SECURITY 

CLEARANCES

Agencies Need Clearly 

Defined Policy for 

Determining Civilian 

Position Requirements 

Report to the Ranking Member, 

Committee on Homeland Security, House 

of Representatives

July 2012

GAO-12-800

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-800, a report to the 

Ranking Member, Committee on Homeland 

Security, House of Representatives

July 2012

SECURITY CLEARANCES

Agencies Need Clearly Defined Policy for 

Determining Civilian Position Requirements 

Why GAO Did This Study

Security clearances allow personnel 

access to classified information that, 

through unauthorized disclosure, can, 

in some cases, cause exceptionally 

grave damage to U.S. national 

security. In 2011, the DNI reported that 

over 4.8 million federal government 

and contractor employees held or were

eligible for a clearance. To safeguard 

classified data and manage costs, 

agencies need an effective process to

determine whether civilian positions 

require a clearance. GAO was asked 

to examine the extent to which the

executive branch has established 

policies and procedures for agencies to 

use when (1) first determining if federal 

civilian positions require a security 

clearance and (2) reviewing and 

revising or validating existing federal 

civilian position security clearance 

requirements. GAO reviewed executive 

orders and the Code of Federal 

Regulations and met with officials from

ODNI and OPM because of their

Directors’ assigned roles as Security 

and Suitability executive agents, as 

well as DHS and DOD based on the 

volume of clearances they process. 

What GAO Recommends

GAO recommends that the DNI issue 

clearly defined policy for agencies to 

follow when determining if federal 

civilian positions require a security 

clearance, and that the DNI and 

Director of OPM collaborate to revise 

the existing position designation tool.

GAO further recommends that the DNI 

issue guidance to require agencies to

periodically review and revise or 

validate the designation of their 

existing federal civilian positions. ODNI

and OPM concurred, although OPM 

raised concerns with which GAO 

disagrees and addresses in the report. 

What GAO Found

The Director of National Intelligence (DNI), as Security Executive Agent, has not 

provided agencies clearly defined policy and procedures to consistently

determine if a position requires a security clearance. Executive Order 13467 

assigns DNI responsibility for, among other things, developing uniform and 

consistent policies to determine eligibility for access to classified information, and 

gives the DNI authority to issue guidance to agency heads to ensure uniformity in

processes relating to those determinations. In the absence of this guidance, 

agencies are using an Office of Personnel Management (OPM) tool that OPM 

designed to determine the sensitivity and risk levels of civilian positions which, in 

turn, inform the type of investigation needed. OPM audits, however, found 

inconsistency in these position designations, and some agencies described 

problems in implementing OPM’s tool. In an April 2012 audit, OPM reviewed the 

sensitivity levels of 39 positions in an agency within the Department of Defense 

(DOD) and reached different conclusions than the agency for 26 of them. 

Problems exist, in part, because OPM and the Office of the Director of National 

Intelligence (ODNI) did not collaborate on the development of the position 

designation tool, and because their roles for suitability—consideration of 

character and conduct for federal employment—and security clearance reform

are still evolving. Without guidance from the DNI, and without collaboration 

between the DNI and OPM in future revisions to the tool, executive branch 

agencies will continue to risk making security clearance determinations that are 

inconsistent or at improper levels. 

The DNI also has not established guidance to require agencies to review and 

revise or validate existing federal civilian position designations. Executive Order 

12968 says each agency shall request or grant clearance determinations, subject 

to certain exceptions, based on a demonstrated need for access, and keep to a 

minimum the number of employees that it determines are eligible for access to 

classified information. The order also states that access to classified information 

shall be terminated when an employee no longer has a need for access, and 

prohibits agencies from requesting or approving eligibility in excess of actual 

requirements for access. During this review of Department of Homeland Security 

(DHS) and DOD components, GAO found that agency officials were aware of the 

need to keep the number of security clearances to a minimum, but were not 

always required to conduct periodic reviews and validations of the security 

clearance needs of existing positions. Overdesignating positions results in 

significant cost implications, given that the fiscal year 2012 base price for a top 

secret clearance investigation conducted by OPM is $4,005, while the base price 

of a secret clearance is $260. Conversely, underdesignating positions could lead 

to security risks. GAO found that the agencies follow varying practices because 

the DNI has not established guidance that requires executive branch agencies to 

review and revise or validate position designations on a recurring basis. Without 

such a requirement, executive branch agencies may be hiring and budgeting for 

initial and periodic security clearance investigations using position descriptions 

and security clearance requirements that no longer reflect national security 

needs. Further, since reviews are not done consistently, DHS and DOD and 

other executive branch agencies cannot have assurances that they are keeping 

the number of positions that require security clearances to a minimum.

View GAO-12-800. For more information, 

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

farrellb@gao.gov
Page i GAO-12-800 Security Clearances 

Letter 1 

Background 4

The Executive Branch Has Not Issued Clearly Defined Policy 

Guidance for Determining When a Federal Civilian Position 

Needs a Security Clearance 10

The Executive Branch Does Not Have a Consistent Process for 

Reviewing and Validating Existing Security Clearance 

Requirements for Civilian Positions 16

Conclusions 20

Recommendations for Executive Action 20

Agency Comments and Our Evaluation 21

Appendix I Scope and Methodology 26

Appendix II Position Designation Guidance 30

Appendix III Personnel Security Clearance Process 35

Appendix IV Comments from the Office of the Director of National Intelligence 37

Appendix V Comments from the Office of Personnel Management 40

Appendix VI Comments from the Department of Homeland Security 45

Appendix VII GAO Contact and Staff Acknowledgments 46

Related GAO Products 47

Contents
Page ii GAO-12-800 Security Clearances 

Tables

Table 1: Executive Branch Agencies and Offices Interviewed 27

Table 2: Summary of Selected DHS and DOD Position Designation 

Guidance 30

Figures

Figure 1: DHS and DOD Security Clearance Determination Process 

for Federal Civilian Positions 7

Figure 2: Seven-Step Process for Suitability and Security Clearance 

Reform 9

Abbreviations

Office of the Director of National Intelligence (ODNI)

Department of Defense (DOD) 

Department of Homeland Security (DHS)

Office of Personnel Management (OPM)

Single Scope Background Investigation (SSBI)

Access National Agency Check and Inquiries (ANACI)

Moderate Risk Background Investigation (MBI)

Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA)

Director of National Intelligence (DNI)

Office of Management and Budget (OMB)

Sensitive Compartmented Information (SCI)

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Page 1 GAO-12-800 Security Clearances 

United States Government Accountability Office

Washington, DC 20548

July 12, 2012

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

Dear Mr. Thompson:

Personnel security clearances allow government 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 September 11, 2001, attacks spurred an increase in the 

number of positions that require a security clearance across the executive 

branch. In tracking the number of people that have a security clearance, 

the Office of the Director of National Intelligence (ODNI) reported that as 

of October 1, 2011, over 4.8 million federal government civilian workforce, 

military personnel, and contractor employees held or were eligible to 

hold1 a security clearance.2, 3

 

1

In certain cases, individuals are investigated and deemed eligible to hold a security 

clearance. These individuals do not have access to classified information. However, 

access can be granted when the duties of their position require it. 

This large number of personnel holding 

clearances coupled with risks to national security underscore the need for 

executive branch agencies to have a standard process to determine 

which positions require a security clearance. Additionally, a standard 

process is also needed to effectively manage costs, since agencies 

spend significant amounts annually on national security and other 

background investigations. For example, two of the agencies that grant 

the most security clearances, the Department of Defense (DOD) and the 

Department of Homeland Security (DHS) spent $787 million and at least 

2

The ODNI report notes that there could be some duplicative entries. However, we did not 

verify the accuracy of this number. 

3

According to the Office of Personnel Management (OPM) fiscal year 2010 data, the 

federal government workforce consisted of over 4.4 million federal civilian employees and 

military personnel. This figure does not include contractors. 

 
 

Page 2 GAO-12-800 Security Clearances 

$57 million,4 respectively, on suitability5

In our previous work,

and security clearance 

background investigations in fiscal year 2011.

6 we identified the need for a sound requirements 

determination process to be considered in executive branch efforts to 

reform the security clearance process. Determining the requirements of a 

federal position includes assessing both the risk and sensitivity level 

associated with a position, which includes consideration of whether that 

position requires access to classified information. Specifically, we noted 

that the executive branch could address whether the numbers and levels 

of security clearances are appropriate and examine existing policies and 

practices to see if they need to be updated or otherwise modified. 

Developing a sound requirements process is important because requests 

for clearances for positions that do not need a clearance or need a lower 

level of clearance increase investigative workload and costs 

unnecessarily. For example, we reported in 2008 that changing the 

clearance needed for a position from secret to top secret increases the 

investigative workload for that one position about 20-fold. That is, top 

secret clearances must be performed twice as often as secret clearances 

(every 5 years versus 10 years) and require 10 times as many 

investigative staff hours (about 60 versus 6). More recently, our 2012 

report found that the executive branch spent over $1 billion on 

background investigations for suitability and security clearances in fiscal 

year 2011.7

 

4

For DHS, this $57 million represents only the amount that DHS paid OPM for suitability 

and security background investigations in 2010. In addition, DHS conducts some of its 

own background investigations.

