documentary evidence from 

personnel associated with a variety of government offices: OUSD(I), 

DISCO, DOHA, other DOD adjudication facilities that make clearance 

determinations for servicemembers and DOD civilians; DOD’s Defense 

Personnel Security Research Center; the Defense Security Service’s 

Training Academy that offers adjudicator training; and OPM. 

Nongovernmental organizations supplying information on conditions, 

causes, and effects included officials representing two of OPM’s 

investigations contractors and technology associations whose member 

organizations require clearances for their industry personnel. We also 

reviewed the February 2007 annual IRPTA-mandated report to Congress 

by the Security Clearance Oversight Group. For the timeliness question, 

our analyses of conditions included a review of computerized data 

abstracted from DOD’s Joint Personnel Adjudication System (JPAS) and 

statistical reports on timeliness that OPM produced for DOD. The abstract

was for the population of 1,685 industry personnel granted initial top 

secret clearances and 574 industry personnel granted top secret clearance 

updates by DISCO during January and February 2006. The clearance 

investigations for those 2,259 industry personnel were started at various 

times prior to the adjudications. While we found problems with the 

accuracy of some of the JPAS data, we determined they were sufficiently 

reliable for the purposes of our September 2006 report. DOD and OPM 

also supplied timeliness statistics for other periods, levels of clearances, 

types of personnel, and agencies to provide us with a broader context with 

which to interpret the timeliness statistics that we computed from the 

JPAS database abstract. We addressed the completeness question with a 

multiple-step process. We (1) randomly selected 50 cases from the 

previously described population of 1,685 initially cleared industry 

personnel, (2) obtained paper files of the 50 investigative and adjudicative 

 8 GAO-06-1070. 

Page 4 GAO-07-842T 
reports, (3) created a data collection instrument using federal investigative 

standards and adjudicative guidelines to standardize our data gathering, 

(4) sought experts’ comments to refine our instrument and process, (5) 

coded data from the paper files, (6) had a second team member 

independently verify the information that another team member had 

coded, and (7) computed statistics to indicate the numbers of investigative 

and adjudicative reports with various types of missing documentation. In 

addition, two team members attended OPM’s basic special agent training 

course to obtain an understanding of the investigative requirements as 

promulgated by OPM, and two other members of our team took about 40 

hours of online adjudication training. We performed our original work 

from September 2005 through August 2006 in accordance with generally 

accepted government auditing standards. 

At the time we issued our report in September 2006, our analysis of 

timeliness data showed that industry personnel contracted to work for the 

federal government waited more than 1 year on average to receive top 

secret security clearances and that timeliness statistics reported to 

Congress by OMB and OPM do not convey the full magnitude of the 

delays. Industry personnel granted eligibility for top secret clearance from 

DISCO from January to February 2006 waited an average of 446 days for 

their initial clearances and 545 days for their clearance updates. Delays 

were found in each phase of the clearance process that we examined. 

First, the application submission phase took an average of 111 days, nearly 

100 days more than the government’s goal. Inaccurate data that the 

employee provided in the application, multiple reviews of the application, 

and manual entry of some application forms are some of the causes for the 

extended application-submission phase. Second, the investigation phase 

took an average of 286 days for initial top secret clearances, well in excess 

of the 180-day goal. In addition, it took 419 days for top secret clearance 

updates (no goal is given for clearance update investigations). Factors 

contributing to the slowness of completing the investigation phase include 

an inexperienced investigative workforce and problems accessing 

national, state, and local records. Finally, it took DISCO adjudicators an 

average of 39 days to grant initial clearance eligibility to the industry 

personnel in our study population, compared to IRTPA’s December 2006 

requirement that 80 percent of all adjudication cases be completed in 30 

days. Regardless of when in the process the delays occur, the outcome is 

the same—the government may incur additional costs from new industry 

employees being unable to begin work promptly and increased risks to 

national security because previously cleared industry employees are likely 

to continue working with critical information while it is determined 

Summary 

Page 5 GAO-07-842T 
whether they should still be eligible to hold a clearance. Moreover, the 

statistics that OMB and OPM report to Congress on the timeliness of the 

clearance process do not portray the full length of time it takes many 

applicants to receive clearances. We found several issues with the 

statistics, including limited information on reinvestigations for clearance

updating and failure to measure the total time it took to complete the 

various phases of the clearance process. Statistics that underrepresent the 

time that it takes for investigations to be completed prevent Congress 

from having a full understanding of the government’s efforts to decrease 

delays in the clearance process and determining if legislative actions are 

necessary. 

In addition to delays in the clearance process, we found that that OPM 

provided incomplete investigative reports to DISCO adjudicators, which 

they used to determine top secret clearance eligibility. In our review of 50 

initial investigations for top secret clearances randomly sampled from the 

population used in our timeliness analyses, we found that almost all (47 of

50) of the sampled investigative reports were missing documentation 

required by federal investigative standards. The missing data were of two 

general types: (1) the absence of documentation showing that an 

investigator had gathered all required information and (2) the absence of

information to help resolve issues (such as conflicting information on 

indebtedness) that were raised in other parts of the investigative report. 

The federal standards indicate that investigations may be expanded as 

necessary to resolve issues. However, we found a total of 36 unresolved 

issues in 27 of the investigative reports. The most common unresolved 

issues pertained to financial consideration, foreign influence, and personal 

conduct. OPM officials suggested that the need to rapidly increase the size 

of the investigative workforce and prior quality control procedures that 

have since been replaced were some of the causes for the delivery of 

incomplete investigative reports to DISCO. Our review also found that 

DISCO adjudicators granted top secret eligibility to all 27 industry 

personnel whose investigative reports contained unresolved issues. In our 

November 2005 assessment of the government plan for improving the 

clearance process, we raised concerns about the limited attention devoted 

to assessing quality in the clearance process, but the plan has not been 

revised to address the shortcoming we identified.9

 The use of incomplete

investigations and adjudications in the granting of top secret clearance 

eligibility increases the risk of unauthorized disclosure of classified 

 9 GAO-06-233T. 

Page 6 GAO-07-842T 
information. Also, it could negatively affect the government’s efforts to 

move toward greater reciprocity. To improve the timeliness and 

completeness of investigations and adjudications, our report contained 

several recommendations to OMB. 

To ensure the trustworthiness, reliability, and character of personnel in 

positions with access to classified information, DOD relies on a 

multiphased personnel security clearance process.10 Figure 1 shows six 

phases that could be involved in determining whether to grant an actual or 

a potential job incumbent a clearance. The three phases shown in gray are 

those that are most transparent to individuals requesting an initial 

clearance, and they are the three phases that were the primary focus of the 

findings in this testimony. 

Background 

 10 DOD Directive 5200.2, DOD Personnel Security Program (Apr. 9, 1999), establishes

policy and procedures for granting DOD military, civilian, and industry personnel access to 

classified information. Additionally, DOD Regulation 5200.2-R, DOD Personnel Security

Program (January 1987), establishes DOD personnel security policies and procedures; sets

forth standards, criteria, and guidelines upon which personnel security determinations

shall be based; prescribes the types and scopes of personnel security investigations 

required; details the evaluation and adverse action procedures by which personnel security 

determinations shall be made; and assigns overall program management responsibilities. 

The policies and procedures for granting industry personnel security clearances and

adjudicative procedural guidance for appealing cases if an unfavorable clearance decision 

is reached also are contained in DOD Directive 5220.6, Defense Industrial Personnel 

Security Clearance Review Program (Apr. 20, 1999). 

Page 7 GAO-07-842T 
Figure 1: Six Phases in the Personnel Security Clearance Process 

At the time of our September 2006 report, our independent analysis of 

timeliness data showed that industry personnel contracted to work for the 

federal government waited more than 1 year on average to receive top 

secret security clearances, and government statistics did not portray the 

full length of time it takes many applicants to obtain clearances. We found 

delays in all phases of the clearance process that we examined, and 

government statistics did not account for the full extent of the delays. 

Delays in the clearance process may cost money and pose threats to 

national security (see table 1). 