Further, the Office of Personnel Management (OPM)—the 

federal investigative service provider for the majority of the executive 

branch—experienced an almost 79 percent increase in its reported costs 

5

Determinations of suitability for government employment in positions in the competitive 

service, certain positions in the excepted service, and for career appointment in the Senior 

Executive Service include consideration of aspects of individuals’ character or conduct 

that may have an impact on the integrity or efficiency of their service. 

6

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

GAO-08-776T (Washington, D.C.: May 22, 2008) and Personnel Clearances: Key Factors 

to Consider in Efforts to Reform Security Clearance Processes, GAO-08-352T

(Washington, D.C.: Feb. 27, 2008). 

7

GAO, Background Investigations: Office of Personnel Management Needs to Improve 

Transparency of Its Pricing and Seek Cost Savings, GAO-12-197 (Washington, D.C.: Feb. 

28, 2012). 
 

Page 3 GAO-12-800 Security Clearances 

to conduct background investigations between fiscal years 2005 and 

2011. Specifically, OPM’s reported costs increased from about $602 

million in fiscal year 2005 to almost $1.1 billion in fiscal year 2011 (in 

fiscal year 2011 dollars).

You asked us to evaluate federal government policies and practices for 

identifying positions that require security clearances, and analyze whether 

a uniform, consistent, and effective security clearance requirements 

determination process is in place. In response to this request, we 

examined the extent to which the executive branch has established 

(1) policies and procedures for agencies to use when first determining 

whether federal civilian positions require a security clearance and 

(2) policies and procedures for agencies to review and revise or validate 

existing federal civilian position security clearance requirements.

Specifically, the scope of our work focused on the security clearance 

requirements of federal civilian positions from selected components within 

DHS and DOD, due to the volume of clearances that these two agencies 

process. Within DHS, selected components included the U.S. Coast 

Guard, U.S. Immigration and Customs Enforcement, and the 

Transportation Security Administration. Within DOD, selected 

components included the headquarters-level elements of the 

Departments of the Army, the Navy, the Air Force, and Washington 

Headquarters Services, which provides human capital support for several 

nonservice DOD agencies and activities. For our first objective, to 

examine the extent to which the executive branch has established 

policies and procedures for agencies to use when first determining 

whether federal civilian positions require a security clearance, we 

interviewed key officials from the above-mentioned federal departments 

and selected components, as well as OPM and ODNI. In addition, we 

reviewed relevant Executive Orders including 10450, 12968, and 13467,8

 

8

Executive Order No. 10450, Security Requirements for Government Employment (Apr. 

27, 1953 as amended), Executive Order No. 12968, Access to Classified Information

(Aug. 2, 1995 as amended), Executive 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 4 GAO-12-800 Security Clearances 

Joint Reform Team9 reports, and part 732 of Title 5 of the Code of 

Federal Regulations.10 We also obtained and analyzed personnel security 

clearance policies within DHS, DOD, and the selected components within 

these departments. Further, we obtained and analyzed OPM’s position 

designation tool because agencies we spoke with use the tool in the 

position designation process. For our second objective, to examine the 

extent to which the executive branch has policies and procedures for 

agencies to review and revise or validate existing federal civilian position 

security clearance requirements, we held meetings with knowledgeable 

officials from DHS, DOD, OPM, and ODNI. In addition, we reviewed part 

732 of Title 5 of the Code of Federal Regulations. We also analyzed 

DHS’s and DOD’s personnel security policies, and the applicable policies 

of selected components within these departments. We conducted this 

performance audit from July 2011 through July 2012 in accordance with 

generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on 

our objectives. A more thorough description of our scope and 

methodology is provided in appendix I.

Security clearances are required for access to certain national security 

information, which is classified at one of three levels: top secret, secret, or 

confidential. The level of classification denotes the degree of protection 

required for information and the amount of damage that unauthorized 

disclosure could reasonably cause to national security.

 

9

In 2007, DOD and ODNI formed the Joint Security and Suitability Reform Team, known 

as the Joint Reform Team, to execute joint reform efforts to achieve timeliness goals and 

improve the processes related to granting security clearances and determining suitability 

for government employment. Agencies included in this government-wide reform effort 

include the Office of Management and Budget, OPM, ODNI, and DOD’s Under Secretary 

of Defense (Intelligence). 

10Part 732 of Title 5 of the Code of Federal Regulations addresses national security 

positions within the federal government including the competitive service, the Senior 

Executive Service, and certain excepted service positions. 

Background 
 

Page 5 GAO-12-800 Security Clearances 

Executive Order 10450, which was originally issued in 1953, makes the 

heads of departments or agencies responsible for establishing and 

maintaining effective programs for ensuring that civilian employment and 

retention is clearly consistent with the interests of the national security. 

Agency heads are also responsible for designating positions within their 

respective agencies as sensitive if the occupant of that position could, by 

virtue of the nature of the position, bring about a material adverse effect 

on national security. In addition, Executive Order 12968, issued in 1995, 

is relevant to position designation because the order also makes the 

heads of agencies—including executive branch agencies and the military 

departments—responsible for establishing and maintaining an effective 

program to ensure that access to classified information by each employee 

is clearly consistent with the interests of national security. This order also 

states that, subject to certain exceptions, eligibility for access to classified 

information shall only be requested and granted on the basis of a 

demonstrated, foreseeable need for access. Further, part 732 of Title 5 of 

the Code of Federal Regulations provides requirements and procedures 

for the designation of national security positions,11

In addition, part 732 states that most federal government positions that 

could bring about, by virtue of the nature of the position, a material 

adverse effect on national security must be designated as a sensitive 

position and require a sensitivity level designation. The sensitivity level 

designation determines the type of background investigation required, 

with positions designated at a greater sensitivity level requiring a more 

extensive background investigation. Part 732 establishes three sensitivity 

levels—special-sensitive, critical-sensitive, and noncritical-sensitive—

which are described in figure 1. According to OPM, positions that an 

agency designates as special-sensitive and critical-sensitive require a 

background investigation that typically results in a top secret clearance. 

Noncritical-sensitive positions typically require an investigation that 

supports a secret or confidential clearance. OPM also defines nonsensitive positions that do not have a national security element, but still 

which include positions 

that (1) involve activities of the government that are concerned with the 

protection of the nation from foreign aggression or espionage, and 

(2) require regular use of or access to classified national security 

information.

 

11Those requirements in Part 732 apply to national security positions in the competitive 

service, Senior Executive Service positions filled by career appointment within the 

executive branch, and certain excepted service positions.

Relevant Orders and 

Regulations 
 

Page 6 GAO-12-800 Security Clearances 

require a designation of risk for suitability purposes. That risk level 

determines the type of investigation required for those positions. Those 

investigations include aspects of an individual’s character or conduct that 

may have an effect on the integrity or efficiency of his or her service.

The personnel security clearance process begins when a human 

resources or security professional determines a position’s level of 

sensitivity, which includes consideration of whether or not a position 

requires access to classified information and, if required, the level of 

access. DHS and DOD follow a general process for determining whether 

a federal civilian position requires access to classified information, which 

informs whether a position requires a security clearance. This process is 

described in figure 1 below and is based on our review of the 

corresponding guidance and testimonial evidence gathered during 

interviews with DHS and DOD officials. In addition, a more thorough 

description of DHS and DOD component-level policies appears in 

appendix II.

Position Designation 

Process
 

Page 7 GAO-12-800 Security Clearances 

Figure 1: DHS and DOD Security Clearance Determination Process for Federal Civilian Positions

a

A Single Scope Background Investigation (SSBI) is conducted so that an individual can obtain a top 

secret clearance (including Sensitive Compartmented Information and Q access) and includes a 

review of the locations where an individual has lived, attended school, and worked. In addition, an 

SSBI includes interviews with four references who have social knowledge of the subject, interviews 

with former spouses, and a financial record check.
 

Page 8 GAO-12-800 Security Clearances 

b

An Access National Agency Check and Inquiries (ANACI) is used for the initial investigation for 

federal employees at the confidential and secret access levels. It consists of employment checks, 

education checks, residence checks, reference checks, and law enforcement agency checks, as well 

as a National Agency Check, which includes data from military records and the Federal Bureau of 

Investigation’s investigative index.

C

The personnel security clearance process is further described in appendix 

III.

A Moderate Risk Background Investigation (MBI) includes an ANACI and provides issue-triggered 

enhanced subject interviews with issue resolution. DHS uses the MBI for non-critical sensitive 

positions when a position is first designated as high, moderate, or low risk. 

The increased demand for personnel with security clearances following 

the events of September 11, 2001, led GAO and others to identify delays 

and incomplete documentation in the security clearance process. In light 

of these concerns, Congress passed the Intelligence Reform and 

Terrorism Prevention Act of 2004 (IRTPA),12

In June 2008, Executive Order 13467 established a Suitability and 

Security Clearance Performance Accountability Council, commonly 

known as the Performance Accountability Council, to be the governmentwide governance structure responsible for driving implementation and 

overseeing security and suitability reform efforts.

which set objectives and 

established requirements for improving the clearance process, including 

improving the timeliness of the clearance process, achieving interagency 

reciprocity, establishing an integrated database to track investigative and 

adjudicative information, and evaluating available technology for 

investigations and adjudications.

13 Further, the order 

appointed the Deputy Director for Management at the Office of 

Management and Budget as the chair of the council and designated the 

Director of National Intelligence (DNI) as the Security Executive Agent 

and the Director of OPM as the Suitability Executive Agent. Since its 

establishment, the Performance Accountability Council has released 

several reports14

 

12Pub. L. No. 108-458 (2004) (relevant sections codified at 50 U.S.C. § 435b). 

through the Joint Reform Team—its working-level 

13Executive Order 13467 calls for investigations of suitability and security to be aligned 

using consistent standards, to the extent practicable.

14Joint Security and Suitability Reform Team, Security and Suitability Process Reform 

(Washington, D.C.: April 2008 and updated December 2008); and Performance 

Accountability Council, Security and Suitability Process Reform: Strategic Framework 

(Washington, D.C.: February 2010).

Personnel Security 

Clearance and Suitability 

Reforms 
 

Page 9 GAO-12-800 Security Clearances 

predecessor that continues to focus on the reform effort—detailing 

reform-related plans, including a February 2010 strategic framework that 

established goals, performance measures, roles and responsibilities, and 

proposed metrics for determining the quality of security clearance 

investigations and adjudications. Those reports contained a reform plan 

that outlined a new seven-step process for end-to-end suitability and 

security clearance reform, see figure 2 below. According to ODNI officials, 

the first step—to “validate need,”—focuses on ensuring that the sensitivity 

level of positions is designated appropriately on the basis of mission 

needs, among other things.

Figure 2: Seven-Step Process for Suitability and Security Clearance Reform

Separate from, but related to, security clearances are determinations of 

suitability that the executive branch uses to ensure individuals are 

suitable, based on character and conduct, for federal employment in their 

agency or position.15

 

15See part 731of Title 5 of the Code of Federal Regulations. 

Suitability requirements sometimes overlap with 

national security requirements. For example, the Department of Justice 

checks suitability to ensure that applicants for jobs with the Drug 

Enforcement Agency have never used illegal drugs. In addition, Health 

and Human Services checks the suitability of applicants for jobs working 

with children. Similarly, the Intelligence Community requires polygraph 

evaluations, among other things, to determine suitability for most 

intelligence positions. OPM was involved in many aspects of the 

suitability investigation process under Part 731 of Title 5 of the Code of 
 

Page 10 GAO-12-800 Security Clearances 

Federal Regulations, prior to the issuance of Executive Order 13467 and, 

as the Suitability Executive Agent, the Director continues to be 

responsible for developing and implementing uniform and consistent 

policies and procedures to ensure the effective, efficient, and timely 

completion of background investigations and adjudications relating to 

determinations of suitability.

In contrast, the DNI was assigned a new role. Executive Order 13467 

states that the DNI, as the Security Executive Agent, is responsible for, 

among other things, developing uniform and consistent policies and 

procedures to ensure the effective, efficient, and timely completion of 

background investigations and adjudications relating to determinations of

eligibility for access to classified information or eligibility to hold a 

sensitive position. In addition to these responsibilities, the Executive 

Order also provides the DNI the authority to issue guidelines and 

instructions to the heads of agencies to ensure appropriate uniformity, 

centralization, efficiency, effectiveness, and timeliness in processes 

relating to determinations by agencies of eligibility for access to classified 

information or eligibility to hold a sensitive position. The order also states 

that the Performance Accountability Council is responsible for ensuring 

that the Executive Agents align their respective processes. Finally, the 

order states that agency heads should implement any policy or procedure 

developed by either the Performance Accountability Council or Executive 

Agents under the order.

The DNI, in the capacity as Security Executive Agent responsible for 

developing uniform and consistent policies related to the security 

clearance process, has expressed intent to issue guidance relating to 

national security positions. However, the DNI has not provided agencies 

with clearly defined policy through regulation or other guidance to help 

ensure that executive branch agencies use appropriate and consistent 

criteria when determining if positions require a security clearance. 

Instead, executive branch agencies are using a position designation tool 

developed by OPM. This tool is designed to determine the sensitivity level 

of civilian positions which, in turn, informs the type of background 

investigation needed if a clearance is warranted. The DNI, however, did 

not have a role in its development even though the two Executive Agents 

are to align their respective processes. As a result, agency officials we 

met expressed mixed views on the effectiveness of the tool for national 

security positions.

The Executive Branch 

Has Not Issued 

Clearly Defined Policy 

Guidance for 

Determining When a 

Federal Civilian 

Position Needs a 

Security Clearance 
 

Page 11 GAO-12-800 Security Clearances 

According to Executive Order 13467, issued in June 2008, the DNI, as 

the Security Executive Agent, is responsible for developing uniform and 

consistent policies and procedures for determinations of eligibility for 

access to classified information or to hold a sensitive position. Further, 

the executive order states that agency heads shall assist the 

Performance Accountability Council and Executive Agents in carrying out 

any function under the order, which includes implementing any policies or 

procedures developed pursuant to the order. Although agency heads 

retain the flexibility to make determinations regarding which positions in 

their agency require a security clearance, the DNI is well positioned, by 

virtue of its role as the Security Executive Agent, to provide guidance to 

help align the process from agency to agency. The DNI, however, has not 

provided agencies with clearly defined policy or instructions.

To assist with position designation, the Director of OPM—the Executive 

Agent for Suitability—has developed a process that includes a position 

designation system and corresponding automated tool to guide agencies 

in determining the proper sensitivity level for the majority of federal 

positions.16

 

16According to OPM’s Federal Investigations Notice No. 10-06 Position Designation 

Requirements (Aug. 11, 2010), the tool is recommended for all agencies requesting OPM 

investigations and required for all positions in the competitive service, positions in the 

excepted service where the incumbent can be noncompetitively converted to the 

competitive service, and career appointments in the Senior Executive Service.

This tool—namely, the Position Designation of National 

Security and Public Trust Positions—enables a user to evaluate a 

position’s national security and suitability requirements so as to determine 

a position’s sensitivity and risk levels, which in turn dictate the type of 

background investigation that will be required for the individual who will 

occupy that position. In most agencies outside the Intelligence 

Community, OPM conducts the background investigations for both 

suitability and security clearance purposes. The tool does not directly 

determine whether a position requires a clearance, but rather helps 

determine the sensitivity level of the position. The determination to grant a 

clearance is based on whether a position requires access to classified 

information or other relevant factors, and, if access is required, the 

responsible official will designate the position to require a clearance.

The DNI Has a Role to 

Guide Agencies in 

Designating Positions for 

Security Clearances, But 

Has Not Provided Agencies 

with Clearly Defined 

Policy Guidance

OPM Has Developed a Tool 

to Help Agencies 

Determine the Proper 

Sensitivity Level for Most 

Federal Positions, but the 

Tool Lacks Input from the 

DNI
 

Page 12 GAO-12-800 Security Clearances 

OPM developed the position designation system and automated tool for 

multiple reasons. First, OPM determined through a 2007 initiative17

OPM first introduced the automated tool in November 2008, and issued 

an update of the tool in 2010. In August 2010, OPM issued guidance 

(1) recommending all agencies that request OPM background 

investigations use the tool and (2) requiring agencies to use the tool for all 

positions in the competitive service, positions in the excepted service 

where the incumbent can be noncompetitively converted to the 

competitive service, and career appointments in the Senior Executive 

Service. Both DHS and DOD components use the tool. A DHS instruction 

requires personnel to designate all DHS positions by using OPM’s 

position sensitivity designation guidance, which is the basis of the tool.

that 

its existing regulations and guidance for position designation were 

complex and difficult to apply, resulting in inconsistent designations. As a 

result of a recommendation from the initiative, OPM created a simplified 

position designation process in 2008. Additionally, OPM officials noted 

that the tool is to support the goals of the security and suitability reform 

efforts, which require proper designation of national security and 

suitability positions.

18

In addition, DOD issued guidance in September 201119

This lack of coordination for revising the tool exists, in part, because the 

execution of the roles and relationships between the Director of OPM and 

requiring its 

personnel to use OPM’s tool to determine the proper position sensitivity 

designation for new or vacant positions, including the establishment and 

reclassification of positions. ODNI officials told us that they believe OPM’s 

tool is useful for determining a position’s sensitivity level. However, 

despite the DNI’s responsibility for policy related to ensuring uniformity in 

the security clearance process, ODNI officials noted that the DNI did not 

have input into recent revisions of OPM’s position designation tool.

 

17The Hadley-Springer commission was an initiative between OPM and the Assistant to 

the President for National Security Affairs that focused on simplifying the federal 

government investigative and adjudicative procedures to improve security requirements to 

determine eligibility for access to classified information, among other things. 

18DHS Management Instruction 121-01-007, Department of Homeland Security Personnel 

Suitability and Security Program (June 2009).

19DOD Washington Headquarters Services, Implementation of the Position Designation 

Automated Tool, (Sept. 27, 2011).
 

Page 13 GAO-12-800 Security Clearances 

the DNI as Executive Agents are still evolving, although Executive Order 

13467 defines responsibilities for each Executive Agent. Accordingly, we 

found that the Director of OPM and the DNI have not fully collaborated in 

executing their respective roles in the process for determining position 

designations. For example, OPM has had long-standing responsibility for 

establishing standards with respect to suitability for most federal 

government positions. Accordingly, the sections of the tool to be used for 

evaluating a position’s suitability risk level are significantly more detailed 

than the sections designed to aid in designating the national security 

sensitivity level of the position. While most of OPM’s position designation 

system, which is the basis of the tool, is devoted to suitability issues, only 

two pages are devoted to national security issues, despite the reference 

to national security in its title. Moreover, OPM did not seek to collaborate 

with the DNI when updating the tool in 2010. Similarly, in 2010, OPM 

initiated revisions to the part of the Code of Federal Regulations that 

pertain to national security positions.20

During our review, human capital and security officials from DHS and 

DOD and the selected components affirmed that they were using the 

existing tool to determine the sensitivity level required by a position. 