Determining Top 

Secret Clearances for 

Industry Personnel 

Averaged More Than a 

Year, and Government 

Statistics Did Not 

Portray All Delays 

Page 8 GAO-07-842T 
Table 1: Time Required to Grant Eligibility for a Top Secret Clearance to Industry Personnel—Cases Adjudicated in January 

and February 2006

Phases of security clearance process a

Total clearance process 2. Application submission 3. Investigation 4. Adjudication

Clearance 

type

Initial 

Update 

All 

Average 

daysb 

446 

545 

471 

 Average

 days

 111

 81

 103

 Average

 days

 286

 419

 320

Average

days

39

36

38

• Subject signs and dates the 

application. 

Example tasks and 

decisions required in each 

phase. 

• Facility security officer 

checks application 

materials for completeness 

and accuracy, and forwards 

them to DISCO after any 

applicable changes. 

• DISCO adjudicator reviews 

materials for completeness 

and other concerns, and 

returns deficient materials 

to the facility security officer 

for further work. 

• If the application materials 

are approved, DISCO

adjudicators determine 

whether the applicant is 

eligible for an interim 

clearance. 

• DISCO then forwards the 

completed application to 

OPM to begin the 

investigation. 

• OPM reviews the 

application for 

completeness and other 

concerns and returns 

deficient materials to 

DISCO for further work. 

• If application is not 

submitted via eQIP, OPM 

key enters information for 

the application into its 

investigative database. 

• OPM schedules the 

investigation, assigning 

the investigation to its 

federal investigative 

workforce or one of its 

investigations 

contractors. 

• Investigators gather 

information on the 

individual in order to 

produce an investigative 

report. 

• OPM’s PIPS database 

obtains a variety of 

electronic information 

that is available via 

government databases. 

• Once the investigative 

work has been 

completed, OPM checks 

the investigative report 

for completeness before 

sending the report to an 

adjudication facility. 

• OPM prints a 

paper copy of 

the 

investigative 

report. 

• OPM ships 

the paper 

copy of the 

report to the 

adjudication 

facility if the 

agency chose 

that format or 

cannot get it 

electronically.c

• DISCO 

adjudicator 

reviews the 

information in 

the 

investigative 

report. 

• DISCO 

adjudicator 

determines if 

industry 

employee is 

eligible for a 

clearance. d

Source: GAO analysis of OPM and DOD information. 

Legend: PIPS = OPM’s Personnel Investigations Processing System. 

a

The phases referred to here are based on those in figure 1. 

b

The average days for the phases do not sum to the average days for the total clearance process 

because the number of applicable cases varies for each calculation.

Page 9 GAO-07-842T 
c

According to OPM, the requesting agency has the option to request that the investigation be 

delivered through PIPS, eliminating the mail time, for all completed investigations that do not contain 

hard-copy third-party information. 

d

Additional time may be needed in this phase if DISCO adjudicators identify major security issues in 

the investigative report. Such cases may be submitted to DOHA for the clearance eligibility

determination.

Delays in Determining 

Eligibility Are Caused by 

Many Factors 

As table 1 shows, industry personnel granted eligibility for top secret 

clearances from DISCO from January to February 2006 waited an average

of 446 days for their initial clearances or 545 days for their clearance

updates. DOD may, however, have issued interim clearances to some of 

these industry personnel, which might have allowed them to begin work 

before they received their final clearances. IRTPA requires that beginning

in December 2006, 80 percent of clearances be completed in an average of

120 days. Delays were found in each phase of the clearance process that 

we examined: 

• Application submission. The application-submission phase of the 

clearance process took an average of 111 days for the initial clearances 

that DISCO adjudicated in January and February 2006 (see table 1). The

starting point for our measurement of this phase was the date when the 

application was submitted by the facility security officer. Our end point for 

this phase was the date that OPM scheduled the investigation into its 

Personnel Investigations Processing System. We used this starting date 

because the government can begin to incur an economic cost if an 

industry employee cannot begin work on a classified contract because of

delays in obtaining a security clearance and this end date because OPM 

currently uses this date as its start point for the next phase in the 

clearance process. The government plan for improving the clearance 

process noted that “investigation submission” (i.e., application 

submission) is to be completed within an average of 14 calendar days or 

less. Therefore, the 111 days taken for the application-submission phase 

was nearly 100 more days on average than allocated. Several factors 

contributed to the amount of time we observed in the applicationsubmission phase, including rejecting applications multiple times because 

of inaccurate information (as reported in an April 2006 DOD Office of 

Inspector General report); multiple completeness reviews—the corporate 

facility security officer, DISCO adjudicators, and OPM staff; and manually 

entering data from paper applications if eQIP was not used. 