However, in the absence of clearly defined policy from the DNI and the 

lack of collaborative input into the tool’s design, officials explained that 

they sometimes had difficulty in using the tool to designate the sensitivity 

level of national security positions.

According to OPM and ODNI 

officials, the revision is expected to clarify the standards for designating 

whether federal positions are national security sensitive, which will help 

agencies more accurately assess the sensitivity of a position. The 

sensitivity level includes consideration of whether a position is eligible for 

access to classified information and the level of access. Further, the 

revision is currently expected to update the definition of national security 

positions to include positions that could have a material impact on 

national security, but might not clearly fall within the current definition in 

part 732 of Title 5 of the Code of Federal Regulations. For example, such 

positions include those with duties that involve the protection of borders, 

ports, and critical infrastructure, as well as those with responsibilities 

related to public safety, law enforcement, and the protection of 

government information systems.

 

20See 75 Federal Register 77783 (Dec. 14, 2010). The comment period for that draft 

revision ended on February 14, 2011. No final or interim rule has been issued, and no 

executive branch agency is currently subject to the proposed revision.
 

Page 14 GAO-12-800 Security Clearances 

OPM regularly conducts audits of its executive branch customer agency 

personnel security and suitability programs, which include a review of 

position designation to assess the agencies’ alignment with OPM’s 

position designation guidance. In the audit reports we obtained, OPM 

found examples of inconsistency between agency position designation 

and OPM guidance, both before and after the implementation of OPM’s 

tool. For instance, prior to the implementation of the tool, in a 2006 audit 

of an executive branch agency, OPM found that its sensitivity 

designations differed from the agency’s designation in 13 of 23 positions. 

Specifically, OPM concluded that 11 positions were underdesignated, 

1 position was overdesignated, and 1 position was adjusted. More 

recently, after the implementation of the tool, in an April 2012 audit of a 

DOD agency, OPM assessed the sensitivity levels of 39 positions, and 

OPM’s designations differed from the agency’s designations in 26 of 

those positions. In the April 2012 report, the DOD agency agreed with 

OPM’s recommendations related to position designation, and the audit 

report confirmed that the agency had submitted evidence of corrective 

action in response to the position designation recommendations. OPM 

provided us with the results of 10 audits that it had conducted between 

2005 and 2012, and 9 of those audit reports reflected inconsistencies 

between OPM position designation guidance and determinations of 

position sensitivity conducted by the agency. OPM officials noted, 

however, that they do not have the authority to direct agencies to make 

different designations because Executive Order 10450 provides agency 

heads with the ultimate responsibility for designating which positions are 

sensitive positions.

As of May 2012, the Naval Audit Service is currently finalizing its own 

internal audit on its top secret requirements determination process for 

civilian positions. While the results were not complete at the time of our 

review, officials explained to us that they began this audit to validate their 

top secret requirements and ensure that they have effective internal 

controls over their designation process.21

DHS and DOD officials expressed varying opinions regarding the tool. For 

instance, some of the officials we met raised concerns regarding the 

 

 

21ODNI conducted a separate position designation audit in response to the Intelligence 

Authorization Act for Fiscal Year 2010, Pub. L. No. 111-259 (2010). In that report, ODNI 

found that the processes the executive branch agencies followed differed somewhat 

depending whether the position was civilian, military, or contractor. 

Audits Show Problems with 

Position Designations

Agency Officials Had Mixed 

Views of Designation Tool
 

Page 15 GAO-12-800 Security Clearances 

guidance provided through the tool and expressed that they had difficulty 

implementing it. Specifically, officials from DHS’s U.S. Immigration and 

Customs Enforcement stated that the use of the tool occasionally resulted 

in inconsistency, such as over- or underdesignating a position, and 

expressed a need for additional clear, easily interpreted guidance on 

designating national security positions. DOD officials stated that they 

have had difficulty implementing the tool because it focuses more on 

suitability than security, and the national security aspects of DOD’s 

positions are of more concern to them than the suitability aspects. 

Further, an official from DOD’s Office of the Under Secretary of Defense 

for Personnel and Readiness stated that the tool and DOD policy do not 

always align and that the tool does not cover the requirements for some 

DOD positions. For example, DOD’s implementing guidance on using the 

tool states that terms differ between DOD’s personnel security policy and 

the tool, and the tool might suggest different position sensitivity levels 

than DOD policy requires. Also, officials from the Air Force Personnel 

Security Office told us that they had challenges using the tool to classify 

civilian positions, including difficulty in linking the tool with Air Force 

practices for position designation. Moreover, an Air Force official stated a 

concern that the definition for national security positions is broadly written 

and could be considered to include all federal positions. Further, 

individuals responsible for making position designation determinations 

can easily reach different conclusions. For instance, officials from DHS’s 

U.S. Immigration and Customs Enforcement stated that the tool is not 

necessarily intuitive and users of the tool need to understand its nuances 

in order to avoid overdesignating a position. Conversely, officials from the 

U.S. Coast Guard stated that they found the tool to be intuitive, and that it 

helps to ensure consistency in designation. Finally, officials from the 

Transportation Security Administration noted that the tool is user friendly 

and provides consistency for managers.

Recently, we have seen indications that the Executive Agents are working 

to align their respective processes. According to OPM’s website, OPM 

has conferred with the Office of Management and Budget (OMB) 

concerning the possibility of reissuing pertinent sections of the Code of 

Federal Regulations jointly with ODNI, with a targeted issuance before 

the end of the 2012 calendar year. ODNI officials also stated their 

intention to work with OPM on the revision effort. ODNI officials further 

acknowledged that they are collaborating with OPM to reach agreement 

on their respective roles as Executive Agents. Our prior work has found 
 

Page 16 GAO-12-800 Security Clearances 

that two or more agencies with related goals can benefit from enhancing 

their collaboration in various areas to achieve common outcomes.22

According to Executive Order 12968, the number of employees that each 

agency determines is eligible for access to classified information shall be 

kept to the minimum required, and, subject to certain exceptions, eligibility 

shall be requested or granted only on the basis of a demonstrated, 

foreseeable need for access. Additionally, Executive Order 12968 states 

that access to classified information shall be terminated when an 

employee no longer has a need for access, and that requesting or 

approving eligibility for access in excess of the actual requirements is 

prohibited. Also, Executive Order 13467 authorizes the DNI to issue 

guidelines or instructions to the heads of agencies regarding, among 

other things, uniformity in determining eligibility for access to classified 

information. However, the DNI has not issued policies and procedures for 

agencies to review and revise or validate the existing clearance 

requirements for their federal civilian positions to ensure that clearances 

are kept to a minimum and reserved only for those positions with security 

clearance requirements that are in accordance with the national security 

needs of the time.

As previously noted, OPM published a December 2010 notice in the 

Federal Register of a proposed revision to the Code of Federal 

Regulations to clarify the policy for designating national security positions. 

Again, as we previously noted, OPM’s website states that OPM has 

conferred with OMB concerning the possibility of reissuing pertinent 

sections of the Code of Federal Regulations jointly with ODNI. One 

feature of the proposed revision would require all federal agencies to 

conduct a onetime review of position descriptions and requirements over 

a period of 2 years to ensure that all positions are properly designated 

using the revision’s updated definition for national security positions. 

Position descriptions not only identify the major duties and responsibilities 

of the position, but they also play a critical role in recruitment, training, 

 

22GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 

The areas for agencies to enhance collaboration include defining a common outcome; 

establishing joint strategies to achieve the outcome; agreeing upon agency roles and 

responsibilities; establishing compatible policies, procedures, and other means to operate 

across agency boundaries; and developing mechanisms to monitor, evaluate, and report 

the results of collaborative efforts.

The Executive Branch 

Does Not Have a 

Consistent Process 

for Reviewing and 

Validating Existing 

Security Clearance 

Requirements for 

Civilian Positions
 

Page 17 GAO-12-800 Security Clearances 

and performance management, among other things. While position 

descriptions may change, so can the national security environment as 

previously observed. 

During our review of several DHS and DOD components, we found that 

officials were aware of the need to keep the number of security 

clearances to a minimum but were not always subject to a requirement to 

review and validate the security clearance needs of existing positions on 

a periodic basis. We found, instead, that agencies’ policies provide for a 

variety of practices for reviewing the clearance needs of federal civilian 

positions. According to DHS guidance, supervisors are responsible for 

ensuring that (1) position designations are updated when a position 

undergoes major changes (e.g., changes in missions and functions, job 

responsibilities, work assignments, legislation, or classification 

standards), and (2) position security designations are assigned as new 

positions are created. Some components have additional requirements to 

review position designation more regularly to cover positions other than 

those newly created or vacant. For example,

• U.S. Coast Guard guidance23

• According to officials in U.S. Immigration and Customs Enforcement, 

supervisors are supposed to review position descriptions annually 

during the performance review process to ensure that the duties and 

responsibilities on the position description are up-to-date and 

accurate. However, officials stated that U.S. Immigration and Customs 

Enforcement does not have policies or requirements in place to 

ensure any particular level of detail in that review.

states that hiring officials and 

supervisors should review position descriptions even when there is no 

vacancy and, as appropriate, either revise or review them.