• Investigation. Investigations for the initial top secret clearances of 

industry personnel adjudicated in January and February 2006 took an 

average of 286 days, compared to OMB’s 180-day goal for that period (see

table 1). During the same period, investigations for top secret clearance

Page 10 GAO-07-842T 
updates or “reinvestigations” took an average of 419 days, almost one and 

a half times as long as the initial investigations (no goal is given for 

clearance updates or reinvestigations). The mandated February 2007 OMB 

report to Congress noted that “Reinvestigation timeliness has not been 

addressed, because the improvement effort focused on individuals for 

whom initial security clearances are required to perform work.” Our 

September 2006 report identified many factors that inhibited the speed 

with which OPM can deliver investigative reports to DISCO and other 

adjudication facilities. Those causes included backlogged cases that 

prevent the prompt start of work on new cases, the relative inexperience

of the investigative workforce, slowness in developing the capability to 

investigate overseas leads, and difficulty obtaining access to data in 

governmental records. 

• Adjudication. DISCO adjudicators took an average of 39 days to grant 

initial clearance eligibility to the industry personnel in our population (see 

table 1). The measurement of this phase for our analysis used the same 

start and stop dates that OPM uses in its reports, starting on the date that 

OPM closed the report and continuing through the date that DISCO 

adjudicators decided clearance eligibility. IRTPA requires that at least 80 

percent of the adjudications made from December 2006 through December 

2009 be completed within an average of 30 days. As of June 2006, DISCO 

reported that it had adjudicated 82 percent of its initial top secret 

clearances within 30 days. 

Delays in any phase of the clearance process cost money and threaten 

national security. Delays in completing initial security clearances may 

have a negative economic impact on the costs of performing classified 

work within or for the U.S. government. For example, in a May 2006 

congressional hearing, a representative of a technology association 

testified that retaining qualified personnel resulted in salary premiums as 

high as 25 percent for current clearance holders.

11 Delays in completing 

clearance updates can have serious but different negative consequences 

than those stemming from delays in completing initial clearance-eligibility 

determinations. In 1999, the Joint Security Commission reported that 

delays in initiating reinvestigations for clearance updates create risks to 

national security because the longer individuals hold clearances the more 

likely they are to be working with critical information. 

 11 Doug Wagoner, statement for the record, hearing before the Committee on Government 

Reform, U.S. House of Representatives (May 17, 2006). 

Page 11 GAO-07-842T 
The statistics that OMB and OPM have provided to Congress on the 

timeliness of the personnel security clearance process do not convey the 

full magnitude of the investigation-related delays facing the government. 

While our September 2006 report noted additional problems with the 

transparency of the timeliness statistics, I will review our concerns about 

five such issues: (1) limited information on reinvestigations for clearance

updating, (2) not counting the total number of days to finish the 

application-submission phase, (3) shifting some investigation-related days 

to the adjudication phase or not counting them, (4) not counting the total

number of days to complete closed pending cases, and (5) not counting 

the total number of days to complete investigations sent back for rework. 

Limited information on reinvestigations for clearance updating. In its 

mandated February 2007 report to Congress, OMB acknowledged that 

“reinvestigation timeliness has not been addressed,” but the findings from 

our population of industry personnel (obtained using DOD’s, instead of 

OPM’s, database to assess timeliness) indicated that clearance update 

reinvestigations took about one and a half times as long as the initial 

investigations. The absence of timeliness information on clearance update 

reinvestigations does not provide all stakeholders—Congress, agencies, 

contractors attempting to fulfill their contracts, and employees awaiting 

their clearances—with a complete picture of clearance delays. We have 

noted in the past that focusing on completing initial clearance 

investigations could negatively affect the completion of clearance update 

reinvestigations and thereby increase the risk of unauthorized disclosure 

of classified information. 