DOD’s personnel security regulation and other guidance24

 

23U.S. Coast Guard, CG-121, Civilian Hiring Guide for Supervisors and Managers, ver. 2

(June 11, 2010). 

provides DOD 

components with criteria to consider when determining whether a position 

is sensitive or requires access to classified information, and some of the 

components also have developed their own guidance.

24DOD 5200.2-R, Department of Defense Personnel Security Program (January 1987, 

reissued incorporating changes Feb. 23, 1996) as modified by Under Secretary of 

Defense Memorandum, Implementation of the Position Designation Automated Tool (May 

10, 2011). 
 

Page 18 GAO-12-800 Security Clearances 

• An Air Force Instruction requires commanders to review all military 

and civilian position designations annually to ensure proper level of 

access to classified information.25

• The Army issued a memorandum in 2006 that required an immediate 

review of position sensitivity designations for all Army civilian positions 

by the end of the calendar year and requires subsequent reviews 

biennially.26

• Officials from DOD’s Washington Headquarters Services told us that 

they have an informal practice of reviewing position descriptions and 

security designations for vacant or new positions, but they do not 

have a schedule for conducting periodic reviews of personnel security 

designations for already-filled positions.

That memorandum further states that if a review warrants 

a change in position sensitivity affecting an individual’s access to 

classified information, then access should be administratively adjusted 

and the periodic reinvestigation submitted accordingly. However, 

officials explained that improper position sensitivity designations 

continue to occur in the Army because they have a limited number of 

personnel in the security office relative to workload, and they only spot 

check clearance requests to ensure that they match the level of 

clearance required.

These various policies notwithstanding, agency officials told us that they 

are implemented inconsistently.

Some of the components we met were in the process of conducting a 

onetime review of position designation during our review. For example, 

Transportation Security Administration officials stated that they 

reevaluated all of their position descriptions over the last 2 years because 

the agency determined that the re-evaluation of its position designations 

would improve operational efficiency by ensuring that positions were 

appropriately designated by using OPM’s updated position designation 

tool. Further, those officials told us that they review position descriptions 

as positions become vacant or are created. Between fiscal years 2010 

and 2011, while the Transportation Security Administration’s overall 

workforce increased from 61,586 to 66,023, the number of investigations 

for top secret clearances decreased from 1,483 to 1,127. In March 2011, 

the Naval Audit Service begin an audit of its top secret requirements 

 

25Air Force Instruction 31-501, Personnel Security Program Management (Jan. 27, 2005).

26Army Director of Counterintelligence, Human Intelligence, Disclosure and Security 

Memorandum, Civilian Position Sensitivity Review (Dec. 31, 2006).
 

Page 19 GAO-12-800 Security Clearances 

determination process for civilian positions at selected activities to verify 

that civilian top secret clearances are based on valid requirements and 

that effective internal controls over the top secret requirements 

determination process are in place. According to a Navy official, the 

results of the audit were still undergoing the Navy’s internal review 

process as of May 2012.

There is a cost to conducting background investigations, and a potential 

for dollar savings when overdesignated positions are identified. DHS and 

DOD officials acknowledged to us that overdesignating a position can 

result in expenses for unnecessary investigations. When a position is 

overdesignated, additional resources are unnecessarily spent conducting 

the investigation and adjudication of a background investigation that 

exceeds agency requirements. As stated earlier in this report, the 

investigative workload for a top secret clearance is about 20-times greater 

than that of a secret clearance because it must be periodically 

reinvestigated twice as often as secret clearance investigations (every 5 

years versus every 10 years) and requires 10 times as many investigative 

staff hours. The fiscal year 2012 base price for a top secret clearance 

investigation conducted by OPM is $4,005 and the periodic 

reinvestigation is $2,711, while the base price of an investigation for a 

secret clearance is $260. Further, the base price of a Moderate Risk 

Background Investigation—most commonly used by DHS, according to 

officials—is $752. However, we did not find policies in which position 

designation reviews were linked to the position holders’ periodic 

reinvestigations. In contrast, underdesignating a position carries security 

risks, such as the potential release of classified information or the 

placement of a person in a position for which they have not been properly 

cleared.

Agencies employ varying practices because the DNI has not established 

a requirement that executive branch agencies consistently review and 

revise or validate existing position designations on a recurring basis. 

Such a recurring basis could include reviewing position designations 

during the periodic reinvestigation process. Without a requirement to 

consistently review, revise, or validate existing security clearance position 

designations, executive branch agencies—such as DHS and DOD—may 

be hiring and budgeting for both initial and periodic security clearance 

investigations using position descriptions and security clearance 

requirements that no longer reflect national security needs. Finally, since 

reviews are not being done consistently, DHS and DOD and other 

executive branch agencies cannot have reasonable assurances that they 

are keeping to a minimum the number of positions that require security 
 

Page 20 GAO-12-800 Security Clearances 

clearances on the basis of a demonstrated and foreseeable need for 

access. 

Executive Order 13467, issued in June 2008, established a Suitability and 

Security Clearance Performance Accountability Council and appointed 

the DNI as the Security Executive Agent and the Director of OPM as the 

Suitability Executive Agent. However, while the order gives the Executive 

Agents the authority to issue policy, the DNI has not provided executive 

branch agencies with clearly defined policy and procedures for 

determining whether federal civilian positions require a security 

clearance. Until the DNI articulates such policy and procedures, executive 

branch agencies, such as DHS and DOD, will not have a foundation on 

which to build consistent and uniform policies. Further, Executive Order 

13467 indicates that executive branch policies and procedures relating to, 

among other things, suitability and eligibility for access to classified 

information shall be aligned using consistent standards to the extent 

possible. However, OPM updated its position designation tool in 2010 

without input from the DNI. Without collaborative input from both OPM 

and DNI in future revisions to the tool, executive branch agencies will 

continue to risk making security clearance determinations that are 

inconsistent or at improper levels. Finally, while Executive Order 12968 

says that clearances should, subject to certain exceptions, be granted 

only on the basis of a demonstrated need for access and kept to a 

minimum, the DNI has not issued guidance that requires agencies to 

review and revise or validate their existing federal civilian position 

designations. Until the DNI does so, DHS and DOD, along with other 

executive branch agencies, cannot have reasonable assurances that all 

security clearance designations are correct, which could compromise 

national security if positions are underdesignated, or create unnecessary 

and costly investigative coverage if positions are overdesignated.

We recommend that the DNI, in coordination with the Director of OPM 

and other executive branch agencies as appropriate, issue clearly defined 

policy and procedures for federal agencies to follow when determining if 

federal civilian positions require a security clearance.

In addition, we recommend that, once the policy and procedures are 

issued, the DNI and the Director of OPM collaborate in their respective 

roles as Executive Agents to revise the position designation tool to reflect 

that guidance.

Conclusions 

Recommendations for 

Executive Action
 

Page 21 GAO-12-800 Security Clearances 

Finally, we recommend that the DNI, in coordination with the Director of 

OPM and other executive branch agencies as appropriate, issue 

guidance to require executive branch agencies to periodically review and 

revise or validate the designation of all federal civilian positions.

We provided a draft of this report to ODNI, OPM, DHS, and DOD for 

comment. Written comments from ODNI, OPM, and DHS are reprinted in 

their entirety in appendices IV, V, and VI respectively. Technical 

comments were provided separately by ODNI, OPM, and DHS, and were 

incorporated as appropriate. DOD concurred with the report without 

written comment. We also provided a draft of the report to OMB for 

information purposes.

In commenting on this report, ODNI stated that the report is a fair 

assessment of existing executive branch policies for determining security 

clearance requirements for federal civilian positions. The DNI has a lead 

or collaborative role in our recommendations, and ODNI concurred with 

all three. First, ODNI concurred with our recommendation that the DNI, in 

coordination with the Director of OPM and other executive branch 

agencies as appropriate, issue clearly defined policy and procedures for 

federal agencies to follow when determining if federal civilian positions 

require a security clearance. ODNI agreed that executive branch 

agencies require simplified and uniform policy guidance to assist in 

determining appropriate sensitivity designations, and cited steps it is 

taking in coordination with OPM, DOD, and OMB. Specifically, ODNI 

acknowledged its work with OMB and OPM to jointly issue revisions to 

part 732 of Title 5 of the Code of Federal Regulations by the end of 2012. 

Second, ODNI concurred with our recommendation that, once the policy 

and procedures are issued, the DNI coordinate with the Director of OPM 

to revise the position designation tool to reflect that guidance. ODNI 

stated that it plans to work with OPM and other executive branch 

agencies through the Security Executive Agent Advisory Committee to 

develop a position designation tool that provides detailed descriptions of 

the types of positions where the occupant could bring about a material 

adverse impact to national security due to the duties and responsibilities 

of the position. ODNI stated its belief that a tool that provides agencies 

with detailed descriptions of this type will bring about greater uniformity 

across the government in agency position designations. Third, ODNI 

concurred with our recommendation that the DNI, in coordination with the 

Director of OPM and other executive branch agencies as appropriate, 

issue guidance to require executive branch agencies to periodically 

Agency Comments 

and Our Evaluation

ODNI Comments
 

Page 22 GAO-12-800 Security Clearances 

review and revise or validate the designation of all federal civilian 

positions. ODNI agreed with our assessment that the duties and 

responsibilities of federal positions may be subject to change, and stated 

that it plans to work with OPM and other executive branch agencies 

through the Security Executive Agent Advisory Committee to ensure that 

position designation policies and procedures include a provision for 

periodic reviews.