Not counting all days to finish the application-submission phase. OMB’s 

February 2007 report noted that its statistics do not include “the time to 

hand-off applications to the investigative agency.” The gray section of the 

application-submission phase in table 1 shows some of the activities that 

were not counted when we examined January and February 2006 

clearance documentation for industry personnel. These activities could be 

included in timeliness measurements depending on the interpretation of 

what constitutes “receipt of the application for a security clearance by an 

authorized investigative agency”—IRTPA’s start date for the investigation 

phase. 

Shifting some investigation-related days to the adjudication phase or 

not counting them. In our September 2006 report, we raised concerns 

about how the time to complete the adjudication phase was measured. 

The activities in the gray section of the adjudication phase in table 1 show

that the government’s procedures for measuring the time required for the 

OMB’s and OPM’s 

Timeliness Reporting Does 

Not Convey Full 

Magnitude of Delays 

Page 12 GAO-07-842T 
adjudication phase include tasks that occur before adjudicators actually 

receive the investigative reports from OPM. More recently, OMB’s 

February 2007 report to Congress noted that its timeliness statistics do not 

include “the time to ... hand-off investigation files to the adjudicative 

agency” and estimated this handling and mailing time at up to 15 days. 

Not counting all days for closed pending cases. OPM’s May 2006

testimony before Congress did not indicate whether the timeliness 

statistics on complete investigations included a type of incomplete 

investigation that OPM sometimes treats as being complete. In our 

February 2004 report, we noted that OPM’s issuance of “closed pending” 

investigations—investigative reports sent to adjudication facilities without 

one or more types of source data required by the federal investigative 

standards—causes ambiguity in defining and accurately estimating the 

backlog of overdue investigations. In our February 2004 report, we also 

noted that cases that are closed pending the provision of additional 

information should continue to be tracked separately in the investigation 

phase of the clearance process. According to OPM, from February 20, 

2005, through July 1, 2006, the number of initial top secret clearance 

investigative reports that were closed pending the provision of additional 

information increased from 14,841 to 18,849, a 27 percent increase. DISCO 

officials and representatives from some other DOD adjudication facilities 

have indicated that they will not adjudicate closed pending cases since 

critical information is missing. OPM, however, has stated that other 

federal agencies review the investigative reports from closed pending 

cases and may determine that they have enough information for 

adjudication. Combining partially completed investigations with fully 

completed investigations overstates how quickly OPM is supplying 

adjudication facilities with the information they require to make their 

clearance-eligibility determinations. 

Not counting all days when inadequate investigations are returned.

OMB’s February 2007 report stated that its statistics do not include the

time incurred to “return the files to the investigative agency for further 

information.” OPM’s procedure is to restart the measurement of 

investigation time for the 1 to 2 percent of investigative reports that are 

sent back for quality control reasons, which does not hold OPM fully 

accountable for total investigative time when deficient products are 

delivered to its customers. In fact, restarting the time measurement for 

reworked investigations could positively affect OPM’s statistics if the 

reworked sections of the investigation take less time than did the earlier 

effort to complete the large portion of the investigative report. 

Page 13 GAO-07-842T 
IRTPA establishes timeliness requirements for the security clearance

process. Specifically, it states that “each authorized adjudicative agency

shall make a determination on at least 80 percent of all applications for a 

personnel security clearance pursuant to this section within an average of

120 days after the date of receipt of the application for a security clearance 

by an authorized investigative agency.” IRTPA did not identify situations 

that could be excluded from mandated timeliness assessments. Without 

fully accounting for the total time needed to complete the clearance 

process, Congress will not be able to accurately determine whether 

agencies have met IRTPA-mandated requirements or determine if 

legislative actions are necessary. 

OPM provided incomplete investigative reports to DOD adjudicators, 

which they used to determine top secret clearance eligibility. Almost all 

(47 of 50) of the sampled investigative reports we reviewed were 

incomplete based on requirements in the federal investigative standards. 

In addition, DISCO adjudicators granted clearance eligibility without 

requesting additional information for any of the incomplete investigative 

reports and did not document that they considered some adjudicative 

guidelines when adverse information was present in some reports. 

Granting clearances based on incomplete investigative reports increases 

risks to national security. In addition, use of incomplete investigative 

reports and not fully documenting adjudicative considerations may 

undermine the government’s efforts to increase the acceptance of security

clearances granted by other federal agencies. 

In our review of 50 initial investigations randomly sampled from the 

population used in our timeliness analyses, we found that 47 of 50 of the 

investigative reports were missing documentation required by the federal 

investigative standards. The missing data were of two general types: (1) 

the absence of documentation showing that an investigator gathered the 

prescribed information in each of the applicable 13 investigative areas and 

included requisite forms in the investigative report and (2) the absence of 

information to help resolve issues (such as conflicting information on 

indebtedness) that were raised in other parts of the investigative report. 

The requirements for gathering these types of information were identified

in federal investigative standards published about a decade ago. 

At least half of the 50 reports did not contain the required documentation 

in 3 investigative areas: residence (33 of 50), employment (32), and 

education (27). In addition, many investigative reports contained multiple 

OPM Delivered 

Incomplete 

Investigative Reports, 

and DISCOAdjudicated Cases 

Did Not Document All 

ClearanceDetermination 

Considerations

Almost All of the Sampled 

Investigative Reports Were 

Incomplete 

Page 14 GAO-07-842T 
deficiencies within each of these areas. For example, multiple deficiencies 

might be present in the residence area because investigators did not 

document a rental record check and an interview with a neighborhood 

reference. Moreover, 44 of the 50 investigative reports had 2 to 6 

investigative areas out of a total of 13 areas with at least one piece of 

missing documentation. 

We also found a total of 36 unresolved issues in 27 of the investigative 

reports. The three investigative areas with the most unresolved issues 

were financial consideration (11 of 50 cases), foreign influence (11), and 

personal conduct (7). Federal standards indicate that investigations may 

be expanded as necessary to resolve issues. According to OPM, (1) issue 

resolution is a standard part of all initial investigations and periodic 

reinvestigations for top secret clearances and (2) all issues developed 

during the course of an investigation should be fully resolved in the final

investigative report provided to DOD. 

One investigative report we examined serves as an example of the types of

documentation issues we found during our review. During the course of 

this particular investigation, the subject reported having extramarital 

affairs; however, there was no documentation to show that these affairs 

had been investigated further. Also, the subject’s clearance application 

indicated cohabitation with an individual with whom the subject had 

previously had a romantic relationship, but there was no documentation 

that record checks were performed on the cohabitant. Moreover, 

information in the investigative report indicated that the subject had 

defaulted on a loan with a balance of several thousand dollars; however, 

no other documentation suggested that this issue was explored further. 

When we reviewed this and other deficient investigative reports with OPM 

Quality Management officials, they agreed that the investigators should 

have included documentation to resolve the issues. 

While we found that the interview narratives in some of the 50 OPM 

investigative reports were limited in content, we did not identify them as 

being deficient for the purposes of our analysis because such an 

evaluation would have required a subjective assessment that we were not 

willing to make. For example, in our assessment of the presence or 

absence of documentation, we found a 35-word narrative for a subject 

interview of a naturalized citizen from an Asian country. It stated only that 

the subject did not have any foreign contacts in his birth country and that 

he spent his time with family and participated in sports. Nevertheless, 

others with more adjudicative expertise voiced concern about the issue of

documentation adequacy. Top officials representing DOD’s adjudication 

Page 15 GAO-07-842T 
facilities with whom we consulted were in agreement that OPM-provided 

investigative summaries had been inadequate.

When we reviewed our findings in meetings with the Associate Director of 

OPM’s investigations unit and her quality management officials they cited

the inexperience of the rapidly expanded investigative workforce and 

variations in training provided to federal and contractor investigative staff 

as possible causes for the incomplete investigative reports we reviewed. 

Later, in official agency comments to our September 2006 report, OPM’s 

Director indicated that some of the problems that we reported were the 

result of transferred staff and cases when OPM accepted DOD 

investigative functions and personnel. However, OPM had had 2 years to 

prepare for the transfer between the announced transfer agreement in 

February 2003 and its occurrence in February 2005. Furthermore, the staff 

and cases were under OPM control until the investigative reports were 

subsequently transferred to OPM for adjudication in January or February 

of 2006. In addition, 47 of the 50 investigative reports that we reviewed 

were missing documentation even though OPM had quality control 

procedures for reviewing the reports before they were sent to DOD. 