While ODNI recognized that the emphasis of this report is on civilian 

positions that require access to classified information, it wished to 

emphasize that the DNI’s role as Security Executive Agent under 

Executive Order 13467 applies to all sensitive positions, and that 

positions that require access to classified information are a subset of all 

sensitive positions. ODNI stated that any guidance issued by the Security 

Executive Agent will cover all sensitive positions and associated 

investigative standards and adjudicative guidelines.

OPM also commented on all three of the recommendations in this report 

in its written comments. OPM concurred with our second 

recommendation, which is addressed more directly to OPM, that its 

Director collaborate with the DNI in their respective roles as executive 

agents to revise the position designation tool to reflect updated federal 

position designation guidance. OPM stated that it committed to doing so 

in a February 2010 strategic framework document which was executed by 

officials within OMB, OPM, DOD, and ODNI. OPM also acknowledged 

that any revisions to the tool need to await final action with respect to 

proposed position designation regulations, which is consistent with our 

recommendation. In addition, OPM summarized executive orders that 

describe its authority. OPM also supported our third recommendation that 

the DNI, in coordination with the Director of OPM and other executive 

branch agencies as appropriate, issue guidance to require executive 

branch agencies to periodically review and revise or validate the 

designation of all federal civilian positions. OPM stated that it would be 

pleased to work with the DNI on guidance concerning periodic reviews of 

existing designations. 

While ODNI concurred with our first recommendation—that the DNI, in 

coordination with the Director of OPM and other executive branch

agencies as appropriate, issue clearly defined policy and procedures for 

federal agencies to follow when determining whether federal civilian 

positions require a security clearance—OPM stated that it is not clear to 

OPM that it has a significant role in prescribing the policy and procedures 

OPM Comments
 

Page 23 GAO-12-800 Security Clearances 

for federal agencies to follow when determining if a federal civilian 

position requires a security clearance. The basis for OPM’s statement is 

Executive Order 12968 (as amended by Executive Order 13467), which 

gives agency heads the ultimate responsibility to grant or deny security 

clearances, subject to investigative standards and adjudicative guidelines 

prescribed by the DNI. In this report, we acknowledge that authority to 

grant or deny a security clearance resides with agency heads under 

Executive Order 12968. However, as we also state in our report, 

Executive Order 13467 provides the DNI the authority to issue guidelines 

and instructions to the heads of agencies to ensure appropriate 

uniformity, centralization, efficiency, effectiveness, and timeliness in 

processes relating to determinations by agencies of eligibility for access 

to classified information or eligibility to hold a sensitive position. Further, 

as we state in our report, this Executive Order established a Suitability 

and Security Clearance Performance Accountability Council to be the 

government-wide governance structure responsible for driving 

implementation and overseeing security and suitability reform efforts. This 

order appointed the DNI as the Security Executive Agent and the Director 

of OPM as the Suitability Executive Agent, and calls for investigations of 

suitability and security to be aligned using consistent standards, to the 

extent practicable. Therefore, we continue to believe that additional 

guidance from the Security Executive Agent—the DNI—would help align 

processes across multiple executive branch agencies, and note that 

ODNI agreed with this assessment. Further, we included OPM in our 

recommendation as a consulting agency in its role as the Suitability 

Executive Agent and because, according to OPM, it is the investigative 

service provider for much of the executive branch. Finally, we 

recommended that the DNI work with other agencies as necessary in an 

acknowledgement of the joint nature of reform effort and its oversight 

structure through the Performance Accountability Council. 

OPM’s response to this report discussed other points for consideration, 

which are summarized below. 

Relationship between the existing position designation tool and security 

clearances: OPM stated in its comments that one of the premises upon 

which this report is based is not accurate. Specifically, OPM asserted that 

we repeatedly posited that agencies must perform the national security 

designation in order to know whether the occupant will require a security 

clearance when, in fact, whether the occupant of a particular position will 

need access to classified information or eligibility for such access (i.e. a 

security clearance) is one of the factors that help determine whether a 

position is sensitive. Accordingly, OPM wrote that there is no basis for 
 

Page 24 GAO-12-800 Security Clearances 

GAO to conclude that OPM’s position designation tool affects how 

agencies determine whether the occupant of a position requires access to 

classified information or eligibility for such access. We state in our report 

that to assist with position designation, the Director of OPM has 

developed a process that includes a position designation system and 

corresponding tool. We continue by stating that the tool does not directly 

determine whether a position requires a clearance, but rather helps 

determine the sensitivity of the position, which informs the type of 

investigation needed. We believe that these statements are consistent 

with OPM’s explanations and, therefore, do not believe that one of the 

premises upon which this report is based is inaccurate. However, we 

have reviewed and made revisions to other statements in our final report 

to ensure consistency with this point.

Additional need for guidance to support the position designation tool: 

OPM noted that it provided us with copies of audits that OPM had 

performed on agencies that employ competitive service civilian personnel, 

where it observed inconsistencies in agency application of the tool. In its 

comments, OPM cited several reasons why this might happen. We 

believe this is consistent with our findings that OPM found examples of 

inconsistency between agency position designation and OPM guidance, 

and also that officials from executive branch departments expressed 

varying opinions to us regarding the tool. In response to other discussion 

in our report about the tool, OPM stated that its proposed revision to part 

732 of Title 5 of the Code of Federal Regulations was intended to 

establish a basis for more detailed guidance. We also note, as previously 

discussed, that OPM concurred with our recommendation to collaborate 

with the DNI to revise the tool.

In its written comments, DHS noted GAO’s positive acknowledgement of 

DHS’ efforts to ensure that only those who need a security clearance are 

authorized one. Although the report does not contain any 

recommendations specifically directed to DHS, the Department stated 

that it remains committed to being an active member of the governmentwide Suitability and Security Clearance Performance Accountability 

Council.

We are sending copies of this report to the House Committee on 

Homeland Security. We are also sending copies to the Director of

National Intelligence, the Director of the Office of Personnel Management, 

the Secretary of Homeland Security, the Secretary of Defense, and the 

DHS Comments
 

Page 25 GAO-12-800 Security Clearances 

Office of Management and Budget. This report will also be available at no 

charge on the GAO website at http://www.gao.gov. 

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

me at (202) 512-3604 or farrellb@gao.gov. Contact points for our Offices 

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

page of this report. GAO staff who made major contributions to this report 

are listed in appendix VII. 

Sincerely yours,

Brenda S. Farrell

Director, Defense Capabilities and Management
Appendix I: Scope and Methodology

Page 26 GAO-12-800 Security Clearances 

This report reviewed government policies and practices for identifying 

federal civilian positions that require security clearances, and analyzed 

whether a uniform, consistent, and effective security clearance 

requirements determination process is in place. Our work focused on the 

Office of the Director of National Intelligence (ODNI), on the basis of its 

role to develop personnel security clearance policy and guidance for the 

federal government. Further, the scope of our work focused more 

specifically on the security clearance requirements of federal civilian 

positions from selected components within the Department of Homeland 

Security (DHS) and the Department of Defense (DOD), because of the 

volume of clearances that these two agencies process. Within DHS, 

selected components include the U.S. Coast Guard, U.S. Immigration and 

Customs Enforcement, and the Transportation Security Administration. 

Within DOD, selected components include the headquarters level 

elements of the Departments of the Army, the Navy, the Air Force, and 

the Washington Headquarters Services. We also included the Office of 

Personnel Management (OPM) in our review on the basis of its role 

implementing security clearance reform and as the primary investigative 

service provider of the federal government. See table 1 for a complete list 

of the agencies and departments interviewed for our review.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 27 GAO-12-800 Security Clearances 

Table 1: Executive Branch Agencies and Offices Interviewed

Executive branch agency Associated departments and offices

Department of Homeland Security (DHS) • Office of the Chief Human Capital 

Officer

• Office of the Chief Security Officer

• U.S. Coast Guard

• U.S. Immigration and Customs 

Enforcement

• Transportation Security Administration

Department of Defense (DOD) • Office of the Undersecretary of 

Defense for Intelligence

• Office of the Undersecretary of 

Defense for Personnel and Readiness

• Army’s Office of the Deputy Chief of 

Staff (G-2)

• Army’s Personnel Security 

Organization (G-3/5/7)

• Army’s Human Resources Program 

Development Division

• Air Force’s Manpower Agency and 

Central Civilian Classification Office

• Air Force’s Personnel Security Office

• Head of Security Policy (Personnel, 

Information, and Industrial) for the 

Navy

• Navy Office of Civilian Human 

Resources

• Washington Headquarters Services

• Defense Manpower and Data Center

Office of Personnel Management (OPM) • Federal Investigative Services

Office of the Director of National 

Intelligence(ODNI)

• Joint Reform Team representatives

Source: GAO.