In our November 2005 testimony evaluating the government plan for 

improving the personnel security clearance process, we stated that 

developers of the plan may wish to consider adding other indicators of the 

quality of investigations. During our review, we asked the Associate 

Director of OPM’s Investigations Unit if OMB and OPM had made changes 

to the government plan to address quality measurement and other 

shortcomings we identified. OPM’s Associate Director said that the plan

had not been modified to address our concerns but that implementation of 

the plan was continuing.

Our review found that DISCO adjudicators granted top secret clearance 

eligibility for all 47 of the 50 industry personnel whose investigative 

reports did not have full documentation. In making clearance-eligibility 

determinations, the federal guidelines require adjudicators to consider (1) 

guidelines covering 13 specific areas, such as foreign influence and 

financial considerations; (2) adverse conditions or conduct that could 

raise security concerns and factors that might mitigate (alleviate) the 

condition for each guideline; and (3) general factors related to the whole 

person. According to a DISCO official, DISCO and other DOD adjudicators 

are to record information relevant to each of their eligibility 

determinations in JPAS. They do this by selecting applicable guidelines 

DISCO Adjudicators 

Granted Top Secret 

Clearance Eligibility for 

Cases with Missing

Information 

Page 16 GAO-07-842T 
and mitigating factors from prelisted responses and may type up to 3,000 

characters of additional information. 

The adjudicators granted eligibility for the 27 industry personnel whose 

investigative reports (discussed in the prior section) contained unresolved 

issues without requesting additional information or documenting in the 

adjudicative report that the information was missing. The following is an 

example of an unresolved foreign influence issue, which was not 

documented in the adjudicative report, although DISCO officials agreed 

that additional information should have been obtained to resolve the issue 

before the individual was granted a top secret clearance. A state-level

record check on an industry employee indicated that the subject was part 

owner of a foreign-owned corporation. Although the DISCO adjudicator 

applied the foreign influence guideline for the subject’s foreign travel and 

mitigated that foreign influence issue, there was no documentation in the 

adjudicative report to acknowledge or mitigate the foreign-owned 

business. When we asked why adjudicators did not provide the required 

documentation in JPAS, the DISCO officials as well as adjudication 

trainers said that adjudicators review the investigative reports for 

sufficient documentation to resolve issues and make judgment calls about 

the amount of risk associated with each case by weighing a variety of past

and present, favorable and unfavorable information about the person to 

reach an eligibility determination. 

Seventeen of the 50 adjudicative reports were missing documentation on a 

total of 22 guidelines for which issues were present in the investigative 

reports. The missing guideline documentation was for foreign influence 

(11), financial considerations (5), alcohol consumption (2), personal 

conduct issues (2), drug involvement (1), and foreign influence (1). DISCO 

officials stated that procedural changes associated with JPAS 

implementation contributed to the missing documentation. DISCO began 

using JPAS in February 2003, and it became the official system for all of 

DOD in February 2005. Before February 2005, DISCO adjudicators were 

not required to document the consideration of a guideline issue unless the 

adverse information could disqualify an individual from being granted a 

clearance eligibility. After JPAS implementation, DISCO adjudicators were 

trained to document in JPAS their rationale for the clearance 

determination and any adverse information from the investigative report,

regardless of whether an adjudicative guideline issue could disqualify an

individual from obtaining a clearance. The administrators also attributed 

the missing guideline documentation to a few adjudicators attempting to 

produce more adjudication determinations. 

Page 17 GAO-07-842T 
Decisions to grant clearances based on incomplete investigations increase

risks to national security because individuals can gain access to classified 

information without being vetted against the full federal standards and 

guidelines. Furthermore, if adjudication facilities send the incomplete 

investigations back to OPM for more work, the adjudication facilities must 

use adjudicator time to review cases more than once and then use 

additional time to document problems with the incomplete investigative 

reports. 