To determine the extent to which the executive branch has established 

policies and procedures for agencies to use when first determining 

whether federal civilian positions require a security clearance, we 

interviewed key federal officials from the above mentioned federal 

agencies and selected components, as well as OPM and ODNI. We 
Appendix I: Scope and Methodology

Page 28 GAO-12-800 Security Clearances 

reviewed relevant Executive Orders including 10450, 12968, and 13467,1

Joint Reform Team2 reports, OPM and ODNI audits, and part 732 of Title 

5 of the Code of Federal Regulations3

To determine the extent to which the executive branch has established 

policies and procedures for agencies to review and revise or validate 

existing federal civilian position security clearance requirements, we 

interviewed knowledgeable officials from the federal agencies and 

selected components in table 1. We reviewed part 732 of Title 5 of the 

Code of Federal Regulations to identify the extent to which it delineates 

processes and responsibilities for federal agencies to review and revise 

or validate whether federal civilian positions require a security clearance. 

We also analyzed DHS’s and DOD’s personnel security policies, and the 

applicable policies of selected components within these departments to 

identify the extent to which each department and selected component has 

. We also reviewed OPM’s 

proposed revision to the Code of Federal Regulations, which aims to 

clarify the policy for designating national security positions that was 

published in the Federal Register in December 2010. We obtained and 

analyzed personnel security clearance policies within DHS, DOD, and the 

selected components within these departments to identify the extent to 

which they have outlined processes for individuals responsible for 

determining if federal civilian positions require a security clearance. In 

addition, we obtained and analyzed OPM’s position designation system 

and tool because agencies we visited use the tool in the position 

designation process.

 

1

Executive Order No. 10450, Security Requirements for Government Employment (Apr. 

27, 1953 as amended), Executive Order No. 12968, Access to Classified Information

(Aug. 2, 1995 as amended), Executive 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).

2

In 2007, DOD and the Office of the Director of National Intelligence formed the Joint 

Security Clearance Process Reform Team, known as the Joint Reform Team, to execute 

joint reform efforts to achieve timeliness goals and improve the processes related to 

granting security clearances and determining suitability for government employment. 

Agencies included in this government-wide reform effort include the Office of Management 

and Budget, OPM, ODNI, and DOD’s Office of the Undersecretary of Defense for 

Intelligence.

3

5 C.F.R. part 732 addresses national security positions within the federal government

including the competitive service, the Senior Executive Service, and certain excepted 

service positions.
Appendix I: Scope and Methodology

Page 29 GAO-12-800 Security Clearances 

established processes for reviewing, revising, and validating existing 

federal civilian position security clearance requirements.

We conducted this performance audit from July 2011 through July 2012 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our objectives.
Appendix II: Position Designation Guidance

Page 30 GAO-12-800 Security Clearances 

The Department of Homeland Security (DHS), the Department of Defense 

(DOD), and their respective components have developed policies and 

procedures that relate to position designation. Both DHS and DOD 

policies provide criteria, in addition to those outlined in the Office of 

Personnel Management’s (OPM) tool, for position designating officials to 

use in determining the sensitivity level of the position. Table 2 below 

provides a descriptive comparison of DHS- and DOD-specific position 

designation guidance.

Table 2: Summary of Selected DHS and DOD Position Designation Guidance

Clearance level Sensitivity level DHS criteria DOD criteria

Top Secret / Sensitive 

Compartmented 

Information 

Special-Sensitive

(positions with the 

potential to cause

inestimable damage to 

the national security) 

Any position designated at a level 

higher than Critical-Sensitive by a 

document that complements 

Executive Order 10450 and 

Executive Order 12968.

Positions that require access to Sensitive 

Compartmented Information (SCI).

Positions that require access to unique or 

uniquely productive intelligence sources or 

methods vital to the United States security.

Positions that could cause inestimable 

damage and/or compromise technologies, 

plans, or procedures vital to the strategic 

advantage of the United States. Any other 

positions designated by appropriate 

officials.

Top Secret Critical-Sensitive

(positions with the 

potential to cause

exceptionally grave 

damage to the national 

security)

Positions that have the potential 

to cause exceptionally grave 

damage to the national security. 

These positions may include 

access up to, and including, Top 

Secret national security 

information or materials; or other 

positions related to national 

security, regardless of duties, that 

require the same degree of trust.

Access to Top Secret information.

Development or approval of plans, 

policies, or programs that affect the overall 

operations of DOD or DOD component.

Development or approval of war plans.

Investigative and certain investigative 

support duties, the issuance of personnel 

security clearances or the making of 

personnel security determinations.

Fiduciary, public contact, or other duties.

Duties falling under Special Access 

programs.

Category I automated data processing 

positions responsible for, among other 

things, the development and 

administration of agency computer security 

programs.

Any other position so designated by the 

Head of the DOD component or designee.

Appendix II: Position Designation Guidance 
Appendix II: Position Designation Guidance

Page 31 GAO-12-800 Security Clearances 

Clearance level Sensitivity level DHS criteria DOD criteria

Secret or Confidential Noncritical-Sensitive

(positions with the 

potential to cause serious 

damage to the national 

security)

Positions that have the potential 

to cause serious damage to the 

national security. These positions 

involve either access to Secret or 

Confidential national security 

information materials, or duties 

that may adversely affect, directly 

or indirectly, the national security 

operations of the Department.

Access to Secret or Confidential 

information.

Security police / provost marshal-type 

duties involving the enforcement of law 

and security duties involving the protection 

and safeguarding of DOD personnel and 

property.

Category II automated data processing 

positions responsible for, among other 

things, systems design, operation, testing, 

maintenance, and monitoring under 

technical review of Category I automated 

data processing positions.

Duties involving education and orientation 

of DOD personnel.

Duties involving the design, operation, or 

maintenance of intrusion detection 

systems deployed to safeguard DOD 

personnel and property.

Any other position so designated by the 

Head of the DOD component or designee.

Source: DHS and DOD.

Note: Data are from DHS, Management Instruction 121-01-007, The Department of Homeland 

Security Personnel Suitability and Security Program (June 2009), and DOD, Enclosure to the Under 

Secretary of Defense for Personnel and Readiness Memorandum, Implementation of the Position 

Designation Automated Tool (May 10, 2011). 

DHS’s management instruction regarding the personnel security and 

suitability program (DHS Management Instruction 121-01-007) defines 

sensitivity levels and instructs the DHS components to follow OPM’s 

position sensitivity designation guidance when determining the proper 

sensitivity level for civilian positions. Further, the supervising official with 

sufficient knowledge of duty assignments is responsible for collaborating 

with Human Resources and assigning position sensitivity designations 

and then those designations are subject to final approval by the 

component’s respective Personnel Security Office.

Immigration and Customs Enforcement: In addition to DHS’s 

management directive, Immigration and Customs Enforcement officials 

confirmed that they are using OPM’s position sensitivity designation 

guidance and position designation tool to ensure that their civilian 

positions have the proper sensitivity level. According to these officials, the 

Immigration and Customs Enforcement’s Office of Professional 

Responsibility and Office of Human Capital work with the program offices 

to establish and validate position security designations.

Department of 

Homeland Security
Appendix II: Position Designation Guidance

Page 32 GAO-12-800 Security Clearances 

Transportation Security Administration: In addition to DHS’s management 

directive, the Transportation Security Administration developed informal 

guidance on the position designation process and uses OPM’s position 

designation tool to determine the sensitivity level for its positions. The 

Transportation Security Administration Personnel Security Section 

requires the manager to confirm that access to classified information is 

required to perform the duties of the position. In addition, the 

Transportation Security Administration’s Personnel Security Section does 

a final review of all position and risk designations.

U.S. Coast Guard: According to U.S. Coast Guard officials, the U.S. 

Coast Guard follows the criteria for position designation laid out in the 

Commandant of the Coast Guard Instruction 5520.12C, Personnel 

Security and Suitability Program. In addition, those officials indicated that 

the U.S. Coast Guard uses OPM’s position designation tool for 

determining the sensitivity level for civilian positions. As part of a standard 

hiring practice, supervisors engage Human Resources with a request for 

personnel action. This initiates the prerecruitment phase of the process 

where the need of the position is validated, the position description is 

reviewed and updated, the job analysis is confirmed, and the recruitment 

strategy is executed.

DOD’s personnel security regulation and other guidance1

• to persons in nonsensitive positions;

provide the 

DOD components with detailed criteria to consider when determining 

whether a position requires access to classified information. Although 

DOD’s policy is also under revision, the current policy incorporates OPM’s 

definitions for critical-sensitive and noncritical sensitive positions. Further, 

DOD’s regulation specifically states that personnel security clearances 

shall not normally be issued:

• to persons whose regular duties do not require authorized access to 

classified information;

• for ease of movement of persons within a restricted area whose duties 

do not require access to classified information;

 

1

DOD 5200.2-R, Department of Defense Personnel Security Program (January 1987, 

reissued incorporating changes Feb. 23, 1996) as modified by Under Secretary of 

Defense for Personnel and Readiness Memorandum, Implementation of the Position 

Designation Automated Tool (May 10, 2011).

Department of 

Defense 
Appendix II: Position Designation Guidance

Page 33 GAO-12-800 Security Clearances 

• to persons who may only have inadvertent access to sensitive 

information or areas, such as guards, emergency service personnel, 

firefighters, doctors, nurses, police, ambulance drivers, or similar 

personnel;

• to persons working in shipyards whose duties do not require access to 

classified information;

• to persons who can be prevented from accessing classified 

information by being escorted by cleared personnel;

• to food service personnel, vendors and similar commercial sales or 

service personnel whose duties do not require access to classified 

information;

• to maintenance or cleaning personnel who may only have inadvertent 

access to classified information unless such access cannot be 

reasonably prevented;

• to persons who perform maintenance on office equipment, computers, 

typewriters, and similar equipment who can be denied classified 

access by physical security measures;

• to perimeter security personnel who have no access to classified 

information; and

• to drivers, chauffeurs and food service personnel.

In addition, DOD’s Under Secretary of Defense for Personnel and 

Readiness issued a memorandum requiring the use of OPM’s position 

designation system and tool to determine the sensitivity level for civilian 

positions. Further, some of the DOD components that we visited have 

developed policies that extend beyond the DOD personnel security policy.

Army: Army officials affirmed that they use OPM’s position designation 

tool to determine the sensitivity level of all civilian positions. In addition, 

Army Regulation 380-67 defines sensitive positions and gives heads of 

DOD components or their designees authority, subject to certain 

conditions, to delegate the designation of position sensitivity within their 

chain of command. Further, a 2006 Army memorandum called for 

sensitivity reviews of all Army civilian positions every 2 years, at a 

minimum.

Navy: According to officials, the Department of the Navy follows guidance 

in the Secretary of the Navy Regulation M-5510.30 along with DOD’s 

personnel security regulation, which requires designators to set the

clearance level for civilian personnel according to the risk the position 

poses. According to a Navy personnel security official, Human Resources 

offices and local commands have been revalidating positions according to 

the needs of the command in response to a 2011 memorandum from the 
Appendix II: Position Designation Guidance

Page 34 GAO-12-800 Security Clearances 

Assistant Secretary of the Navy for Manpower and Reserve Affairs. 

According to Navy officials, Human Resources offices used the position 

designation tool provided by OPM to determine the sensitivity level for all 

civilian positions.

Air Force: The Air Force uses Air Force Instruction 31-501 coupled with 

the DOD 5200.2-R to implement its personnel security program. 

According to the instruction, commanders with position designation 

authority determine the security sensitivity of civilian positions. Each 

position is coded with the appropriate security access requirement and 

identified in the unit manning document and the Defense Civilian 

Personnel Data System. If the security access requirement code requires 

a change, the unit commander submits an authorization change request 

to the servicing security activity. The commander also conducts an annual 

review of positions to determine the accuracy of position coding and 

adjust coding if necessary. Air Force officials confirmed that they are 

using OPM’s Position Designation System and Tool to determine the 

proper sensitivity level for all civilian positions. Also, according to Air 

Force officials, in situations where a commander wants to upgrade a 

particular position, it must be reviewed and approved by a 3-star general.

Washington Headquarters Services: Washington Headquarters Services 

oversees position designation for certain DOD headquarters activities and 

defense agencies. According to Washington Headquarters Services 

officials, these agencies and activities follow DOD’s personnel security 

regulation for position designation and use OPM’s position designation 

system and tool in accordance with DOD policy.2

 

2

See Washington Headquarters Services memorandum entitled Implementation of the 

Position Designation Automated Tool (Sept. 27, 2011).
Appendix III: Personnel Security Clearance 

Process

Page 35 GAO-12-800 Security Clearances 

Since 1997, federal agencies have followed a common set of personnel 

security investigative standards and adjudicative guidelines for 

determining whether federal workers and others1 are eligible to receive 

security clearances.2

• The application submission phase. A security officer from an 

executive branch agency (1) requests an investigation of an individual 

requiring a clearance; (2) forwards a personnel security questionnaire 

(Standard Form 86) using the Office of Personnel Management’s 

(OPM) e-QIP system or a paper copy of the Standard Form 86 to the 

individual to complete; (3) reviews the completed questionnaire; and 

(4) sends the questionnaire and supporting documentation, such as 

fingerprints and signed waivers, to OPM or the investigation service 

provider.

Once an applicant is selected for a position that 

requires a security clearance, government agencies rely on a multiphased 

personnel security clearance process that includes the application 

submission phase, investigation phase, and adjudication phase, among 

others. Different departments and agencies may have slightly different 

security clearance processes—the steps outlined below are intended to 

be illustrative of a typical process.

• The investigation phase. Federal investigative standards and OPM’s 

internal guidance are typically used to conduct and document the 

investigation of the applicant. The scope of information gathered in an 

investigation depends on the level of clearance needed and whether 

the investigation is for an initial clearance or a reinvestigation for a 

clearance renewal. For example, in an investigation for a top secret 

clearance, investigators gather additional information through more 

time-consuming efforts, such as traveling to conduct in-person 

interviews to corroborate information about an applicant’s employment 

and education. After the investigation is complete, the resulting 

investigative report is provided to the agency.

 

1

Others include military servicemembers and private industry personnel; however, the 

scope of this report is federal civilian workers.

2

Memorandum from Samuel Berger, Assistant to the President for National Security 

Affairs, to George J. Tenet and John P. White, Co-Chairmen, Security Policy Board, 

Implementation of Executive Order 12968 (Mar. 24, 1997). This memorandum approves 

the adjudication guidelines, temporary eligibility standards, and investigative standards 

required by Executive Order 12968, Access to Classified Information (Aug. 2, 1995), as 

amended. The standards were later published in 32 C.F.R. Part 147. Further, the 

standards were updated in 2005; however, those updates are not currently reflected at 32 

C.F.R. Part 147.

Appendix III: Personnel Security Clearance 

Process
Appendix III: Personnel Security Clearance 

Process

Page 36 GAO-12-800 Security Clearances 

• The adjudication phase. Adjudicators from an agency use the 

information from the investigative report to determine whether an 

applicant is eligible for a security clearance. To make clearance 

eligibility decisions, the adjudication guidelines specify that 

adjudicators consider 13 specific areas that elicit information about (1) 

conduct that could raise security concerns and (2) factors that could 

allay those security concerns and permit granting a clearance.

In addition, once the background investigation and adjudication for a 

security clearance are complete, the requesting agency determines 

whether the individual is eligible for access to classified information. 

However, often the security clearance—either at the secret or top secret 

level—does not become effective until an individual needs to work with 

classified information. At that point, the individual would sign a 

nondisclosure agreement and receive a briefing in order for the clearance 

to become effective. DOD commonly employs this practice and, in some 

cases, the individual ultimately never requires access to classified 

information. Therefore, not all security clearance investigations result in 

an active security clearance.

Finally, once an individual is in a position that requires access to 

classified national security information, that individual is reinvestigated 

periodically at intervals that are dependent on the level of security 

clearance. For example, top secret clearanceholders are reinvestigated 

every 5 years, and secret clearanceholders are reinvestigated every 10 

years.
Appendix IV: Comments from the Office of the 

Director of National Intelligence

Page 37 GAO-12-800 Security Clearances 

Appendix IV: Comments from the Office of 

the Director of National Intelligence
Appendix IV: Comments from the Office of the 

Director of National Intelligence

Page 38 GAO-12-800 Security Clearances 
Appendix IV: Comments from the Office of the 

Director of National Intelligence

Page 39 GAO-12-800 Security Clearances 
Appendix V: Comments from the Office of 

Personnel Management

Page 40 GAO-12-800 Security Clearances 

Appendix V: Comments from the Office of 

Personnel Management
Appendix V: Comments from the Office of 

Personnel Management

Page 41 GAO-12-800 Security Clearances 
Appendix V: Comments from the Office of 

Personnel Management

Page 42 GAO-12-800 Security Clearances 
Appendix V: Comments from the Office of 

Personnel Management

Page 43 GAO-12-800 Security Clearances 
Appendix V: Comments from the Office of 

Personnel Management

Page 44 GAO-12-800 Security Clearances 
Appendix VI: Comments from the Department 

of Homeland Security

Page 45 GAO-12-800 Security Clearances 

Appendix VI: Comments from the 

Department of Homeland Security
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 46 GAO-12-800 Security Clearances 

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov

In addition to the contact named above, David Moser (Assistant Director), 

Sara Cradic, Cynthia Grant, Nicole Harris, Jeffrey Heit, Kimberly Mayo, 

Richard Powelson, Jason Wildhagen, Michael Willems, and Elizabeth 

Wood made key contributions to this report.

Appendix VII: GAO Contact and Staff

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 
Related GAO Products

Page 47 GAO-12-800 Security Clearances 

Personnel Security Clearances: Continuing Leadership and Attention Can 

Enhance Momentum Gained from Reform Effort. GAO-12-815T. 

Washington, D.C.: June 21, 2012.

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.

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

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 Security Clearance Reform: Preliminary Observations on 

Timeliness and Quality. GAO-11-185T. Washington, D.C.: November 16, 

2010.

Privacy: OPM Should Better Monitor Implementation of Privacy-Related 

Policies and Procedures for Background Investigations. GAO-10-849. 

Washington, D.C.: September 7, 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 

Related GAO Products
Related GAO Products

Page 48 GAO-12-800 Security Clearances 

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 

22, 2009.

DOD Personnel Clearances: Preliminary Observations about Timeliness 

and Quality. GAO-09-261R. Washington, D.C.: December 19, 2008.

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: Questions for the Record Regarding Security 

Clearance Reform. GAO-08-965R. Washington, D.C.: July 14, 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.

DOD Personnel Clearances: Questions for the Record Related to the 

Quality and Timeliness of Clearances. GAO-08-580R. Washington D.C.: 

March 25, 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 12, 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: 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.
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Page 49 GAO-12-800 Security Clearances 

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: 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.

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.

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.

(351644)
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