Incomplete investigations and adjudications undermine the government’s 

efforts to move toward greater clearance and access reciprocity. An 

interagency working group, the Security Clearance Oversight Steering 

Committee, noted that agencies are reluctant to be accountable for poor 

quality investigations, adjudications conducted by other agencies or 

organizations, or both. To achieve fuller reciprocity, clearance-granting 

agencies need to have confidence in the quality of the clearance process.

Without full documentation of investigative actions, information obtained,

and adjudicative decisions, agencies could continue to require duplicative 

investigations and adjudications. 

Incomplete timeliness data limit the visibility of stakeholders and decision 

makers in their efforts to address long-standing delays in the personnel 

security clearance process. For example, not accounting for all of the time

used when personnel submit an application multiple times before it is 

accepted limits the government’s ability to (1) accurately monitor the time 

required for each step in the application-submission phase and (2) identify

positive steps that facility security officers, DISCO adjudicators, OPM 

investigative staff, and other stakeholders can take to speed the process. 

The timeliness-related concerns identified in my testimony show the 

fragmented approach that the government has taken to addressing 

clearance problems. When I testified before this Subcommittee in 

November 2005, we were optimistic that the government plan for 

improving the clearance process prepared under the direction of OMB’s 

Deputy Director for Management would be a living document that would 

provide the strategic vision for correcting long-standing problems in the 

personnel security clearance process. However, nearly 2 years after first 

commenting on the plan, we have not been provided with a revised plan 

that lays out how the government intends to address the shortcomings that 

we identified in the plan during our November 2005 testimony. Continued

failure to address the shortcomings we have cited could significantly limit

the positive impact that the government has made in other portions of the 

Delivery and Use of 

Incomplete Investigations 

Increase Risks to National 

Security and Reciprocity 

Concluding 

Observations 

Page 18 GAO-07-842T 
clearance process through improvements such as hiring more 

investigators and promoting reciprocity. 

While eliminating delays in the clearance process is an important goal, the

government cannot afford to achieve that goal by providing investigative 

and adjudicative reports that are incomplete in the key areas required by 

federal investigative standards and adjudicative guidelines. Also, the 

incomplete investigative and adjudicative reports could suggest to some 

security managers that there is at least some evidence to support agencies’

concerns about the risks that may come from accepting the clearances 

issued by other federal agencies, and thereby negatively affect OMB’s 

efforts toward achieving greater reciprocity. Further, as we pointed out in

November 2005, the almost total absence of quality metrics in the 

governmentwide plan for improving the clearance process hinders 

Congress’s oversight of these important issues. Finally, the missing 

documentation could have longer-term negative effects, such as requiring 

future investigators and adjudicators to devote time to obtaining the 

documentation missing from current reviews when it is time to update the 

clearances currently being issued. 

Mr. Chairman and Members of the Subcommittee, this concludes my 

prepared statement. I would be happy to answer any questions you may 

have at this time. 

For further information regarding this testimony please contact me at 

(202)512-5559 or stewartd@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this statement. Individuals who made key contributions to this 

testimony are Jack E. Edwards, Assistant Director; Kurt A. Burgeson; 

Nicolaas C. Cornelisse; Alissa H. Czyz; Ronald La Due Lake; Beverly C. 

Schladt; and Karen D. Thornton.

Contact and 

Acknowledgments 

Page 19 GAO-07-842T 
Related GAO Products 

DOD Personnel Clearances: Questions and Answers for the Record 

Following the Second in a Series of Hearings on Fixing the Security 

Clearance Process. GAO-06-693R. Washington, D.C.: June 14, 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. 

GAO’s High-Risk Program. GAO-06-497T. Washington, D.C.: March 15, 

2006. 

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

Program and the Government Plan for Improving the Clearance 

Process. GAO-06-323R. Washington, D.C.: January 17, 2006. 

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. 

Defense Management: Better Review Needed of Program Protection 

Issues Associated with Manufacturing Presidential Helicopters. GAO-06-

71SU. Washington, D.C.: November 4, 2005. 

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

Program. GAO-05-988R. Washington, D.C.: August 19, 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.

DOD’s High-Risk Areas: Successful Business Transformation Requires 

Sound Strategic Planning and Sustained Leadership. GAO-05-520T. 

Washington, D.C.: April 13, 2005. 

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

2005. 

(351048) 
This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER